Privacy & cookies

This Privacy Notice is issued by Morses Club Scheme Limited (we, us, our) and is addressed to customers that we interact with regarding the proposed Scheme of Arrangement (the Scheme). For further details on the Scheme, please see the Practice Statement Letter (PSL) available on the Scheme portal at https://www.morsesclubscheme.com/, or contact us at [email protected].

The following information is only intended to cover Morses Club Scheme Limited’s processing of personal data relating to, or in connection with administering, the Scheme. For information regarding Morses Club Limited's processing of personal data in relation to its activities as a lender, please visit: https://www.morsesclub.com/privacy-notice.

This Privacy Notice may be amended or updated from time to time to reflect changes in our practices, the way we collect and use your information, or changes in the law.

We encourage you to read this Privacy Notice carefully, and to check this page from time to time to review any changes we might make to it.

Our lawful basis for processing your personal data

Where you provide personal data in relation to the Scheme, including by creating an account on or otherwise providing information through the Scheme portal or by voting on the Scheme, we will use, store and otherwise process such personal data for our legitimate interests in administering the Scheme and establishing, exercising or defending legal claims.

If the Scheme is approved and you subsequently make a claim under it, we will use, store and otherwise process personal data you provide or which we otherwise collect in relation to the claim, for our legitimate interests in administering the Scheme, including contacting you in relation to your claim and establishing, exercising or defending legal claims.

We will process your information as per our contractual and legal obligations and to ensure we are acting responsibly and fairly. This includes:

• Performing adequate checks (including seeking supporting information such as your personal data where required) to confirm your identity and to ensure you are eligible to make a Redress Claim under the Scheme (as defined in the PSL)
• Identifying claims that will not be dealt with under the Scheme
• Assessing, determining and administering any potential claim you make if the Scheme is approved (including via court proceedings)
• Responding to and complying with any regulatory requirements (i.e. our obligations concerning the Financial Conduct Authority or Financial Ombudsman Service) and legal obligations (i.e. court judgments)

If you or any third party referred below provide us with any special category data in relation to any claim under the Scheme, for example any health information, we will process this on the basis that it is necessary for the establishment, exercise or defence of legal claims, or reasons of substantial public interest in relation to the safeguarding of your economic wellbeing, for example, in order to ensure that any health condition we have been made aware of is duly considered in relation to any claim you make under the Scheme. 

How we collect your personal data

We will collect personal data:

• That you provide to us directly through our website, including through creating an account on the online portal, and through voting on the Scheme
• That you provide in reference to making a claim under the Scheme if it is approved
• Where necessary, from third parties such as banks, credit reference and fraud prevention agencies, and other organisations that help us make decisions or assessments under the Scheme
• That you, or third parties, have previously provided to Morses Club Limited, or its affiliates, in connection with applying and taking out a loan from them, in accordance with the relevant Privacy Notice made available to you when that information was collected
• That Morses Club Limited provides to us in relation to loans you have taken out with them, where relevant for assessing, determining and administering a claim made under the Scheme (if it is approved)

What personal data we will collect

We will collect any personal data we need from you and the third parties noted above in order for you to participate in voting on the Scheme and, if approved, make a claim in relation to it, as well as any other information which we reasonably need to make decisions about you or your claim or fulfil our obligations under the Scheme.

The information we will collect about you includes:

• Your name, date of birth, address and contact information (i.e. phone number and email address)
• Details of how you vote in relation to the Scheme, including any written comments you provide during the voting process
• If the Scheme is approved, details of any claim you make under it
• Documents to verify your information (including, without limitation, bank statements or payslips)
• Information we collect as part of assessing and making a decision about you or any claim you make under the Scheme
• Any special category data (including relevant health information) about you that needs to be considered when assessing, determining and administering any claim under the Scheme
• Details of the Morses Club Limited loans you have taken out (including customer reference and loan agreement numbers) and all transactions relating to these
• Card and bank account information. If you provide us with any debit card and bank details, either via a claim under the Scheme or subsequently, we will retain those details and use them to fulfil our obligations under the Scheme, unless you advise us otherwise
• Information about your computer including your IP address, operating system and browser type. For more details, please see our Cookie Policy
• Your experience on our website or the Scheme portal for usability monitoring, testing and improvement. We will not, however, record any personal data you submit through the Scheme Portal for such monitoring and testing.
• Recording and/or monitoring any written, verbal or electronic communication between you and us.

How we will use your personal data

We will use your information to progress all aspects of the administration of the Scheme and to review and determine the validity of any claims, and administer any proven claims, made under the Scheme if it is approved.

We will use your personal data:

• To operate your account on the Scheme portal and any manage any correspondence you may have with us
• To determine whether you are a Redress Creditor and to organise the Creditor Meeting
• To administer the voting process in relation to the Scheme
• To determine, adjudicate on, and administer any claim you may make under the Scheme if it is approved (including obtaining advice from third party service providers in relation to claims).
• To contact you (using any contact details that you have given to us) via email, SMS, letter or telephone, or to send you push notifications about the Scheme and any claim you may make under it if it is approved
• To respond to complaints or other correspondence from you
• To advise Morses Club Limited of any determined claim made under the Scheme
• To exercise our rights set out in agreements or contracts and to comply with our legal obligations

Retention of your personal data

If you have an account on our Scheme portal, we will store your information for one year from the date you vote on the Scheme or, if the Scheme is approved, for such period as is required in connection with the administration and determination of any claims you make under the Scheme.

If you make a claim under the Scheme, we will keep your information until your claim has been administered in full. Once your claim has been administered in full, and providing we have no ongoing relationship with you or any lawful reason to keep your data, we will remove your information seven years after the full administration of your claim.

Who we will share your personal data with

We will share your personal data with:

• Morses Club Limited:
  • for the purposes of Morses Club Limited employees (on behalf of the Scheme):
    • Managing your account and details on the Scheme portal
    • Responding to your queries and complaints
    • Processing any claim you may make under the Scheme if it is approved
    • Auditing our internal processes
    • Testing our systems
  • for the purpose of Morses Club Limited updating your contact details in their systems, to ensure they have your latest details and can continue to contact you in accordance with your preferences
  • for the purpose of ensuring Morses Club Limited is aware of and can assess any information necessary to safeguard your economic wellbeing (including health information or other factors)
  • for the purposes of managing the determination of any claim, including offsetting amounts against loans made by Morses Club Limited
  • where there is another lawful and legitimate reason to do so.
• The Scheme Supervisors
• The Scheme Adjudicator
• Companies who verify your information for us
• Third party service providers as necessary, including:
  • companies who help us document, record, assess and test our internal processes and systems
  • companies who help us in relation to the assessment, determination and administration of claims in relation to the Scheme
  • mail house and telecommunications companies we use to send you communication via text, email and letter
  • companies who store your information on our behalf
• Any regulator with jurisdiction in relation to the Scheme
• Any party where we are legally obliged to

Because of the nature of our business and the other organisations we work with, we may transfer your information to other countries. We will only transfer your information so that it may be used as we have described. These other countries may have different laws regarding the use of your information than those that apply in the UK.

We will not transfer your data out of the European Economic Area (EEA) to any country that has been deemed (by the European Commission) to have inadequate data protection controls, except where such transfers are lawful under data protection law, including where we implement appropriate safeguards in relation to the transfer such as EU Commission’s Standard Contractual Clauses (SCCs), or their UK equivalents. You can contact using the details below for further information on these safeguards.

Your data subject rights

You have the right to ask us to confirm what personal data we hold about you at any time (by making a subject access request) and to access such personal data. You may ask us to rectify your personal data where it is inaccurate. You may ask us to delete or restrict the processing of your personal data in certain circumstances. You also have the right to object to the way we use your information in certain circumstances, including where we process your personal data on the basis of legitimate interest.

If we are using your personal data because we deem it necessary to do so, and you do not agree, you have the right to ask to remove your information or ask us to stop processing it. In cases where you ask us not to contact you, we may still hold your personal data so that we know not to use it to contact you.

If you request us to delete your information, we will only refuse your request if we are of the view that it is necessary to keep your information and we are legally obliged or permitted to do so, or we have the legal right to process the information for another specific reason, for example, if you have an ongoing relationship with us.

Where we have obtained your consent to process your personal data for certain activities, you may withdraw your consent at any time (provided that this will not affect the lawfulness of any processing that was based on your consent prior to such withdrawal).

You may also have the right to instruct us to provide you with a copy of your data in a structured and electronic format so that you can pass it to a third party of your choosing. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.

If you would like to make a request regarding your data rights in relation to the Scheme, you can contact us at [email protected]. We will normally fulfil your request within one month of receiving it, though this timescale may be extended if your request is particularly large or complex. Where this is the case, we will notify you that more time is needed.

You will not be charged any fee to exercise your data rights, unless we believe your request is manifestly unfounded or excessive. In this instance, we may require a reasonable administrative fee to fulfil your request or may refuse to do so and will notify you if this applies to your request.

Please note that your rights regarding our use of your personal data are not absolute. If we do not agree to your request regarding your data rights, we will inform you of the legal reason(s) why we are unable to do what you have asked.

How to complain

If you are unhappy with how we have used your personal data, you can tell us about it by contacting us on [email protected]. You can also complain to the Information Commissioner’s Office (ICO), who is the UK’s independent regulator of information rights. More information can be found at https://ico.org.uk/global/make-a-complaint/ or by contacting the by phone or letter using the details below:

Address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Controller

The data controller of your personal data in respect of the Scheme is:

Morses Club Scheme Limited, Building 1, The Phoenix Centre, 1 Colliers Way, Nottingham, NG8 6AT

We are registered with the Information Commissioner’s Office in the UK with registration number ZB456193.

You can contact us at [email protected] or by writing to us at the above address.

Data Protection Officer

Morses Club Scheme Limited has a Data Protection Officer who can be contacted by email at [email protected], or by writing to them at the above address.

How we secure your personal data

We recognise how important it is to protect the personal data you share with us and use systems and technology that securely store and transfer your data. We ensure your personal data is only accessed by appropriate personnel that have a justified reason to see your data. We also ensure that our systems and software are kept up to date and perform well, to allow you to access your data when you need to. The measures we have in place also help us protect against unauthorised or unlawful processing, accidental loss, destruction of, or damage to, your personal data.

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