2. What information do we collect about you?
Where We Get Your Personal Data From: You may share personal data about yourself and your circumstances with us through use of our Website or within phone calls, emails or otherwise. We may also receive personal data about you from third parties such as from companies who instruct us to provide debt collection services, other companies which are our group companies and credit reference agencies.
What Categories of Personal Data Do We Collect?: The personal data that we collect ourselves and receive from third parties may include the following: your name, address, e-mail address, phone number, debt information, payment history, credit reference information, and any other details relating to your account.
Also, each time you visit our Website we may automatically collect information and personal data about your computer for system administration, including where available your IP address, operating system and browser type.
We collect limited sensitive personal data as required by the FCA and we have set out more detail on this in the section headed “Sensitive Personal Data”.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
We collect information on our websites, which you provide to us and we also obtain from third parties such as credit reference agencies, existing creditors and debt management companies when your details are passed on to us. Website usage information is collected using cookies. We collect, for example, personal information to allow you to use our websites or use the secure online service provided and the information we collect will depend on which services you access and use.
Typically, we may collect the following information about you:
- Any information, including personal information you submit via our websites;
- Any information in relation to an account that is processed or serviced via our websites
Some personal information is also gathered when you register to use the online services provided. We also collect information when you voluntarily complete customer survey or provide feedback. If you email us, or give us your email address, we will record it. We may use it to contact you occasionally about your account.
3. Uses made of your personal data?
Fredrickson International Ltd may use personal data held about you in the following ways:
- for our debt collection purposes and those of our group companies including to manage your account, to tailor payment plans to your individual circumstances, to carry out our obligations arising from purchasing your account, to locate you and to check/update your contact details;
- to carry out account analysis for ourselves and our group companies such as to determine whether you are likely to pay your debts;
- to provide services to our clients in relation to debt collection (including to manage your account and to tailor payment plans to your individual circumstances), analysing your account (such as to determine whether you are likely to pay your debts, assessing affordability and to enable our client to make financial decisions), your payment history, account usage, check/update your contact details and to locate you.
- to administer our Website;
- to improve our Website to ensure that content is presented in the most effective manner;
- to allow you to participate in interactive features of our service, when you choose to do so; and
- to prevent money laundering and fraud.
Please note that as a user of our Website, you are responsible for keeping any passwords used to access your personal account information confidential.
If you require further information about the purposes for which we use your personal data then please contact our Data Protection Officer at:
By letter: The Data Protection Officer, Lowell Financial Ltd, Ellington House, 9 Savannah Way, Leeds LS10 1AB.
By email: email@example.com
BASIS FOR USING YOUR PERSONAL DATA
Our use of your personal data for the purposes set out above is for the legitimate interests of our business. As indicated above we may also pass your personal data to group companies and third parties this is also for our legitimate business interests.
HOW LONG WILL YOUR PERSONAL DATA BE KEPT BY US?
We will retain your personal data for six years from the closure of each account you hold with us.
DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
We may share your personal data with group companies as set out above as under the heading “Uses Made Of Your Personal Data”.
Fredrickson International Ltd may also share your personal data with certain third parties as follows:
- We may share your personal data with third parties who are our clients in the financial services industry as set out above under the heading “Uses Made Of Your Personal Data”.
- We may subcontract some of our services to sub-contractors and we may share your personal data with our sub-contractors as data processors.
- We may share your personal data with our suppliers who provide goods and services to us to enable them to provide these to us. These suppliers are our data processors and may only use your personal data in the way we specify.
If we or any member of the Lowell Group merges, transfers or sells part or all of the business to a third party, your personal data may be disclosed to the third party and any relevant advisors. Further, if the transaction goes ahead, the third party may use or disclose your personal data as set out in this policy.
SENSITIVE PERSONAL DATA
The Act defines certain personal data as ‘sensitive’ such as personal data regarding your ethnic origin, physical health and mental health.
We are required by the Financial Conduct Authority to understand whether the people that we deal with could be regarded as vulnerable and this may involve collecting and using sensitive personal data. We may, for debt collection purposes, therefore ask you for some sensitive details or you may voluntarily give such personal data to us. We will only use this personal data for debt collection purposes and we will obtain your consent to processing this data. We may share any of your sensitive personal data with other members of the Lowell Group and/or instructing clients for debt collection purposes only. Any sharing of your sensitive personal data will be on the basis of your consent or if we are required or permitted to do so under the Data Protection Act 1998.
CREDIT REFERENCE AGENCIES
Credit Reference Agencies (“CRAs”) hold personal data about consumers. Most of the personal data held by the CRAs relates to how you have maintained your credit accounts. They also hold address details and personal data from public sources such as the electoral roll, public records including county court judgments, and bankruptcy and insolvency data. We may obtain personal data about you from the CRAs for debt collection purposes and to check your credit history, verify your identity (or someone linked with you), to locate you and to prevent fraud protection and money laundering.
If you fall behind with your payments and a full payment or satisfactory payment plan are not made, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on your credit file for 6 years. Other organisations may see these defaults and any searches done on your file, and these may affect your ability to borrow from other lenders.
WHERE WE PROCESS YOUR PERSONAL DATA
The data that we collect from you will not be transferred to and stored anywhere outside of the EEA.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website.
RECORDED PHONE CALLS
We may monitor and/or record phone calls between our staff and you in order to offer you and our staff additional security, resolve complaints, for training purposes and to improve our quality and service standards.
4. How do we protect your personal information?
When you use the online secure area of our website your information is encrypted whilst it is being transferred over the Internet. We have appropriate technological and operational procedures in place to protect your information from any loss, misuse, alteration or destruction and all persons within the Group are subject to strict obligations of confidentiality. We endeavour to take all reasonable steps to ensure your personal information is protected.
To help protect your personal data and minimise the risk of it being intercepted by third parties, we offer the use of a secure server and use industry standard encryption when you submit information through our websites. Data that is provided to us is stored on our secure servers.
However, we cannot guarantee the security or the integrity of information which you send online. The transmission of information via the Internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk. In particular, you should not use email to send confidential or sensitive information.
When emailing us, we would recommend you always use the secure messaging service on our website, www.fredpay.com , to make sure that the content of your email is secure. If you send us email in other ways, remember that it could be intercepted so please keep the amount of confidential information you include to a minimum. We will not give your email address to any unauthorised third parties.
Your access to the online secure area of our website is password protected so that only you have access to your personal information. Where we have given you (or where you have chosen) a password so that you can access our online secure website, you are responsible for keeping this password confidential. We strongly recommend that you do not divulge your password to anyone and we will never ask you your password in unsolicited phone calls or emails.
5. Access to your information and correction
You have the right to request a copy of the information that we hold about you. We may at our discretion make a small charge of £10 for this service which covers our costs in providing you with the information requested. If you would like a copy of some or all of your personal information, please contact us using the contact details below.
We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or remove information you think is inaccurate. You can update your details via our secure messaging service. Alternatively, you can either talk to one of our customer advisors on 0345 543 9907, or email us by sending an email to firstname.lastname@example.org , or you can send your request in writing to us at Fredrickson International, PO Box 990A, Surbiton, KT1 9YX.
- Google Analytics, such as analysing the traffic to our websites and to speed up access to our websites ; and
- To ensure the text and font styles displayed are legible by using Scalable Inman Flash Replacement or SIFR
We will ask you on the homepage whether you want us to place a cookie on your computer for the above reasons.
We do not use persistent cookies, i.e. those that are pushed out to your computer and stored. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our websites in order to tailor it to the needs of our customers. We only use this information for statistical analysis purposes and then the data is removed.
However, when you log in to the secure area of our website to access your account(s), we will require the use of a cookie to keep you logged into the secure account area. The purpose of this cookie is to enable you to remain logged-in to the website for the duration of your Internet browser session and removes the need for you to input your log in details each time you browse to a new page. When you close your Internet browser, the cookie will be automatically removed. This cookie only contains your User ID, which is a database reference and does not contain any other personal data. By logging in to our secure area, you consent for us to place a cookie on your computer.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can set your browser not to accept cookies and the websites listed below tell you how to remove cookies from your browser. You have the ability to change the settings on your Internet browser to accept all cookies, to notify you when a cookie is set, or not to receive cookies at any time, although this may mean that some services on our websites cannot then be provided to you, or certain features may not function as a result.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our websites and you will prevent us from obtaining valuable analytics information that helps us improve the content and functionality of our websites, including the use of the online secure area of our websites. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.
For further information about cookies and how to adjust your browser settings, visit the following websites:
7. Other websites
You acknowledge and agree that by you accessing any linked website, we are not responsible or liable, either directly or indirectly, for:
- The privacy practices of such websites;
- The content of such websites;
- The use to which you or others make of these websites or resources (including any damage, loss or offence caused by, or in connection with, external websites and resources)
9. How to contact us
If you are unhappy with how we use your personal data then please contact our Data Protection Officer at:
By letter: The Data Protection Officer, Lowell Financial Ltd, Ellington House, 9 Savannah Way, Leeds LS10 1AB
By email: email@example.com
If you are not satisfied with our resolution of your concern then please contact the Information Commissioner’s Office on 0303 123 1113