Effective date: 20th August 2020
Debt Owl Advice understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, http://www.debtowladvice.co.uk/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
2. Information About Us
2.1 Our Site is owned and operated by Us.
2.2 Our Data Protection Officer can be contacted by email at email@example.com, or by post. Please address postal correspondence to: The Data Protection Officer, Debt Owl Ltd, 120 Bark St, 6th Floor, Bolton, BL1 2AX.
2.3 We are Debt Owl Ltd is an Appointed Representative of Pebble Protection Limited and is entered on the Financial Services Register under reference number 932608. Pebble Protection Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference number: 807915 and you can check this on the Financial Conduct Authority website: https://register.fca.org.uk/s/ed
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 residential status;
5.3 date of birth;
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as resided country;
5.6 employment status;
5.7 IP address;
5.8 cookies and tracker information from your browser and/or device;
5.9 web browser type and version;
5.10 operating system;
5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5.12 where you contact us by phone, email or post a record of that contact;
5.13 where you contact us by phone we will retain a recording of that call.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests (see 6.8 below for further information). Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 For monitoring of calls made to and from customers to ensure that we are meeting the standards that we set;
6.2.6 personalising and tailoring Our services for you;
6.2.7 replying to emails from you;
6.2.8 supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us on firstname.lastname@example.org;
6.2.9 market research;
6.2.10 analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.2.11 to manage your marketing preferences;
6.2.12 to manage your data processing preferences;
6.2.13 to compile anonymised data for analytical purposes.
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.7.1 As a general rule, unless we have been requested to delete Your information, Customer personal data will be kept for the duration of the provision of the services and for a period of up to five years after the services have been terminated by You or Us.
6.7.2 Where we have not provided You with any products or services (i.e. there has been no contract between You and Us), then we will keep your data for a period of 12 months.
6.7.3 We may keep data longer than stated in 6.5.1 and 6.5.1 where we are required to do so by law or a contractual obligation, however where we can we will anonymise such data so that it no longer identifies a living individual.
6.7.4 Call recordings are retained for a period of five years from the date that the call is made.
6.8 Legitimate Interest
6.8.1 Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.
6.8.2 You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 14.
6.8.3 Our legitimate interests include:
a) the maintenance of our IT/Data Security systems and processes;
b) putting in place fraud prevention mechanisms;
c) keeping our records up to date;
d) working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
e) developing products and services;
f) being efficient about how we fulfil our legal duties;
g) maintaining a marketing suppression list; and
h) complying with laws/regulations that apply to us.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 All our customer data is sorted and accessed from our servers in the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
8. Do We Share Your Data?
8.1 We may share your data with other companies for carrying out/putting in place the debt solution that we recommend and for reporting purposes.
8.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:
8.3.1 Pebble Protection Limited – Our Principle
8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you control on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
11.1 You may access Our Site without providing any data at all.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14.
14. Contacting Us