What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Financial data (including income and expenditure)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Information relating to compliments or complaints
• Video recordings
• Audio recordings (e.g., calls)
• Records of meetings and decisions
• Account access information
• Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Purchase or service history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences
• Technical data, including information about browser and operating systems
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We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Purchase or account history
• Website and app user journey information
• IP addresses

We collect or use the following personal information for research or archiving purposes:

• Names and contact details
• Addresses
• Purchase or client account history
• Website and app user journey information
• IP addresses

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Identification documents
• Client account information
• Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Payment details
• Account information
• Purchase or service history
• Call recordings
• Photographs
• Relevant information from previous investigations
• Customer or client accounts and records
• Financial transaction information
• Information relating to health and safety (including incident investigation details and reports and accident book records)
• Correspondence

Lawful bases data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure– You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing– You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • o Information is collected in order to provide relevant services to our clients to improve the work that we deliver and for the interests of the company to generate further income by delivering additional services.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Information is collected in order to provide information and marketing updates to our clients to improve the work that we deliver and for the interests of the company to generate further income by delivering additional services.
  • We gather information from potential clients who have indicated an interest in our services or what we identify may have an interest in our services in order to offer relevant services or deliver additional services.

Our lawful bases for collecting or using personal information for research or archiving purposes:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Information is gathered in order to further understand the performance of customer social media or websites. We use this information to plan further marketing activities, refine performance, and generate more engagement for our client.
  • We conduct research into the performance of our client’s competitors, from publicly available information, in order to improve our marketing efforts on our client’s behalf.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • It is in our legitimate interest, and our client’s, that we respond appropriately to any queries or complaints.

How we get personal information from you

• Directly from you
• Regulatory authorities
• Debt collection agencies
• Publicly available sources
• Market research organisations
• Credit reference agencies
• Providers of marketing lists and other personal information
• Suppliers and service providers
• Third parties:
  • Data Cleansing Providers

How long we keep information

The data we gather is periodically reviewed and kept for as long is reasonably necessary to meet our legitimate interests.

Who we share information with

Data processors

Hubspot CRM

Data Cleansing Providers

This data processor does the following activities for us: We may work with data cleansing providers to source or cleanse data lists for marketing purposes.

Others we share personal information with

• Debt collection agencies
• Other financial or fraud investigation authorities
• Insurance companies, brokers or other intermediaries
• Professional or legal advisors
• Emergency services
• Insolvency practitioners
• Regulatory authorities
• External auditors
• Organisations we’re legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media
• Suppliers and service providers
• Professional consultants

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Hubspot

Category of recipient: CRM software provider

Country the personal information is sent to: USA

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

6 December 2024

To be reviewed

6 December 2025