Novitas Loans

Novitas Loans has ceased lending and is permanently closed. Novitas Loans was a provider of lending for legal costs and is part of the Close Brothers group. Close Brothers will continue to support previous customers of Novitas Loans.

If you would like to discuss the status of your legal case, please contact your solicitor.

If you would like to discuss your After the Event (‘ATE’) Insurance Policy, please contact your insurer.

You can contact us by email at: enquiries@novitasloans.co.uk or write to us at:

Novitas Loans, 10 Crown Place, London, EC2A 4FT

You can find contact details for relevant organisations which can provide additional support here.

Novitas Loans Limited (a previous subsidiary of Close Brothers Group plc) has now ceased trading and all personal data has been transferred to Close Brothers Group Plc for retention in accordance with our legal and regulatory obligations and in line with our Privacy Notice.

"We", "our" or "us" means Close Brothers Group plc of 10 Crown Place, London, EC2A 4FT and its subsidiaries, affiliates and their respective parent and subsidiary companies (“Close Brothers Group”). For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). Close Brothers is responsible for ensuring that it uses your personal data in compliance with data protection law.

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, our Data Protection Officer can be contacted at dpo@closebrothers.com or DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.

This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect about you

We will collect and use the following personal data about you and your representatives:

Information you give us

• This is information about you and your representatives that you give us by filling in forms or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your and your representatives’ name, address, e-mail address and telephone number, financial and credit card information, employment history, health information, credit history, identification records, qualifications and vehicle or asset details.
• You must ensure that in respect of any information you provide us with, which does not relate to you (for example, information about your representatives), you have obtained the necessary consent in order to disclose such information and provided the individual to whom the information relates with a copy of this notice (including any child/ren 13 years old or over).

Information we collect or generate about you and your representatives

• Website Usage Information – Our website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.
• We sometimes record telephone conversations to resolve complaints, improve our service and for training and quality assurance purposes.
• We generate data for statistical analysis.
• We may (through the case notes provided by your solicitor) collect details about you that are considered to be special categories of personal data, such as health related information, religious beliefs and sexual orientation.
• In relation to special categories of personal data that we may collect, we will only collect that information because it is included in your case notes provided to us by your appointed representative or provided to us by you. We will only keep the information for the purposes of retaining full records of the case, including the review of your loan application and to understand your personal circumstances to provide additional support to you throughout the life of your loan. Please see the section special categories of personal data below for more details about how we use this data.

Use of Cookies

For full details on what cookies are, what they do, and which cookies are used by us, please see our Cookies Policy: https://www.closebrothers.com/cookies-privacy

To enable you to sign in and personalise your online experience we use “cookies”. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. We use cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalised content and appropriate advertising on your later visits to our website.

Information we receive from other sources

• Financial/ Credit Information – We will use information provided by credit reference agencies when assessing your application for finance and to verify your or, if applicable, your representatives’ identity. Such information may include some details about other credit you have taken out, any credit arrangements you have met or failed to meet, and any court judgments made against you.
• Fraud Prevention Agencies – When verifying your identity as part of our application process, we may access information recorded by fraud prevention agencies within and outside the UK. This may include information about any criminal convictions and any allegations regarding criminal activity that relate to you.
• Intermediaries – We will receive information from dealers, brokers and introducers including your personal details, contact details and relevant asset or policy details for the purposes of entering in to and administering your agreement.
• Social Media Profile – Where you have clicked through one of our promotions or event notices posted on a third party social media website such as LinkedIn, we will receive your contact information provided as part of your user profile such as your name, e-mail address and telephone number and any other relevant business information such as your organisation’s name, address and your industry. Some of this information may be prepopulated based on your social media profile; other parts may be completed by you, as and when requested.
• Public databases – we may obtain information about individuals from public databases. We use reputable sources including but not limited to the electoral register and Companies House. We employ appropriate measures to assure the quality of information which we collect.

How we use your personal data

Your personal data may be used by us in the following ways:

Credit Scoring & Crime Prevention

• to verify your identity as part of the account opening process for new customers;
• for making a credit check on you. We may carry out a search with a credit reference agency who will keep a record of our enquiry against your name and which may be linked to your representatives (“associated records”). For the purposes of any application for products or services from us, you may be assessed with reference to “associated records”. Where any search or application is completed or agreement entered into involving joint parties, we may record details at credit reference agencies, as a result an “association” will be created that will link your financial records. Details of which credit reference agency we have used are available on request. We may also add to your or, if applicable, your business’s, record with the credit reference agencies details of your agreement with us, any payments you make under it and any default or failure to keep to its terms. These records will remain on the credit reference agencies’ files for 6 years after our agreement with you is settled or terminated whether settled by you or, if applicable, your business or by way of default. These credit reference agencies may create, or add to, their own record about you, or, if applicable, your business, details of our search and your application. This and other information about you or, if applicable, your business and those with whom you are linked financially may be used to make credit decisions about you or your business;
• You can find further information about how credit reference agencies (Experian) may process your personal data at www.experian.co.uk/crain or you can contact us to obtain a paper copy of this information;
• we may use credit scoring techniques and automated decision making systems to either fully or partially assess your information. These credit scoring techniques and automated decision making systems may take into account any previous applications for finance, defaults or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application;
• to allow us to detect and prevent fraudulent activity including sharing personal data with fraud prevention agencies; and
• to allow us to detect and prevent money laundering activity or terrorist financing.

Products & Services

• to provide you with information, products or services that you may request from us;
• to carry out our obligations arising from any agreements you enter into with us;
• to make payments;
• to recover monies;
• where we are permitted to do so, to send promotional information about our products and services via methods such as e-mail, post, telephone, etc.; and
• to contact you via post, e-mail or telephone in relation to the administration of your account or to carry out quality control research.

Statistical Analysis

• as part of our legal and regulatory obligations, to conduct statistical analysis in order to improve our credit risk profile, tackle fraud, and improve our credit decisions. This may include statistical analysis on your personal data even if your application is declined by us or you decide not to complete your application with us; and
• in order to identify and offer you tailored products and services that are suitable for you and improve our service.

Special category of personal data we use

Under the data protection legislation, information revealing health (including physical and mental health), religious beliefs and sexual orientation, are 'special categories of personal data' that we may process about you.

The Financial Conduct Authority (FCA) requires us to treat customers fairly and to understand whether our customers may be in vulnerable situation. A customer may be in a vulnerable situation if their personal circumstances mean that they are at greater risk of harm, for example they are in financial difficulties, they experience one or more major life events or they have a physical or mental health condition.

We only collect the minimum amount of information about any physical or mental health conditions you may have. We need to make sure:

• we comply with the FCA’s requirements to treat you fairly and assess whether we believe you may be a in a vulnerable situation or whether you may need additional support from us;
• we undertake other processing activities on the data such as analysis and quality assurance to assist with the administration of your loan and, internal/external regulatory reporting;
• understand whether your condition has or may have an impact on your ability to pay the amounts you owe;
• we deal with your accounts in the way that we believe best suits your needs;
• we make sure that any payment plan which we agree with you is tailored to your circumstances;
• wherever possible, we communicate with you using your preferred method of communication and
• we take any other steps we believe are necessary to deal with you fairly.

If you provide us with information about your health conditions, we will use this information in the way that we have explained above on the basis that we need it to protect your economic well-being as you may be in a vulnerable situation or at economic risk due to your health conditions.

We may process your health information to settle complaints and answers your queries, as it is in our legitimate interests to make sure that complaints are investigated and resolved to the highest standards, in line with FCA requirements, and to, establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings.

If we believe you are in immediate danger, we may process information relating to your physical and mental health conditions (including sharing this information with the emergency services) on the basis that it may be a life and death situation.

Legal basis for processing your personal data

We process your personal data pursuant to the following legal bases:

• your consent to share your personal data with third party affiliates who may wish to offer you products and services which may be of interest to you;
• taking steps (at your request) prior to entering into an agreement with you, and subsequently for the administration and performance of our agreement with you;
• to comply with our legal and regulatory obligations;
• to establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings; and
• the use of your personal data as described is necessary for our legitimate business interests which are:
• enforcing the terms and conditions of any agreement we have with you;
• the recovery of outstanding debts existing under an agreement with you;
• for statistical analysis to improve our products and services;
• to contact you about products and services that may be of interest to you or
• in the case of processing special categories of personal data, we will process this information for example, to understand your needs to support you if you are or become a vulnerable customer and, to establish, exercise or defend any legal action against us. In any case, we will keep to all laws that apply.

You may object to this at any time by contacting us at enquiries@novitasloans.co.uk or by calling +44 (0)333 321 6070 or by mail addressed to Novitas Loans Limited, 10 Crown Place, London EC2A 4FT.

Sharing your personal data

We may disclose your personal data within the Close Brothers Group and to third party service providers in the circumstances described below:

• to ensure the delivery or maintenance of products or services you have taken out with us;
• to ensure the safety and security of our data; and
• as part of our internal research and statistical analysis activity.
• We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of the Close Brothers Group:

• to our professional advisers in order to enforce or apply the terms of use and other agreements you have with us;
• to an insurer (including insurers in connection with insured products and services) or insurers for administration;
• to claims handlers and fraud prevention agencies;
• to any guarantor;
• to any funder in order to enable funders to assess the value of our assets;
• to any broker or introducer of an agreement with us;
• to tracing and repossession agents;
• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
• to third party agents or contractors (for example, the providers of our electronic data storage services or call centres and/or third party debt managers or collectors) for the purposes of providing services to us; and with your consent, to third party affiliates who may wish to offer you products and services which may be of interest to you.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

We may also share your personal data outside of the Close Brothers Group to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation including but not limited to disclosures made to Credit agencies and Companies House; and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area / UK

The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”) or in the UK. However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA and/or in the UK. It may also be processed by staff operating outside of the EEA and/or in the UK who work for a company in the Close Brothers Group or for one of our suppliers.

Where we transfer your personal data outside the EEA and/or in the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA and/or in the UK. This can be done in a number of ways, for instance:

• the country that we send the data to might be approved by the European Commission or a relevant data protection authority; or
• the recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission, or a relevant data protection authority, obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA and/or in the UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA and/or in the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.

If you are a customer we will retain your personal data for 7 years following the end of our relationship with you, unless we are required by law to keep it for a longer period of time (in which case, we will keep it until the expiry of the period required by law).

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

• the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but may be legally entitled to refuse that request;
• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
• the right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request;
• the right to object to the processing of your personal data for direct marketing purposes; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
• You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
• You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk/.

Changes to our privacy notice

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact us

We are registered in the UK and our registered address is 10 Crown Place, London EC2A 4FT. Our company registration number is 00520241.

Please contact us if you have any questions about our privacy notice or personal data we hold about you.

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The directors provide the following statement pursuant to the Companies Act 2006 (as amended by Companies (Miscellaneous Reporting) Regulations 2018) (the “Act”) to describe how they have acted in accordance with their duty under Section 172 of the Act (“Section 172”) to promote the success of the Company for the benefit of its member(s) as a whole, and in so doing, how they have had regard to those factors set out in Section 172, (1) during the financial year.

Furthermore, in compliance with the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 (as amended by the Companies (Miscellaneous Reporting) Regulations 2018), the directors provide the following statement to describe how they have engaged with employees, and how they have had regard to employee interests and the need to foster the Company’s business relationships with suppliers, customers and others, and in each case, the effect of that regard, including on the principal decisions taken by the Company during the financial year.

Section 172 requires a director to have regard to the following matters, among others, when discharging their duty:

• the likely consequences of any decision in the long term;
• the interests of the Company’s employees;
• the need to foster the Company’s business relationships with suppliers, customers and others;
• the impact of the Company’s operations on the community and the environment;
• the desirability of the Company maintaining a reputation for high standards of business conduct; and
• the need to act fairly between members of the Company.

The board directors of the Company (“the Board”) is collectively responsible for managing the affairs of the Company to deliver its strategy by making important decisions, monitoring the underlying performance of the Company, as well as being a means for establishing ethical standards. Understanding the interests of key stakeholders is an important part of CBG’s strategy and helps inform the directors’ decision making throughout the year.

Board meetings are held as required where the directors will consider the Company’s principal activities and make decisions. Meetings are scheduled to provide adequate time for consideration and discussion by the directors of the interests of stakeholders, and for the directors to seek further information from management, as required. As a part of those meetings, the directors receive information in a range of different formats to assist them in discharging their responsibilities under Section 172 when making relevant decisions. This information may include, among other things, reports and presentations on financial and operational performance, business updates, budget planning and forecasts, HR matters, as well as specific areas of engagement, such as employee opinion surveys. When making decisions, the Board seeks to understand the impact on each of its stakeholders, including the likely consequences of a decision in the long term, whilst acknowledging that a decision will not necessarily be favourable for all stakeholders, as there may be competing interests between them.

The Company is part of CBG, and as such it follows a range of group-wide policies in place to protect employees and provide a safe working environment, to ensure compliance with all regulatory requirements and adherence to the highest professional and ethical standards in dealing with customers, suppliers and colleagues, as well as ensuring that it continues to be cognisant of its social and environmental responsibilities. In doing so, and by balancing the interests of the Company’s stakeholders when making decisions, the Board seeks to maintain a reputation for high standards of business conduct. Further information on these group-wide policies can be found in the Annual Report and Accounts of the Company’s ultimate holding company, CBG.

The directors seek to engage directly with stakeholders wherever possible on certain issues, though the size of CBG means that stakeholder engagement often takes place at an operational or CBG level. This approach creates greater efficiency and facilitates a greater positive impact on environmental, social and other issues than may be possible at a Company level, as well as ensuring consistency of approach across CBG. Where engagement has taken place at operational level, the outcome of that engagement has been brought to the Board for its consideration where relevant throughout the year. Additional details on engagement at CBG level with stakeholders, including employees, suppliers, customers, the community and environment can be found in the Strategic Report section of the Annual Report and Accounts of CBG.