Privacy & Cookie Policy

We promise:

• To keep your data safe and private

• Not to sell your data

• To give you ways to manage and review your marketing choices at any time.

The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we're required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

• Your personal details (e.g. name, date of birth)

• Address details

• Contact details (e.g. phone number, email)

• Special personal information (e.g. health information)

• Financial information (e.g. details of your income and expenditure)

• Employment information

• Information about your creditors

• Information on how you use our website(s) and products and services

Data protection law defines some personal information as "special categories of data". This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you.

If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, a joint Individual Voluntary Arrangement), your personal information and any information about the service provided to you will be shared with the other person.

We may obtain personal information from you in a number of ways:

• When you make an application or enquiry to us either by email, phone, via our website, by a third party or by any other means

• By adding reviews or interacting with us using social media such as Twitter or Facebook

• When we may need to obtain up to date information about you to meet our legal or regulatory obligations

• Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us

• When you participate in market research

• Where you have given permission for your information to be provided to us

We can only use your personal information where it falls into one or more of the following categories:

• It is necessary to enter into or fulfil a contract we have with you

• You have provided your consent

• We have a legal or regulatory obligation to do so

• It is necessary to carry out a task that is in the public interest

• It is necessary to protect your vital interests

• It is in our legitimate interest to do so and it is not against your rights

Where you make an application or enquiry for one of our products or services, we'll use your information to provide you with appropriate information to recommend a suitable debt solution. We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to welcome you to our services.

Where we give you advice regarding an Individual Voluntary Arrangement, we will process your personal information to administer the service we provide. This may include contacting you where we may need further information or sending you updates on the progress of the service we provide to you.

To be able to provide you with advice regarding insolvency solutions we need to collect certain categories of personal data. This will include:

• Contact details – Your full name, address, contact number, e-mail address etc. This is so we can contact you about and process your enquiry.

• Personal and financial details – Your date of birth, gender, any previous names, your living arrangements, employment details, details of any dependants, details of any assets you hold and your payment information.

• The people you owe money to and your property and assets – creditor details (including the names of your creditors, reference numbers and balances).

• Your income and expenditure – details of your financial position including all sources of income and your household expenditure.

• Call recordings, chat logs and e-mails: When you contact us by telephone, your call may be recorded for training and monitoring purposes. We also keep any e-mail correspondence and online chat logs to help us to manage your IVA.

• Special personal information – only with your permission and where this is relevant to your financial situation and how a debt solution needs to work for you, or where we have a legal right to do so.

We may share your information with our Debt Solution Providers/partners, i.e. IVA companies who provide and/or administer the plan on our behalf. We will only share your information with them if they've agreed to keep it confidential.

In addition, your information may be shared with:

• Your creditors and their representatives: Your personal data will be shared with your creditors, their agents, debt collectors, bailiffs and solicitors dealing with the debts.

• Our regulators, such as the Insolvency Practitioners Association and the Institute of Chartered Accountants for England and Wales, the Information Commissioner's Office or any other regulatory body.

• The Insolvency Service: If your IVA is accepted then details about you and your IVA will be recorded on the Insolvency Register which is accessible by the public. The information we share includes your name, gender, date of birth and address. We have a legal obligation to supply this information.

• Credit reference agencies (CRAs) where we have your authority or a legitimate interest, including TransUnion (formerly Callcredit), Equifax, and Experian.

• Solicitors: We may from time to time need to instruct solicitors to assist with the administration of your IVA or to assist us with legal, regulatory and contractual obligations.

• IT Providers: We use third-party software companies to help manage your data, including case management systems, payment processors, telephony companies and external printing companies.

• MoneyPlus Group, The Insolvency Group and J3: We work with these organisations and share your data with them for direct marketing purposes; they also provide regulated debt advice.

If you continue to be our customer and we give you advice, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we're required to keep your data to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

If you do not go ahead with any product or service offered by us, your personal information will normally be deleted after 2 years (except for any recorded telephone calls) unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing or promotional messages from us.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Websites and marketing: To help us understand you better and provide you with information about other products which may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances. If you don't want us to profile your personal information this way, you can contact us to let us know.

Reviews and market research: Where we have a copy of your personal information we may contact you to ask you to provide a review about the services you've received or where we are carrying out market research. Although this information would really help us, you wouldn't be required to provide us with this information unless you were happy to.

Legal or regulatory obligation: We are required to process your personal information where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering or our regulatory obligations.

Responding to complaints or enquiries: If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.

Internal analysis: As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis. We will use as little personal data as we can to achieve this.

We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

• Company security policies and standards

• Staff security awareness and role-based access controls to prevent unauthorised access

• Encryption and anonymisation technology

• Anti-malware technologies

• Security monitoring and testing

• Secure archiving and deletion

• Compliance with industry regulation and legislation

To help us keep you up to date about the products and services that we provide to you, we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any online customer platforms or other electronic means.

If you start an application for a product or service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.

If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you, we do need to be able to send you communications. It is important that you keep us up to date when you change your contact details.

We record any telephone calls you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.

We may keep a copy of the telephone calls for up to 6 years from the date the telephone call was made.

Access to your personal information: You have the right to request from us a copy of the personal information that we may hold about you (a "Data Subject Access Request"). You can request this information by contacting us. We won't charge you to provide you with this information.

Right to have your personal information corrected: If the personal information we hold about you is incorrect you have the right to request that we correct this.

Right to stop or limit processing: You may request that your personal information is deleted or that we stop processing the information if we're no longer entitled to process it. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations.

Portability: In some cases you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically. If you want to request this you'll need to contact us.

The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Further details can be found by contacting us at: Will Fletcher, The Forum, Tameside Business Park, Windmill Lane, Denton, M34 3QS.

We will only share your personal information outside the European Economic Area (EEA), where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.

If we do share your information outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA to ensure appropriate safeguards are in place.

When using this website, some information may be collected automatically using 'cookies'. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used.

There are two types of cookies by lifespan:

• Temporary cookies: these form part of the security process and expire when you close your web browser.

• Permanent cookies: these stay in your device for a longer period of time or until you manually delete them.

There are also two types by entity:

• First-party cookies: set by the website that you are visiting, either by us or by a third-party at our request.

• Third-party cookies: set by a third-party rather than the provider of the website that you are visiting.

Cookies allow sites to provide personalised content and remember log-in details and settings. They also tell website owners things like what search engine a visitor used to find the website, how often they've visited it, and how long they've spent on it. Except for essential cookies, all cookies will expire after 10 years.

You have the ability to accept or decline cookies by modifying the settings on your browser. Please remember that disabling certain cookies may affect the functionality of our website. Further information on managing cookies can be found at https://allaboutcookies.org/

If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer:

Will Fletcher, The Forum, Tameside Business Park, Windmill Lane, Denton, M34 3QS

Any updates to this privacy policy will be found on this page. If we make any important or significant changes to the way we may collect and use your personal information we will endeavour to notify you of this change.