1.1 This website is owned and operated by Aspire Money Limited, Citrus Loans which is a Trading name of Aspire Money Limited.
1.2 We are registered in England under FCA registration number 681346, and our registered office is at Unit 1, Castle Court 2, Castlegate Way, Dudley, West Midlands DY1 4RH
1.3 Should you wish to confirm our registration details please click here FCA register
1.4 We are also registered with the Information Commissioners Office; under registration number Z1262766. Should you wish to confirm our registration details please click here DPA register
1.5 If you would like any further information on this policy, please contact us:

• by post to the postal address: PO BOX 15799, Solihull, B93 3GA
• using our website contact form Contact Us
• by email using compliance@aspiremoney.co.uk

2.1 We are a credit broker, and in order to establish your general eligibility against the lenders on our panel product criteria, we will need to collect and process certain categories of your personal data.

2.2 We will process the information contained in any enquiry you submit to us regarding our services. This information will be processed for the purposes of providing our services to you which will be finding you a lender to assist you with the loan options you are searching for.

2.3 We and the panel of lenders will retain and use the personal data you provide us for statistical analysis and analytics regardless of whether or not you take up a loan with one of the lenders on our panel. Where we do this, we take strict measures to ensure that your personal data cannot be identified.

2.4 Aspire Money may share a small amount of customer information with trusted companies to help confirm details, find or contact customers if needed, recover fees, or support our lending partners — but only when it’s necessary and done safely, following data protection rules.

Activity	GDPR Lawful Basis for Processing
Assessing product eligibility As a credit broker, we match your personal and financial circumstances to the lenders on our panel products and lending criteria. In order to do this, we collect information either directly from you or through an introducer you have approached. As the first stage in this process, we will assess your general eligibility for the lenders’ products by undertaking a number of checks with credit reference agencies and fraud prevention agencies.	We require your personal information so that we can obtain the options available to you from the lenders on our panel. It is also in our legitimate interests, when you approach us, to undertake a number of checks to assess your eligibility for a loan against our panel of lenders products. In some cases, we must undertake these checks to comply with a legal obligation, for example under anti-money laundering regulations. We have a regulatory obligation to assess whether you will meet the lenders criteria for a loan and to ensure you do not over-commit yourself. Our vulnerability checks are also designed to protect your vital interests. In carrying out this initial assessment, we may use automated decision systems that enable us to speed up our assessment. However, if you do this, you can ask us to assess your application manually if you wish.
Matching you with a lender on our panel Once we have completed our own checks, we will assess which lender meets your requirements based on your circumstances. We do this by using the lenders’ underwriting criteria and the process is very similar to our own checks and includes a soft credit search which is an initial review of your credit history that is held with the credit reference agencies.	At this stage, working on behalf of one or more of the lenders on our panel, we are processing your information because it is necessary for us to assess your application against lenders’ criteria and provide you with any options that are available to you before your application is submitted to the lender. In carrying out this assessment, we may use automated decision systems based on one or more of the lenders’ underwriting criteria. Again, this speeds up our assessment, but you can ask us to assess your application manually if you would prefer.
Maintaining records of your application For legal, regulatory and administrative purposes we shall retain your personal information securely on our systems until there is no longer any requirement to retain it.	We have legal and regulatory obligations in respect of identifying fraud, money laundering and financial crime. As a business regulated by the Financial Conduct Authority, we also have regulatory reporting obligations. We will also retain your information in other circumstances where we have a legitimate basis for doing so, such as record keeping, dealing with any enquiries or complaints from you and internal administration.
Keeping you up-to-date The lenders on our panel products and services, they have available, will change over time. We would like to keep in touch with you, whether you have taken out a loan with one of the lenders on our panel, or where we have been unable on this occasion to provide you with any suitable options.	Where you have applied for a loan, we may contact you to keep you up to date with products and services which may be of interest. It is in our legitimate interests to do this, but of course you can tell us you would prefer us not to contact you by clicking on this link, unsubscribe@aspiremoney.co.uk and providing us with your full name, contact number (s) and postcode, so we can action this for you.
Use of Legitimate Interests – Tracing and Collections Aspire Money is a regulated credit broker and not a lender. However, in certain circumstances, we may share limited personal information with third-party tracing or debt collection partners. This activity is undertaken only where it is necessary and proportionate to protect Aspire Money’s legitimate business interests or to support our partners in accordance with agreed brokerage services. This may occur when: Outstanding balances: Where there is an amount directly owed to Aspire Money, for example, in cases of commission clawback arising from early loan settlement, non-payment, or provision of inaccurate information. Partner support: Where a lender, provider, or other partner introduced through our brokerage services requires assistance in re-establishing contact with a customer. All processing of personal information for these purposes is carried out under the legitimate interests lawful basis. The impact on individuals is minimal, and customers are informed of this possibility and retain the right to object at any time.	We rely on the lawful basis of legitimate interests under Article 6(1)(f) of the UK GDPR to do this. Our legitimate interest lies in the recovery of business-related debts, maintaining accurate records, and supporting our lending partners in responsible customer management. We always ensure that: Only information that is relevant and necessary for the specific purpose is shared. All third-party partners are contractually required to handle personal data securely and to use it solely for the agreed purpose. Customers are informed of this activity within our Privacy Notice and may object to such processing at any time.

You have the right to opt out, regarding the future processing of your information. Opting out will not affect the lawful basis for processing of your data before you opted out.

In order to do this, please use any of the preferred methods of communication below

• by post, to the postal address PO BOX 15799, Solihull, B93 3GA
• using our website contact form Contact Us
• by email using compliance@aspiremoney.co.uk

There are different ways in which we obtain your data

• From our website, if you complete our online application form
• If you telephone us to make a loan application
• Certain Lenders and Financial Brokers may pass your information to us, should they be unable to assist you with a loan. Please note that if this is the case, we will provide you with the identity of these individual firms.

The categories of data that we collect are as follows:

• Collecting and recording details about any health issues you may have which may affect your understanding of our application process. Our vulnerability checks are designed to protect your vital interests.
• Loan amount you require
• Your name and date of birth
• Partner name and date of birth (should you request a joint application)
• Address Details
• Employment Details
• Partner Employment Details (should you request a joint application)
• Mortgage Details or Tenancy Details
• Bank Details
• Other Income & Expenditure you might incur
• Your Financial Status i.e., Bankruptcy, Defaults & Missed Credit Payments, County Court Judgements, Individual Voluntary Arrangement and Debt Management Plan

In order to process your application, we will perform a soft credit check on you with one or more Credit Reference Agencies (“CRAs”).
To do this, we will supply your personal information to CRAs and they will give us information about you. The information we will supply includes information from your application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. The information which we and other organisations provide to the credit reference and fraud prevention agencies may be supplied by credit reference agencies to other organisations and used by them to perform similar checks. If you are making a joint application or tell us that you have a spouse or financial partner, we will link your records together. You should make sure you discuss this with them before completing the application. Soft credit searches are not visible to other companies and have no impact on your credit rating. We will use this information to:

• Assess your application against our panel of lenders criteria;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, detect fraud and money laundering;
• Ensure any options provided to you are appropriate to your circumstances.

What is a soft credit search?

A soft search is recorded on your credit file but is not visible to lenders. It includes identity checks and quotation searches.

What is a hard credit search?

Hard searches occur when you make a formal application for credit. They are visible to other lenders and may temporarily affect your credit rating.

The credit reference agencies used by us and our panel of lenders are Experian, Call Credit and Equifax. More details can be found in their CRAIN documentation:

• Callcredit: www.callcredit.co.uk/crain
• Equifax: www.equifax.co.uk/crain
• Experian: www.experian.co.uk/crain

We may make searches of records held at fraud prevention agencies. If you give us false or inaccurate information and we confirm fraud, we will record this and may pass this information to fraud prevention agencies and other organisations to prevent fraud and money laundering. Law enforcement agencies may access and use this information.

We share personal data for crime and fraud prevention and the apprehension and prosecution of offenders.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

The information which we, other organisations and fraud prevention agencies provide to the credit reference and fraud prevention agencies about you and your financial associates may be supplied by the credit reference and fraud prevention agencies to other organisations and used by us and them for example to:

• Prevent fraud and money laundering,
• Verify your identity if you or your financial associate applies for other facilities including all types of insurance applications and claims,
• Assist other organisations to make decisions on credit and credit related services or other facilities,
• Trace your whereabouts and recover debts that you owe,
• Managing credit and credit related accounts and other facilities;
• Undertake statistical analysis and system testing.
• Checking details on applications for credit and credit related accounts or other facilities.
• Checking details of job applicants and employees.

As a regulated credit broker, Aspire Money does not directly hold, service, or collect repayment on loans. However, in specific circumstances, limited tracing or collections activity may be undertaken where it is necessary to protect the commercial interests of the business or to support lender partners in accordance with agreed brokerage services. Aspire Money may engage tracing or collections services where:

• Commission recovery is required, for example, where payments are subject to clawback due to early loan settlement, inaccurate customer information, or suspected fraudulent activity.
• Lender support is necessary, such as assisting partners in tracing customers who have become unreachable.

Although Aspire does not pursue the recovery of credit on behalf of lenders, these activities may be justified under the legitimate interest’s lawful basis, as they meet the following criteria:

• Purpose: To recover fees or assist partners in locating and contacting a customer.
• Necessity: Alternative means of contact or recovery are unavailable.
• Balance: The impact on individual privacy is minimal; customers are informed of such processing and have the right to object.

Datatrac – Collections and Trace

To support collections and trace activities for financial institutions and creditors, we may also use Datatrac (www.datatrac.co.uk).

• Datatrac collects and processes personal data strictly in line with data protection and privacy laws.
• Data is used only for legitimate business purposes such as locating individuals, verifying information, and managing debt recovery.
• Datatrac maintains rigorous security standards to prevent unauthorised access or misuse.
• Individuals retain full rights under the UK GDPR, including access, correction, and restriction of their personal data.

a) The panel of Lenders and specialist companies we work with

We work closely with various lenders and specialist companies to bring you a range of products and services designed to meet your needs. When you enquire about one or more of these products, the relevant lender/company will use your details to provide you with information and carry out their obligations arising from any application or contract you have entered into with them.
These companies will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. These companies may share your information with us which we will use in accordance with this Privacy Policy.
Please see below a list of companies that we may share your information with:

Evlo: Trading name of Everyday Lending Limited	One Stop Money Shop	Motiv Finance
Drafty: Trading name of GAIN Credit LLC	Norwich Trust	Norton Finance
Loans Warehouse Ltd	Munzee Loans: Trading name of Loans 2 Go Limited	Multa (Trading Style of Twibli Limited)
My Community Finance	Loqbox	Fluent Money
Savvy.co.uk	Salary Finance	Loans By Mal: Trading name of Monthly Advance Loans Limited
OakbrookAdvance	118 118 Money	Match the Cash Limited trading as Sharemyloan.co.uk.
Salad	Zilch Technology Limited	Wednesday Financial Services trading name of Clarke Hendrik Group Ltd
Essential Finance Management Ltd: Trading name of Bopay)	Propel Holdings Trading name of QuidMarket

Where we submit your personal data to the lenders on our panel to assess your application against the lenders’ criteria and provide you with an option, to which you subsequently decide you do not want to proceed with, please take note of the below regarding the retention of your data by the lender.
Some lenders will retain your information for statistical analysis and analytics, to defend possible future legal claims, under applicable statutory requirements and any relevant industry guidelines.
In some circumstances, you have the right to ask that the lender erase your personal information where it is no longer required.
Those circumstances include:

• the personal data that they hold is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• you object to the processing under certain rules of applicable data protection law;
• the processing is for direct marketing purposes;
• the personal data have been unlawfully processed

b) Service Providers

We may provide your personal information to anyone who hosts or maintains data centres, service platforms and other infrastructure and systems on behalf of us. Except as described above, we will not disclose your personal information to Third Parties, without your consent. The below table shows the list of Service providers that we will provide your personal information to:

Iomart Hosting (Titan)

Connex One

Car Finance Loan Options

Aspire Money works with Motiv Finance a company registered in the UK with company number 11517060. Motiv Finance is a credit broker and not a lender.

Motiv partners we may share data with:

Oodle

My Car Credit (Evolution Funding LTD)

CarFinance 247

CreditPlus

Moneybarn

Blue Motor Finance

Match Me Car Finance

Motiv Finance Policies:
https://motivfinance.co.uk/Privacy
https://motivfinance.co.uk/Terms

Open Banking

Equifax and ConsentsOnline have been engaged by Aspire Money to share your account Transaction Data with the lenders on our panel as part of our Open Banking Service.

ConsentsOnline is registered with the Financial Conduct Authority as an Account Information Services Provider (AISP). ConsentsOnline will, with your permission:

• use your name and financial account details to request access to your financial account;
• collect your Transaction Data and (with the use of its subcontractor, AccountScore Limited – please see below) analyze and categorize your Transaction Data as instructed by you or the Approved Recipient;
• provide your Transaction Data and any Analysed Data to Equifax so that Equifax can make that information available to the Approved Recipient; and
• provide account information services directly to you, including by making your Transaction Data available to you via an online portal.

Equifax has an agreement in place with Aspire Money to provide the above noted services via ConsentsOnline. This means that Equifax’s processing of your personal data is more limited, and includes:

• verifying your identity and financial account details by comparing this information with the financial data it already holds about you; and
• making the Transaction Data and analysis of that data (provided by ConsentsOnline) available to the Approved Recipient.

To view Equifax and ConsentsOnline Privacy Policy please click on the relevant link below:
https://consents.online/Privacy

As part of the services offered to you through this website, the information which you provide to us may be transferred to lenders in countries outside the European Union (“EU”).

If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

Your data will be processed at our call centre based in South Africa.

If we process your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

By submitting your personal data, you’re agreeing to this transfer, storing or processing of your data.

a) Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

b) Personal data categories will be retained for a minimum period of 12 months following the date of your enquiry, and for a maximum period of 6 years following the date of your enquiry.

We may use automated decision systems once your loan application is submitted to us. This is done in an effort to ensure that we are able to assess your eligibility for a loan against our panel of lenders criteria and ultimately provide you with the loan options available for you to consider.

Your principal rights under data protection law are:

• the right to access your information
• the right to rectification
• the right to erasure where records are no longer required
• the right to object to Processing where this use is based on our legitimate interests
• the right to restrict processing
• the right to complain to a supervisory authority

13.1 The right to access your information

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to that personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, at your request, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

If your information has been passed over to our panel of lender/s you will need to contact them requesting the information they will hold about you.

13.2 The right to rectification

You have the right to have any inaccurate personal data that we hold about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

If your information has been passed over to lender(s) on our panel you will need to contact them requesting them to correct any inaccurate information they may hold about you.

13.3 The right to erasure, where records are no longer required

In some circumstances you have the right to the erasure of your personal data without undue delay.

Those circumstances include:

• the personal data that we hold is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• you object to the processing under certain rules of applicable data protection law;
• the processing is for direct marketing purposes;
• the personal data have been unlawfully processed

However, there are exclusions of the right to erasure.

The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

If your information has been passed over to lender(s) on our panel you will need to contact them requesting to exercise your right to erasure, regarding the information they hold about you.

13.4 the right to object to Processing where this use is based on our legitimate interests

To the extent that we may contact you to keep you up to date with services that may be of interest to you and this is based on our legitimate interests to do so, you have the right to unsubscribe to this service at any time. Opting out of this will not affect the lawful basis for processing of your data before you opted out.

This does not automatically mean that we need to erase your personal data, and in most cases, it will be preferable to suppress your details. Suppression involves retaining just enough information about you to ensure that your preference not to receive future communications on products or services is respected.

If your information has been passed over to lender(s) on our panel you will need to contact them requesting to exercise your rights to object to any processing, regarding the information they hold about you and any other consent you may have provided to them over the use of your information.

13.5 The right to restrict processing

In some circumstances you have the right to restrict the processing of your personal data.

Those circumstances are:

• you contest the accuracy of the personal data;
• processing is unlawful but you oppose erasure;
• we no longer need the personal data for the purposes of our processing, but we require personal data for the establishment, exercise or defence of legal claims;
• you have objected to processing, pending the verification of that objection.

However, we will only otherwise process it, for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

If your information has been passed over to lender(s) on our panel you will need to contact them requesting to exercise your right to restrict processing, regarding the information they hold about you.

13.6 The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection, the Information Commissioners office.

Information Commissioners Office Contact Details

You can call their helpline on 0303 123 1113.

We would welcome the opportunity to investigate any complaint you have, you can do this by:-

• emailing us at: compliance@aspiremoney.co.uk
• writing to us at: PO BOX 15799, Solihull, B93 3GA

You may exercise any of your rights in relation to your personal data by specifying the details of your request to:-

• email us at: compliance@aspiremoney.co.uk
• write to us at: PO BOX 15799, Solihull, B93 3GA

In order to process your loan enquiry, we will require you to complete our online loan application, or telephone our contact centre and complete an application with one of our consultants. We require this information to assist you in finding you loan options. If you do not provide us with this information, we will be unable to carry out our services to you as a credit broker.

To find out what personal data we require from you please click here

For what purposes are personal data being processed and what is the legal basis for it?

We may receive information about you if you use any of our other websites i.e. Citrus Loans and Opal Loans which are Trading names of Aspire Money Limited.

We also work closely with third parties for example other Credit Brokers, Business partners and Lenders who you may have contacted you to assist you with your loan enquiry. These third-party companies may have been unable to assist you with your enquiry and may have noticed that we could possibly assist you, in this case they will have passed your information to us, ensuring that you have been informed and have agreed to your information been processed in this way.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Like many other websites, this website uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your preferences, and to record session information, such as length of visit. Depending on the type of cookie we use, cookies also allow us to make our web site more user friendly, for example, permanent cookies allow us to save your password so that you do not have to re-enter it every time you visit our web site.). This helps us to improve our website and deliver a better more personalised service.

Below is a table of information which lists all cookies used on our website.

Owner Cookie	Cookie Name	Cookie Description
Google Analytics	_utma	A Google Analytics cookie, which keeps track of the number of times, a visitor has been to the site, when their first visit was, and when their last visit occurred.
Google Analytics	_utmb	A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor enters a site.
Google Analytics	_utmc	A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor leaves the site.
Google Analytics	_utmv	Used for reporting in Google Analytics classifying the visitor.
Google Analytics	_utmz	A Google Analytics cookie which tracks where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world the site was accessed from.

Information regarding the use of Pixels

The pixels used, are not set up to collect personally identifiable data such as names, email addresses. As such the pixel tag can’t be used to track anything back to an individual.
Third party media owner pixels – e.g. DBM, Quantcast etc
We have some of these pixels on our site, and these are used for the following techniques:

• Building an audience (retargeting, lookalike, exclusions)
• Optimising
• To model the data
• Reporting

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.