Privacy Policy

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Introduction

Asset Collections and Investigation Limited (“ACI”) company registration number 03775287, with its registered office address situated at Unit 10, Whitehills Business Park, Whitehills Drive, Blackpool, Lancashire, FY4 5LW. Also referred to as “we”, “us” or “our” in this Privacy Notice.

ACI is registered with the Information Commissioners Office (“ICO”) with the ICO registration number ZA116228.

ACI takes the preservation of your privacy and the security of your personal data very seriously. We will control and process your personal data fairly and lawfully in accordance with the Data Protection Act 1998 and with the General Data Protection Regulations 2018, solely for the purpose of collecting repayment of the debt acquired and to manage your account.

This Privacy Notice will inform you as to how we use and protect your personal data when your account is assigned to us or when it is passed to us to manage on behalf of a third party; and it explains your privacy rights and how the law protects you.

Please also use the Schedule to understand the meaning of some of the terms used in this document.

1. Important information and who we are;

Purpose of this Privacy Notice

This Notice aims to give you information on how ACI collects and processes your personal data, including any data you may provide over the telephone, via letter, email or via our website www.assetcollections.uk (“the Website”).

The Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Notice together with any other Privacy or Fair Processing Notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data

Please note – This policy may be amended from time to time so please check back to ensure you are aware of any changes.

Data Controller

ACI are the Data Controller and become responsible for your personal data when your account is assigned to us.

Data Processor

ACI are a Data Processor when managing your account on behalf of another creditor who legally owns your account (the Data Controller).

Data Protection Officer

We have appointed a Data Protection Officer (“DPO”) who is responsible for advising ACI about data protection, for monitoring internal compliance, and to act as a point of contact for data subjects (customers) and the ICO.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Email address: dpo@assetcollections.co.uk

Postal address: Unit 10, Whitehills Business Park, Whitehills Drive, Blackpool, Lancashire, FY4 5LW

You have the right to make a complaint in relation to the way we process your personal data at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us / our DPO in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on 20th May 2018 and historic versions can be obtained by contacting us / our DPO.

The data protection law in the UK will change on the 25th May 2018. This Privacy Notice sets out your rights under the new laws.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes address, email address, telephone numbers and details of employment.

  • Financial Data includes bank account details, salary details, assets, liabilities, details on any dependants, income and expenditure and payment card details.

  • Transaction Data includes details about payments to and from you, details of any arrears, details of arrears charges and associated costs.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.

  • Profile Data includes your username and password, payments made by you, your financial situation, marketing preferences, feedback and survey responses.

  • Usage Data includes information about how you use our Website, payment line and services.

  • Communications Data includes your preferences in relation to how we communicate with you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not generally collect any Special Categories of Personal Data (Sensitive Personal Data) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, however, we may on occasion collect information about your health and about criminal convictions and offences. We will only collect and process this data with your express permission and where it is reasonable and necessary to assist us with the management of your account.

If you fail to provide personal data

Where we need to collect personal data by law and you fail to provide that data when requested, or if we have been provided data that is or appears to be out-of-date personal data by the original lender, we may verify and / or obtain up to date personal data from other reliable third-party data sources.

3. How is your personal data collected?

Initially we are provided with your personal data by a Lender or Debt Purchaser, when they assign the account to us or when they pass the account to us to act on their behalf. They are the original Data Controller of your personal data and when we take over the ownership of your account (on assignment) we also become a Data Controller of your personal data. When we are passed your data to act on behalf of a Lender or Debt Purchaser they remain the Data Controller and we become a Data Processor.

We may also receive some personal data from you including via:

    • Direct interactions You may give us your Identity, Contact and Financial Data by completing a call back form via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;

    • contact us to discuss your account;

    • requesting information from us;

    • create an account on our Website;

    • use our 24-hour payment line;

    • complete a survey; or

    • give us some feedback.

Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Websites employing our cookies. Please see our Cookie Policy on our Website for further details.

    • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below;

· Technical Data fromanalytics providers such as Google based outside the EU;

· Contact, Financial and Transaction Data from providers of technical, payment services based inside the EU.

· Identity and Contact Data from the Credit Reference Agencies we use based inside the EU.

· Identity and Contact Data from publicly available sources such as the Electoral Register based inside the EU.

· Identity and Contact Data from online tracing tools based inside the EU.

· Cifas, a fraud prevention agency or similar fraud prevention agencies.

· The Insolvency Service or insolvency practitioners.

· Debt Management Companies.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to understand your personal circumstances and assess your income and expenditure in relation to payment proposals.

· Where we need to enquire about your Identity and Contact Data from third party data sources or online tracing services.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

To enable us to understand your personal and financial situation and to contact you about your account.

To set up a suitable payment arrangement.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Marketing and Communications

(a) To enable us to understand your personal circumstances and financial situation in order to set up an affordable and sustainable payment arrangement.

(b) We may also use third party tracing services.

To set up a payment arrangement and manage repayment of the account until the final payment is made.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Marketing and Communications

To enable us to collect payments towards the outstanding balance and prevent further enforcement action.

To manage our relationship with you which will include:

(a) Meeting our regulatory obligations including providing you with statutory or regulatory information.

(b) Managing your account.

(c) Notifying you about changes to our Terms or Privacy Policy

(d) Asking you to leave a review or take a survey.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Marketing and Communications

(a) Management of the account.

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services)

(d) Necessary for our legitimate interests (to recover debts)

To enable you to complete a survey.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Management of your account with us.

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business).

(c) To understand the customer experience and provide better customer services for our customers.

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation.

To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you

(a) Identity

(b) Contact

(c) Technical

(d) Profile

(e) Usage

(f) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our services, to develop them, to provide a better customer experience, to grow our business.)

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.

(a) Technical

(b) Profile

(c) Usage

(a) Necessary for our legitimate interests (to define types of customers for our services.

(b) To keep the Website updated and relevant, provide a better customer experience.

(c) To develop our business and to inform our marketing strategy).

 

Marketing

We do not currently conduct any marketing or advertising to our customers.

Third-party Marketing

We do not currently conduct any marketing or promotions with third parties.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy on our Website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us .

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

· External Third Parties as set out in the Schedule.

· Specific third parties listed in the table in the Schedule.

· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not generally transfer your personal data outside the European Economic Area (EEA). However, if the original creditor or previous owner of your account is located outside the EEA we may on occasions, but only as required, raise or respond to queries or questions raised by you.

7.Data security

ACI makes every effort to ensure appropriate safeguards are in place for the storing and processing of your personal data using both technical and organisational methods. Our servers and your personal data are stored in the EU.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a need to know basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so or where we feel it is in your best interests to do so.

8.Data retention

How long will you use or store my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal and regulatory purposes.

In certain circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. More information about your rights is provided in the Schedule.

  • · Request access to your personal data .
  • · Request correction of your personal data .
  • · Request erasure of your personal data .
  • · Object to processing of your personal data .
  • · Request restriction of processing your personal data .
  • · Request transfer of your personal data .
  • · Right to withdraw marketing consent .
  • · Right to request a manual decision-making process where an automated decision-making process has been used.

If you wish to exercise any of the rights set out above, please contact us / our DPO.

Identification

For security purposes we may wish to request specific information from you to help us confirm your identity before taking action to comply with your request to exercise your rights.

Fees

In general, you will not have to pay any fees to exercise your rights.

Time limit to respond

We try to respond to all legitimate requests within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

SCHEDULE

1. LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us / our DPO.

Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

2. THIRD PARTIES

Internal Third Parties

Other companies in ACI acting as joint controllers or processors and who are based within the United Kingdom and provide IT and system administration services and undertake leadership reporting.

External Third Parties

· Service providers acting as processors based in the United Kingdom who provide I.T., SMS messaging services, call recording services, customer satisfaction survey administrators and system administration services.

· Professional advisers acting as processors or joint controllers including lawyers, bankers, debt recovery agents, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, debt recovery services, tracing agents, insurance and accounting services.

· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

· HM Courts & Tribunals Service and other authorities acting as processors or joint controllers based in the United Kingdom.

· Credit Reference Agencies acting as processors or joint controllers based in the United Kingdom who we may use to conduct credit searches and who we report account conduct to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.