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Comparable Privacy Policy

Last updated June 2025 - Privacy Policy

We are committed to protecting the information we hold about you. This Privacy Policy is to let you know how Comparable Ltd (“Comparable” or “we” or “us”) gathers and processes your personal information. This Privacy Policy also explains how others, such as third parties, and other sister companies of Comparable in the Lendable Operations Ltd group will process your personal information.

If you have any questions or want to exercise any of your rights set out in this Privacy Policy, please contact us at comparable@zable.co.uk.

Who are we?

We are Comparable Ltd (trading as Zable Insurance and Zable Mobile) . Our registered office is at Telephone House, 69-77 Paul St, London, EC2A 4NW and we are registered in England and Wales under company number 10754800. We are registered on the Information Commissioner's Office (ICO) Register of Data Controllers under registration number ZB805798.

We can be contacted:

by post at Comparable Ltd, Telephone House, 69-77 Paul St, London, EC2A 4NW; or by email at comparable@zable.co.uk. Our Data Protection Officer can be contacted by post at the address above.

How do we collect personal information?

We collect personal data about you in the following ways:

  • directly from you when you fill in forms on our site, any App we make available to you, or when you correspond with us by email, phone or otherwise;
  • by observing how you access and use our products and services. For example, how you use our website or how you manage your accounts with us;
  • from organisations that have your consent to share your data with us or for a separate legal basis for a specific or defined purpose. This could include for direct marketing or assessing your eligibility for a partner's product which may be suitable for you;
  • from public sources, for instance the Companies House register, the individual insolvency register, the ‘Open Register' part of the electoral register;
  • from search engine results, or your interactions with us (for example, through social media);
  • from third party organisations such as Credit Reference Agencies ("CRAs") and Fraud Prevention Agencies. The CRAs provide information on your financial behaviour. This is referred to as your credit history and gives lenders information on how you manage your finances (including things like your mortgage, credit cards overdrafts, loans, mobile phone contracts, and utilities)

What personal information do we collect?

We may hold and use various types of personal information collected at the start of, and during your relationship with us. We will limit the collection and processing of these personal data to what is necessary to achieve the purposes identified in this notice.

The information you provide to us must be correct, accurate, complete and not misleading.

Personal information may include:

  • personal details including your name, address, previous address, phone numbers, email address, date of birth, employment status and home ownership details;
  • financial and banking information including account details, transactional information, and any data you share with us when applying for an insurance product;
  • demographic and lifestyle information;
  • information about criminal convictions and offences (for example, for insurance applications)
  • behavioural metrics (including biometric data and information such as the way you use your device for any App we make available to you, or online service, or when making online payments or payments through our app, or your monthly data usage and other device metadata);
  • information collected from Credit References and Fraud Prevention agencies. We will collect this information at the point you first enquire about a product with us;
  • details of any contacts that we have had with you;
  • details of how you applied for a product with us (for example which browser you applied with);
  • details of any contact with us including any telephone, email or other communication with you;
  • information collected through customer feedback surveys;
  • open banking data that you have authorised us to access;
  • credit score and credit report related data from credit reference agencies if you instruct them to provide us with this data on your behalf; and

In some circumstances we may also collect and process special categories of personal information. In particular, we may process personal data that relates to your health (such as your medical history), biometric data, and any other information relating to criminal convictions and offences. This is to help ensure that our services are accessible and so that we can offer appropriate levels of support where required.

How do we use your personal information?

We may use your information:

  • to process and complete your application for a product with us;
  • to supply services to you;
  • to search CRAs’ and Fraud Prevention Agencies' records. For example, if you apply for a product with us, we may make periodic searches at CRAs to offer you other products and services which we consider to be of interest to you;
  • to set up and process payments and prevent fraudulent transactions;
  • to communicate effectively with you when applying for one of our products;
  • to effectively answer and manage any questions, concerns or complaints you may have;
  • to update our records and maintain your account with us;
  • to offer you products and/or services that may be of interest to you, where you have consented to be contacted for such purposes. This may include our making periodic searches of your credit file at CRAs;
  • to monitor, review and improve the content and appearance of our website, to ensure it is presented in the most effective manner for you;
  • to maintain and develop our business systems, including without limitation, testing and upgrading them;
  • to trace your whereabouts if we cannot contact you;
  • to recover any money you owe us;
  • to comply with our legal and regulatory obligations;
  • for any other specific purpose which we notify you of at the time your personal information is collected;
  • to pre-populate fields on our site to make it easier for you to navigate when you return to our website and login as an existing customer;
  • to help us analyse our business and develop marketing strategies, develop products and improve our advertising materials; and
  • to share your personal information (for example, your mobile number and email address), in a secure format, with social media companies who can match this to personal information they already hold about you so they can display messages to you about our products and services. If you do not want us to share your personal information with social media companies for this purpose, you can tell us not to.

We may monitor and record calls, emails, SMS and other communications to ensure transactions are executed correctly, detecting any vulnerabilities you may have, and for security, quality control, training and fraud prevention purposes.

If we cannot offer you a product, we may check your eligibility for a similar product from our panel of trusted partners. We will always seek your consent to do this and in assessing eligibility our partners will always use soft checks which will not impact your credit file.

Our partners include but are not limited to:

Why do we process your personal information?

We will only collect and use your personal information where it is necessary for us to carry out our lawful business activities. Our grounds for processing your data are as follows

Contractual necessity

We may process your information where it is necessary to enter into a contract with you or to perform our obligations under that contract or any service you have given us authorisation to carry out. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you.

This may include processing to:

  • assess your eligibility for the products and services we provide;
  • sharing information to assess your creditworthiness with CRAs, fraud prevention agencies, and account information service providers;
  • assess your eligibility for products including new loans and credit cards. This may include making periodic searches at CRAs ; and
  • provide and administer the products we offer, including:
    • setting up your account;
    • verifying your contact information;
    • collecting and providing to you required information and documents including statements and formal notices;
    • disbursing money and processing payments;
    • to manage fees, charges and interest due on your account;
    • to send you service communications and notices required by law;
    • to collect and recover outstanding sums owed to us;
    • to provide you with insights into your credit history and the factors affecting your credit score; and
    • to address any enquiries or complaints we receive from you or a representative you have appointed.

Legal obligation

We may process your data where it is a legal or statutory obligation on us.

This may include processing to:

  • confirm your identity;
  • detect, investigate and report transactions in order to comply with laws relating to money laundering, financial crime and international sanctions;
  • assess affordability of any credit products for which you apply;
  • detecting, investigating and reporting financial crime, and taking measures to prevent this;
  • maintain records of our business as required by law, e.g. creating and keeping record of company accounts;
  • complying with laws which require us to provide information, directly or indirectly to any national authority, for the purpose of calculating and collection of tax;
  • responding to enquiries and requests for information by any of our regulators including the Financial Conduct Authority and Information Commissioner's Office;
  • creating and submitting reports required by any of our regulators;
  • to otherwise meet our obligations under all laws and regulations based on law which apply to our business activities (which may involve our sharing your data with other sister companies belonging to the Lendable Operations Ltd group of companies); and
  • where we have a duty to protect vulnerable customers and provide them with support.

Legitimate interest

We may process your information when we have a business or commercial reason to do so. If we do, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

This may include processing to:

  • develop new products and services and identifying which may be of interest to you;
  • share information with you about our products or services that may be of interest to you by using social media companies;
  • contacting you to make you aware of such products and services, where we have the relevant permission to do so. This may include a reasonable period after your relationship has ceased with us;
  • collect information in order to perform statistical analysis, analytics and profiling, for example, to create scorecards, models and variables in connection with the assessment of credit, fraud, vulnerabilities, risk or to verify identities, to monitor and predict market trends, and for analysis such as loss forecasting (and share this information with other members of the Lendable Operations Ltd group of companies);
  • monitor, review and improve the content and appearance of our website or app(s), to ensure that content from our website or App(s) is presented in the most effective manner for you assess how our customers use our website, products and services;
  • maintain and develop our business systems, including without limitation, testing and upgrading them;
  • share information with organisations who introduce you to us under a commercial agreement;
  • share information to assess your creditworthiness (including with other members of the Lendable Operations Ltd group of companies);
  • assess your eligibility for other products we offer. This may include making periodic searches at CRAs and using data from account information service providers;
  • recover monies owed;
  • sell debts to other firms;
  • share with third parties for the purpose of preventing fraud and financial crime; and
  • obtain finance for the products we provide.

Who do we share your personal information with?

We may share your personal information with third party companies who provide services on our behalf, and/or third party companies who provide services to us. This may require these organisations to access and process your personal data.

These may include:

  • auditors;
  • CRAs;
  • fraud prevention agencies including CIFAS;
  • Account Information Service Providers (AISPs), Account Information Services (AIS), and Payment Initiation Service Providers (PISP);
  • our service providers and agents (including their subcontractors). This may include but is not limited to:
    • debt collection agencies and debt management companies and companies specialising in customer reconnection and general information gathering visits;
    • communications service providers offering mail, email and SMS text services. For example, we may use a third-party tool to enhance our service and assist in responding to your enquiries sent via live chat or email. Your personal data will only be shared with this tool if you disclose it. Comparable will not directly share any account-specific information with this tool; and
    • third parties providing services to us which are necessary for our legitimate interests and where permitted by law, e.g. AI-powered assistant tools to help enhance our service offering, or to support us with the delivery of services to you.
  • debt purchasers;
  • customer survey providers in order to receive feedback and improve our services (including Trustpilot who will invite you to share your opinion about your service experience with us);
  • IT service providers;
  • data security providers for debugging and product improvement purposes;
  • legal services;
  • digital and direct marketing service providers;
  • payment processors;
  • trusted third parties we partner with to provide you with products and/or services;
  • trusted lenders and brokers who will assess your eligibility for products;
  • prospective assignees of your account;
  • providers of payment-processing services and other businesses that help us process your payments, as well as other financial institutions that are members of the payment scheme (for example, Visa);
  • anyone we transfer or delegate (or may transfer or delegate) our rights or obligations to, as allowed under the terms and conditions of any contract you have with us;
  • your advisers (such as accountants, lawyers and other professional advisers) who you have authorised to represent you, or any other person you have told us is authorised to give instructions, or use the account, products or services, on your behalf (such as under a power of attorney); and
  • other subsidiary companies belonging to the Lendable Operations Ltd group of companies (including to provide you with products or services, and for internal reporting).

Sending personal data outside of the EEA

To deliver services to you, we, or one of our service providers, may transfer your personal data to countries outside either the UK or the European Economic Area (“EEA”), whose personal data protection laws are less strict than in the UK or the EEA.

Where we or one of our service providers do so, we will make sure suitable safeguards are in place to protect your personal data, in line with data protection law. The safeguards we use will depend on the circumstances and the third party who we transfer data to, but include relevant clauses in contracts or the ICO’s International Data Transfer Agreement to make sure the personal data is sent and received in line with any laws that apply.

Please contact comparable@zable.co.uk if you want to know more details about the above safeguards or obtain a copy of the standard contractual clauses we use to transfer data outside the UK and the EEA.

How do we use Credit Reference Agencies?

If you choose to apply for a product with us, we may perform credit and identity checks on you with one or more CRAs to allow us to process your application. Where you take services from us we may also make periodic searches at CRAs to manage your account with us and assess eligibility for products we offer. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit 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.

We may use this information to:

  • assess your creditworthiness and whether you can afford to take the product;
  • verify the accuracy of the data you have provided to us;
  • prevent criminal activity, fraud and money laundering;
  • manage your account(s);
  • trace and recover debts;
  • ensure any offers provided to you are appropriate to your circumstances; and
  • assess your eligibility for a similar product after your existing product has ended.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your accounts including settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt and payment performance. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

How do we work with Fraud Prevention Agencies?

The personal information we have collected from you may 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. The Fair Processing Notices for Cifas provides further details on how your information will be used by us and these fraud prevention agencies, and your data protection rights.

Consequences of Processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you.

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, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data Transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks' intended to enable secure data sharing.

How can you amend your preferences?

When we first collect your data we will give you the opportunity to amend your preferences. Any electronic marketing communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time. You may also amend your contact preferences in the following ways or by logging into your online account and amending details there;

What are your personal data rights?

As a data subject, you have a number of rights:

  • the right to access the personal data we hold about you;
  • the right to rectify inaccurate personal data or complete it if it is incomplete;
  • the right to have your personal data deleted;
  • the right to request restriction of or suppression of your personal data;
  • the right to obtain and make use of your personal data for your own purposes across different services (“portability”);
  • the right to object to the processing of your personal data in certain circumstances;
  • rights related to automated decision-making including profiling, and
  • the right to withdraw consent at any time. In certain circumstances, we may need to get your consent before we can access or process your personal data. If this happens, we will always ask for your consent first. If you have given us consent in the past but subsequently change your mind, you can withdraw your consent at any time by emailing cards@zable.co.uk

Your data protection rights are subject to certain restrictions and conditions and financial organisations are required to retain a range of your information for legal and regulatory reasons including responsible lending and the prevention of financial crime. We are required to keep a record of the information reported to the CRAs about you and will therefore retain repayment information regarding your account for six years from the end of the relationship (where your account settled and closed). If your account is recorded as defaulted, the data is kept for six years from the date of the default. This may be extended where we require this to bring or defend legal claims.

If you think that any of the personal data we hold about you is wrong or incomplete you have the right to challenge it.

We will not make a charge for handling your rights request, unless we consider it to be manifestly unfounded or excessive involving a disproportionate effort (particularly if this is repeated request). If you would like to exercise any of the rights outlined above, you can make a request by calling 020 3322 9128 or in writing by emailing cards@zable.co.uk.

We will assess your request and if we decide not to act upon it or place certain restrictions on it, we will inform you of our reasons for this.

You have the right to complain to us and to the data protection regulator, the Information Commissioner's Office. Their address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by phone on 0303 123 1113 (local rate) or 01625 545745 if you prefer to use a national rate number.

You can find details on how to report a concern at: https://ico.org.uk/make-a-complaint

‘Special categories’ of personal data

We will not typically ask you for any ‘special categories’ of personal data. This is also referred to as ‘sensitive personal data’ and includes information revealing an individual's political opinions, racial or ethnic origin, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning an individual's sex life or sexual orientation.

We may process personal data about your health or medical conditions, including but not limited to where we need to understand this to provide you with support, or to make adjustments in how we provide you with information or provide you with additional services that you may need. Companies acting on our behalf specialising in identifying vulnerable customers or customer reconnection and information gathering visits may also process personal data about your health or medical conditions for this purpose. If we process such data, we will do so to comply with our legal obligations to support you if you are, or become a vulnerable customer, and to establish, take or defend any legal action.

How long do we keep your personal information?

We will retain your personal data for as long as we are required to under relevant legislation and regulation, and where no specific rules apply, for no longer than it is necessary for our lawful purposes. This will usually be no more than six years from the end of our relationship with you. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims.

We may also retain data for longer periods for statistical purposes, and if so we will anonymise this.

How do we protect your information?

We use leading cloud services that have adopted industry security best practice frameworks to protect your data in transit and at rest.

How do we use automated decisions?

We may use your personal data in automated processes to make decisions about you. You have the right not to be subject to a decision based on solely automated processing, if this will have a legal or other significant effect on you (certain exceptions apply).

We may use automated decision making in:

  • managing fraud and money laundering risk identification. If our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with information that you have provided previously, or you appear to have deliberately hidden your true identity we may decide that you pose a fraud and money laundering risk;
  • profiling to identify whether you are suitable for products and services we offer and to inform you of these. We may use profiling in conjunction with our partners when developing new prospect marketing campaigns; and
  • determining appropriate action to take, where your account has gone into arrears or default. You have the right for this to be reconsidered manually

Changes to our Privacy Notice

You can ask us for a copy of this Privacy Notice using the contact details set out above. We may change or update this Privacy Notice from time to time. If changes to this Privacy Notice will have a major effect on what we do with your personal data or on you personally, we will give you enough notice to allow you to exercise your rights (for example, to object to the processing).