Privacy Policy

Last Updated - 9 May 2025

Who we are

Comuno is a trading name of Choose Wisely Limited, a company registered in England and Wales (Company No. 07580462) with its registered office at This Workspace, 18 Albert Road, Bournemouth, England, BH1 1BZ

We are authorised and regulated by the Financial Conduct Authority (FCA) as a credit broker under registration number 730574 as a credit broker, not a lender.

Comuno connects people with community finance providers, such as credit unions and community development finance institutions, offering fair and affordable credit options. We also provide information and tools to help users make informed financial decisions.

We are committed to protecting your privacy and handling your personal information in a lawful, fair, and transparent way.

Our role and legal basis for processing

When you use Comuno, we act as a data controller for your personal data. This means we determine how and why your information is processed.

We process your data under one or more of the following lawful bases:

  • Consent - when you ask us to share your data with a lender, community finance provider, or partner.

  • Contract - to perform the services you’ve requested (for example, to match you with suitable credit providers).

  • Legal obligation - to meet our regulatory duties under FCA and consumer credit laws.

  • Legitimate interest - to improve our services, ensure site security, and prevent fraud.

The information we collect

We collect and process the following types of data:

Information you provide directly

  • Personal details (name, address, date of birth, contact details)

  • Financial information (income, expenditure, employment details)

  • Credit and affordability data, where provided through Open Banking or credit reference agencies

  • Your loan preferences and application details

Information we collect automatically

  • IP address and device identifiers

  • Website analytics (via cookies and similar technologies)

  • Behavioural data (how you use our site and interact with offers)

Information from third parties

  • Credit and affordability data from credit reference agencies and Open Banking providers

  • Application outcomes and performance data from lenders and community finance providers

How we use your information

We use your data to:

  • Match you with suitable community finance providers

  • Send your application details to those providers when you give consent

  • Provide you with personalised product comparisons and signposting via our Money Medic service

  • Verify your identity and prevent fraud

  • Comply with our legal and regulatory obligations

  • Improve our products, services, and website performance

We do not sell your data to third parties.

Who we share your data with

We may share your personal data with:

  • Community finance providers and credit unions - when you ask us to refer you to them.

  • Partner organisations - such as credit reference agencies, Open Banking partners, and Money Medic partners (e.g. Inbest.ai) for eligibility and signposting services.

  • Service providers - companies that help us host, secure, and maintain our website or systems (e.g. AWS, analytics providers).

  • Regulators or law enforcement - such as the FCA or the Information Commissioner’s Office (ICO), when legally required.

Each party is subject to strict contractual and data protection obligations.

International transfers

Your data is primarily stored in the UK or European Economic Area (EEA).

If we transfer your data outside the EEA, we ensure it is protected through recognised safeguards such as:

  • Adequacy decisions (e.g. transfers to countries approved by the UK government), or

  • Standard Contractual Clauses approved by the ICO.

How long we keep your data

We retain your data only for as long as necessary to:

  • Fulfil the purpose for which it was collected,

  • Comply with legal or regulatory requirements, and

  • Defend against potential claims.

Typically, this means keeping application data for up to 6 years after your last interaction with us.

Your rights

Under the UK GDPR, you have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete information

  • Request deletion of your data (“right to be forgotten”)

  • Restrict or object to processing in certain cases

  • Withdraw consent (where processing is based on consent)

  • Request data portability

To exercise your rights, please email privacy@comuno.co.uk or write to us at our registered address.

If you’re not satisfied with how we handle your data, you can complain to the Information Commissioner’s Office (ICO):

www.ico.org.uk

Cookies and tracking

We use cookies to improve your browsing experience, analyse traffic, and personalise content.

You can manage your cookie preferences at any time through your browser settings or our cookie banner.

For more details, see our Cookie Policy.

How we protect your information

We use robust security measures to keep your data safe, including:

Encryption in transit and at rest

Secure hosting with AWS and Cloudflare

Regular vulnerability scanning and access controls

Staff training and audit logging

We also comply with FCA data security and confidentiality requirements, ensuring data integrity, lawful sharing, and fair processing across all systems.

Children’s data

Comuno is not intended for individuals under 18.

We do not knowingly collect or process data from anyone under 18 years of age.

Updates to this policy

We may update this policy from time to time to reflect legal, regulatory, or operational changes.

Any updates will be published on this page with a new “last updated” date.

Contact us

If you have any questions about this Cookie Policy or how we use cookies, please contact:

location iconThis Workspace, 18 Albert Road, Bournemouth, England, BH1 1BZ
location iconhello@comuno.co.uk