Credit Score Privacy Notice

At Lowell we’re committed to protecting your privacy and data protection rights. This notice sets out what information we collect when you use the credit score function which is available to you when you access your online account via our website or the Lowell mobile app.  It explains how we use your information, who we share it with and how we protect it. It also sets out your rights and how to exercise them.

We’ve set out some useful Frequently Asked Questions (FAQs) at the top of this notice and you’ll find the legal bit at the end of the notice.

Frequently Asked Questions (FAQs)

What is the credit score function in my online account?

The credit score function in your online account presents existing Lowell customers with their credit score from one of the main UK credit reference agencies (CRAs), TransUnion. We call this your “TransUnion Credit Score” in this notice.

Your TransUnion Credit Score is a number between 1 and 710 that TransUnion calculates according to the factual information on your credit report which it receives from various data sources.

The TransUnion Credit Score you see in your online account may be different from the credit scores you see elsewhere that may be calculated for you by the other CRAs (Experian and Equifax).

You must be an existing Lowell customer who has downloaded the Lowell mobile app or who has registered for an online account via Lowell.co.uk to access your TransUnion Credit Score.

What is a credit report?

Your credit report contains all of the information a credit reference agency (CRA) holds on you under your name and address; this includes information on how well you have managed with borrowing money in the past, whether you are registered to vote (known as being on the electoral roll), who has viewed your credit report, why they have viewed it, what they have viewed and when they viewed it.

The CRAs create a credit report for you based on information supplied to them by lenders, utilities providers and other public sources, including electoral register information and any judgments, insolvencies, and bankruptcies.

What is a credit score?

A credit score is calculated from the information in your credit report; it gives a general picture of your current financial position.

Do I have more than one credit score?

Yes, different organisations you have a financial relationship with may use their own rules to calculate a credit score for you. Each of the credit reference agencies (TransUnion, Experian and Equifax) have their own rules for calculating a credit score for you. The score we're showing you in your online account is calculated by TransUnion.

Who is Lowell?

Lowell is Lowell Financial Ltd. Lowell operates the Lowell mobile app and Lowell.co.uk. We collectively call these methods of accessing your account as your “online account” in this notice.

We make access to your accounts online at Lowell.co.uk or via the Lowell app available to our customers:

  • to provide you with information about being a Lowell customer and what it means for you
  • so that you can use it to manage your debt with us and make payments.

Lowell Financial Ltd is part of the Lowell group of companies. We manage customer debts on behalf of Lowell Portfolio I Ltd which is another company in the Lowell group.

Lowell Portfolio I Ltd buys customer debt where there is an outstanding balance from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.

Lowell Financial Ltd manages the debt, which means that if we write or speak to you or if you use the Lowell app or Lowell.co.uk, it will usually be Lowell Financial Ltd that you are dealing with.

 

Company

Lowell Financial Ltd

Company number

04558936

Country

Incorporated in England and Wales

ICO registration number

Z7273861

Registered office

No.1 The Square, Thorpe Park View, Thorpe Park, Leeds, LS15 8GH

 

We also provide credit management solutions to other companies to help them manage the accounts that you have with them.

 

Lowell is not responsible for the content of your TransUnion Credit Score.

 

Who is TransUnion?

TransUnion is TransUnion International UK Limited.

TransUnion is part of the TransUnion group of companies. TransUnion is one of the UK’s major credit reference agencies (CRAs). CRAs hold details of an individual’s credit history at their addresses. Local authorities, courts, and credit providers share information with CRAs to promote responsible lending, support debt recovery, and to prevent over-indebtedness and fraud.TransUnion is responsible for calculating your TransUnion Credit Score.

Company

TransUnion International UK Limited

Company number

03961870

Country

Incorporated in England and Wales

Registered office

One Park Lane, Leeds, West Yorkshire LS3 1EP

 

Lowell and TransUnion are independent controllers of your personal data.

For more information about how TransUnion use your personal data, please see their privacy notice which is available at https://www.transunion.co.uk/legal-information/bureau-privacy-notice.

How does the credit score function actually work?

Your online account allows you to make a data subject access request (under UK GDPR) to TransUnion to view your TransUnion Credit Score, should you wish to do so. It is not a full data subject access request for all information held by TransUnion about you. It will only include the information contained in your TransUnion Credit Score.

Will using the TransUnion credit score function leave a record on my credit report?

When you request your TransUnion Credit Score in your online account, this will leave what is called a soft footprint on your credit report. This shows that Lowell requested your TransUnion Credit Score on your behalf. This will occur without you requesting your Credit Score directly from TransUnion.

Soft footprints can usually only be seen by you, the organisation which has created the soft footprint, and the credit reference agency which has provided the credit data (TransUnion provide this in your online account). When an organisation collects your credit score for you, they see everything that you can see, including all the soft footprints on your credit report.

The soft footprint is left so you can see when your data has been accessed, by whom and when.  It is not used by any lenders in any lending decisions and will not affect your credit score.

The soft footprints on your credit report are made available to Lowell even if they have been created by another organisation. 

If you get your credit score from any other organisation, they will be able to see the soft footprint left by Lowell.

How do I access my TransUnion credit score?

You can access the TransUnion Credit Score function at any time via your online account. When you access it for the first time, you will be asked to provide some further information via your online account which will be shared with TransUnion. TransUnion will use this information to confirm your identity and make sure that you are provided with the correct information.

If TransUnion is unable to confirm your identity, you will not be able to access your TransUnion Credit Score. If this happens, neither TransUnion nor Lowell will be able to tell you why TransUnion has been unable to confirm your identity. Although it may be due to TransUnion not being able to match your personal details to the correct credit profile on its database.

How do I access my TransUnion credit score if I don't want to do it via my online account?

If you wish to access your credit information from TransUnion, but you do not wish to provide further information to confirm your identity via your online account, you can request a copy of your statutory credit report at https://www.transunionstatreport.co.uk/CreditReport/AboutYou.

What information from my TransUnion credit score can Lowell see?

If you register for your TransUnion Credit Score through your online account, TransUnion will provide the information to Lowell for us to show you in your online account. This means that the soft footprints on your credit report are made available to Lowell, even if they have been created by another organisation.

How will Lowell use my TransUnion credit score?

We will only use the information contained in your TransUnion Credit Score to display this information to you in your online account. We only retain the data for as long as you have the information open in your online account. This means that if you submit a request to exercise any of your rights under the data protection legislation to Lowell, the information in your TransUnion Credit Score will not be covered.

We will never use your TransUnion Credit Score to manage your Lowell accounts or make any decisions (including automated decisions) about you or your account. We will also never use your TransUnion Credit Score for any form of marketing.

Will anyone else be able to see that I am using the Lowell app for my TransUnion credit score?

The request for your TransUnion Credit Score will leave a soft footprint on your credit file. This will occur without you requesting your credit score directly from TransUnion.  Other organisations that you use to obtain your credit report and credit score will be able to see the soft footprint left by Lowell. However, if you make a request to TransUnion directly to view your own credit report, this is not visible to organisations that assess an application for credit nor will it have an impact on your score.

Will my TransUnion credit score be updated?

TransUnion will update your TransUnion Credit Score and send this to Lowell every seven days  so that you have the most up-to-date information.

What do I do if I think my TransUnion credit score is inaccurate?

The TransUnion Credit Score is calculated by TransUnion using the data TransUnion holds in your credit report.   You can check your credit report by going to https://www.transunionstatreport.co.uk/CreditReport/AboutYou.  If, after you've reviewed your credit report you feel something is inaccurate, you can raise a dispute by contacting TransUnion at ukconsumer@transunion.com.

Can I find out why my TransUnion credit score has changed?

In your online account, you will see a “What’s New?” section which will show anything in your TransUnion Credit Score which has changed. If you need more information, you will need to contact TransUnion’s Support and Help Desk Service by email at UKConsumer@transunion.com.

Can I use the TransUnion credit score to access information for anyone else?

No, you can only obtain your own TransUnion Credit Score.

What if I change my mind about using the credit score function?

You can opt out of receiving your TransUnion Credit Score at any time by clicking on “Opt Out”.

What if Lowell stops providing the TransUnion credit score function?

If your TransUnion Credit Score is temporarily unavailable, we will send you a message via your online account to let you know.

If Lowell decides to stop providing the credit score function as a service in your online account, you will no longer be able to access your TransUnion Credit Score in your online account.

Does the Lowell app use cookies or similar technology to collect my data?

iovation Inc is part of the TransUnion group of companies.  They help TransUnion to detect and combat online fraud and other types of cybercrime.  They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report. 

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

For more information about the cookies and similar technologies that Lowell set, please see our mobile app privacy notice

The legal bits

Who are we?

The Lowell mobile app and Lowell.co.uk is operated by Lowell Financial Ltd:

  • to provide you with information about being a Lowell customer and what it means for you and
  • so that you can use it to manage your debt with us and make payments and receive refunds.

Where we use “Lowell”, “we”, “our” or “us” in this privacy notice, we mean Lowell Financial Ltd unless we say otherwise. Where we use “online account”, we mean the Lowell mobile app and lowell.co.uk where you can access your account online.

Lowell Financial Ltd is part of the Lowell group of companies. We manage customer debts on behalf of Lowell Portfolio I Ltd which is another company in the Lowell group.

Lowell Portfolio I Ltd buys customer debt where there is an outstanding balance from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.

Lowell Financial Ltd manages the debt, which means that if we write or speak to you or if you use the Lowell app or Lowell.co.uk, it will usually be Lowell Financial Ltd that you are dealing with.

We also provide credit management solutions to your original creditor to help them manage the relationship that you have with them.

Company

Lowell Financial Ltd

Company number

04558936

ICO registration number

Z7273861

Country

Incorporated in England and Wales

Registered office

Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB

Who is TransUnion?

TransUnion is TransUnion International UK Limited.

TransUnion is part of the TransUnion group of companies. TransUnion is one of the UK’s major credit reference agencies (CRAs). CRAs hold details of an individual’s credit history at their addresses.  Local authorities, courts, and credit providers share information with CRAs to promote responsible lending, support debt recovery, and to prevent over-indebtedness and fraud. TransUnion is responsible for calculating your TransUnion Credit Score.

Company

TransUnion International UK Limited

Company number

03961870

Country

Incorporated in England and Wales

Registered office

One Park Lane, Leeds, West Yorkshire LS3 1EP

 

Lowell and TransUnion are independent controllers of your personal data.

For more information about how TransUnion use your personal data, please see their privacy notice which is available at https://www.transunion.co.uk/legal-information/bureau-privacy-notice.

Where do we get your information from?

We collect the information you provide directly to us when you register for your TransUnion Credit Score and we obtain your TransUnion Credit Score from TransUnion.
We collect the information provided by TransUnion in respect of your TransUnion Credit Score to share it with you.


For more information about how TransUnion uses your personal data, please see their privacy notice which is available at www.transunion.co.uk/legal-information/bureau-privacy-notice.


For more details about the information we collect about you as a Lowell customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

What information is collected about you?

When you register for your TransUnion Credit Score, we use the address information we already hold for you and we also collect your telephone number.


We also collect the content of your TransUnion Credit Score.


iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.


For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.


We may also combine the information you give us and the information we collect about you with information that we receive from other sources, such as the previous owner of your account.


For more detail about the information we collect about you as a Lowell customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

Why do we need your information?

We need the information we collect when you register for your TransUnion Credit Score so that we can submit your request to TransUnion. TransUnion need this information so that it can confirm your identity and match your information with the correct credit profile on its database.


We need the information provided by TransUnion to show you your TransUnion Credit Score.


iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.


For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

By agreeing to our terms and conditions for the use of your online account and the TransUnion Credit Score, you have entered into a contract with us. We need the information above to provide you with the TransUnion Credit Score under those terms and conditions. For more detail about why we need the information we collect about you as a Lowell customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

Who do you share your information with?

We share the information that you provide directly to us when you register for your TransUnion Credit Score with TransUnion.


TransUnion share the content of your TransUnion Credit Score with us.


iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

We also use a number of carefully selected third parties to supply us with IT products and services. We will only share your information with our suppliers where it is necessary for them to provide us with the services we need.


For more detail about who we share your information with as a Lowell customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

Where is your information stored?

The information that we do collect about you is generally stored on servers and filing systems in the UK but from time to time it may be stored in or accessed from countries outside the UK. Where this may happen, we always make sure that there are appropriate safeguards in place, such as the Standard Contractual Clauses or binding corporate rules, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

Standard Contractual Clauses

These are a set of standard clauses which have been recognised by the European Commission and the Information Commissioner’s Office as providing adequate protection to personal information transferred outside the EEA.

When we include these clauses in a contract with one of the companies we work with, it means that if they transfer your information outside the EEA, they must make sure that your information is just as safe as it is in the EEA.

 

Binding corporate rules

 

These are a way for large groups of companies which are based in lots of countries around the world to transfer personal information to companies in their group in a way that complies with the EU data protection rules. The binding corporate rules must be approved by the European data protection authorities before the group of companies can adopt them.

When one of the companies we work with uses binding corporate rules, it means that if they transfer your information outside the EEA, they have procedures in place to make sure that your information is handled in a way that makes sure that your information is just as safe as it is in the EU.

 

How long do we keep your information for?

If you register for your TransUnion Credit Score through your online account, TransUnion will provide the information to Lowell for us to show you in your online account. This means that the soft footprints on your credit report are made available to Lowell even if they have been created by another organisation. 

We only retain the data for as long as you have the information open in your online account. 

For more detail about how long we keep your information as a Lowell customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

 

Do we carry out profiling and automatic decision making?

We do not carry out any profiling or automated decision-making in respect of the information we collect in respect of your TransUnion Credit Score.


For more details about the profiling and automated decision-making we carry out in respect of the information we hold about you as a customer, please see our customer privacy notice and if you use our app, please see our mobile app privacy notice.

What rights do you have?

Under the data protection laws, you have a number of rights in respect of your information, which include the right to:

  • access the information which we hold about you
  • ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
  • delete or erase your information (sometimes called the right to be forgotten)
  • stop or restrict our processing of your information
  • object to our processing your information
  • not be subject to automated decision-making and
  • request the transfer of some of the information we hold about you (known as data portability).

Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use the information we hold about you, please see our Customer Privacy Notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by:

  • email to dpo@lowellgroup.co.uk
  • letter to Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE.

 

What happens if you decide you no longer want to use your TransUnion credit score?

You can opt out of receiving your TransUnion Credit Score at any time by clicking on “Opt Out”.

What if you have a complaint?

If you have any questions, concerns or complaints about the way we process your personal information, please contact our Data Protection Officer in the first instance by

  • email to dpo@lowellgroup.co.uk
  • letter to Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ

and they will do their very best to help you.

If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

Who are the Lowell group?

The Lowell group is made up of the following companies incorporated in the UK

 

Lowell Portfolio I Ltd  (Company number 04857418)

Lowell Financial Ltd (Company number 04558936)

Lowell Solicitors Limited (Company number 08647091)

Overdales Legal Limited (Company number 07407310)

Lowell UK Shared Services Limited (Company number 08336897)

Lowell Group Shared Services Limited (Company number 08647094)

Lowell Receivables Financing 1 Limited (Company number 11344999)

Lowell Receivables Financing 2 Limited (Company number 13403235)

Lowell Receivables Financing 3 Limited (Company number 13849615)

Lowell Portfolio III Limited (Company number 08096778)

Lowell Portfolio IV Limited (Company number 08654105)

Changes to the notice

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date.

This notice was last reviewed and updated in February 2024.