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Your right to privacy is important to us. We know that your personal data belongs to you and not to us. That’s why we take the security of your information seriously and have strict policies and processes in place to ensure it is kept private and safe.
This privacy notice describes the way we collect your information, how we use it and why.
This notice is applicable but not limited to anyone who:
The Group is made up of many different legal entities. The letterhead we use when we write to you will let you know which entity you have a relationship with.
More information on the Group can be found at www.paragonbankinggroup.co.uk.
Where we use the term ‘we’ in this notice we mean the relevant member of the Group who is processing your personal information.
The entity you have a relationship with will be the controller of any personal information you provide to us. The Group’s Company Registration number is 2336032 and its registered address is 51 Homer Road, Solihull, B91 3QJ.
If you have any queries about how your personal information is used by us, which are not answered in this notice, please contact the Data Protection Officer (DPO) at 51 Homer Road, Solihull, B91 3QJ or email [email protected].
Personal data is considered to be any information that either alone, or in combination with other information, would identify you as a living individual. For example, your name and date of birth.
The type of loan or other product you have with us will dictate how your personal information is collected.
Personal information may be provided to us by;
And may be provided;
We may also obtain information about you from:
When applying for a product or service we will ask you to provide some information about yourself for security, identification and verification purposes.
When completing any forms, we will always tell you how your information will be used in relation to the product or service you are applying for within the declaration and in any associated terms and conditions.
When you provide any information about others (eg for a joint account) you must ensure that you have their consent or are otherwise entitled to provide the information to us.
If you are an introducer of business, the information provided in this notice also explains how we manage your personal data, as well as any business you provide.
We may monitor or record phone calls or webchat conversations with you to ensure we have carried out your instructions correctly, to resolve queries or issues, to improve our quality of service, for regulatory purposes and to help prevent or detect fraud or other crimes. We also record conversations for employee training purposes.
When we ask you for personal information online it will only be in response to you applying for, or using, one of our digital products or services.
If you are visiting our site or mobile app, please review our Cookie Policy at www.paragonbank.co.uk/cookies to see what information may be recorded.
The types of personal information we capture about you will vary depending on your relationship with us. We may process the following personal information;
Throughout the life of your account, you may provide the following information to us:
These pieces of information are considered to be special categories of data. We will only record them if they are relevant to the management of your account (for example, if you have a medical condition which means you require a bespoke communication approach) and we will not record this information without your explicit consent. You are able to withdraw this consent at any time, just get in touch.
Under Data Protection law we are only allowed to process your personal data if we have a proper reason to do so. This includes sharing it outside the Group. The law allows us to process your data for one or more of the following reasons;
A legitimate interest is when we have a business or commercial reason to use your information. This reason must not unfairly go against what is right and best for you.
The table below shows the ways we may use your personal information and why;
We may share your personal information with the following third parties;
If you would like to know which specific third parties process data on our behalf, please contact our Data Protection Officer (DPO) 51 Homer Road, Solihull, B91 3QJ or email [email protected].
We may share your personal information with credit reference agencies (CRAs) to carry out credit checks and record details of your repayment history. The CRA’s have drafted a notice called ‘Credit Reference Agency Information Notice’ (CRAIN) which sets out how your data will be processed.
The credit reference agencies we normally use are:
Equifax Ltd
Experian
TransUnion
If you are a Limited Company Director, in addition to the above we may also share your information with Creditsafe. They can be contacted at Bryn House, Caerphilly Business Park, Van Road, Caerphilly, CF83 3GR
If you would like to see the information that these credit reference agencies hold about you, please contact them directly; they will be able to explain how you may progress your request and any charges that may apply.
We may share your personal information and some of the personal data from your online interactions with fraud prevention agencies, the National Crime Agency, Action Fraud and the Home Office to protect us from fraud and money laundering. We may also pass information to financial and other organisations involved in fraud prevention including law enforcement agencies who may also access and use this information to detect, investigate and prevent crime. Fraud Prevention Agencies we typically use and their contact details are as follows:
Synectics Solutions
www.synectics-solutions.com/data-sar
National Hunter
www.nhunter.co.uk/privacy-policy/
Cifas
www.cifas.org.uk/fpn
Lexis Nexis Risk Solution Group
www.risk.lexisnexis.com/group/processing-notices/threatmetrix
We may decide that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. If you give false or inaccurate information and we suspect fraud we will record this. Please go to www.cifas.org.uk/fpn to read the Cifas privacy notice in full
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, finance or employment to you. If you have any questions about this, please contact us.
From time to time we may make you aware of products or services which are similar to the ones you currently hold with us that may be of interest to you. We will only do this if we consider this type of processing to be a legitimate business interest or with your consent.
You are able to get in touch and ask us to stop sending you these messages at any time or you can unsubscribe by selecting the link at the bottom of any marketing email from us. If you chose not to receive marketing information you will still receive important information about your product or service.
When you receive emails from us, they may contain tracking pixels or other similar technology. We use these pixels to help us understand if you have opened the email and how you have interacted with it.
We will keep your personal information for as long as you are a customer of Paragon Banking Group. After you stop being a customer, we may keep your data for up to 12 years for one of these reasons;
We will keep your data for longer than this if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for the following purposes:
When this happens, we will make sure that your privacy is protected and we will only use it for these purposes.
You or a third party may send information to us as a prospective customer. If we do not have any products that are suitable for you, or you decide not to proceed with your application for any reason, we will store the personal information provided to us for no longer than two years.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to 6 years. In some cases, Paragon may hold your data for an indefinite period.
You have various rights in terms of how and why your personal data is processed. Please contact us at any time if you wish to exercise these rights:
There may be times when some or all of your personal information may be transferred to, stored or processed by third-party suppliers located in countries outside the UK.
In these circumstances we will take the necessary steps to ensure that the transfer of your data is in line with UK data protection requirements and that your information is treated securely and protected to a similar standard. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and/or for our legitimate interests.
We’ll put in place the approved standard contractual clauses (as approved by the UK and European Commission) or any other appropriate safeguard which constitute appropriate measures to ensure that your personal data is treated by those third parties in a way that is consistent with, and which respects the European Union (EU) and UK laws on data protection.
If you are an Expatriate, due to the nature of the product you have chosen, a set of transfers of your personal information to countries outside of the UK may be required. Our lawful basis for these transfers is because they are necessary to implement precontractual measures and for the performance of a contract between you and Paragon.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area (EEA), they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing. For further information please contact the fraud prevention agencies listed within this notice.
We may need to collect personal information by law, under the terms of a contract we have with you. If you chose not to give us this personal information it may delay, or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts. It could mean that we cancel a product or service that you have with us.
If you wish to complain about how we have treated your personal data you can:
This notice was last updated in March 2024
We may make updates to this notice from time to time however if we make major changes to the way in which we process your personal data we will inform you directly.
Head officeParagon51 Homer RoadSolihullWest MidlandsB91 3QJ
Paragon Bank PLC is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registered in England number 05390593. Registered office 51 Homer Road, Solihull, West Midlands B91 3QJ. Paragon Bank PLC is registered on the Financial Services Register under the firm reference number 604551