Introduction

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Privacy

We respect individuals' rights to privacy and to the protection of personal information. The purpose of this Privacy Policy is to explain how we collect and use personal information in connection with our business. 'Personal information' means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

We may update our Privacy Policy from time to time and when we do we will communicate any changes to you and publish the updated Privacy Policy on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.


Policy Contents

Privacy Policy (GDPR 2018)

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1. Who we are

1.1 This privacy policy (the 'Privacy Policy') applies to all personal information processing activities carried out by All About Debt Limited (AAD).

1.2 AAD is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this policy, references to 'we', 'us' or 'our' are references to AAD Consumer Forum.

1.3 Our company number is 08825488 and our registered address is Office 34 New House, 67-68 Hatton Garden, London, EC1N 8JY. Our contact details and address to request information can be located at all-about-debt.co.uk and further down the page of this policy.

1.4 We are registered with the DPA and our registration number is: Z3513615.

2. The information we process

2.1 We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this policy. Our members are responsible for posting their own content so you remain in control of all personal information at all times. Personal information may include:

a) basic personal information, including name and email address, date of birth and contact details;

b) financial information, including account and transactional information and history that you may upload to secure areas of the website;

c) information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details) where disclosed by you, on the forum or website;

d) information about your financial circumstances, including personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history and needs and goals;

e) education and employment information;

f) goods and services provided;

g) visual images and personal appearance (such as copies of identification or CCTV images); and

h) online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your forum profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online security authentication, mobile phone network information, searches, site visits and usage patterns.

2.2 We may also process certain special categories of information for specific and limited purposes, such as preventing crime or to make our services accessible to other members. We will only process special categories of information where we've obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out in Schedule A – Purposes of Processing (below), for which the information is provided). This may include:

a) information about racial or ethnic origin,

b) religious or philosophical beliefs;

c) trade union membership;

d) physical or psychological health details or medical conditions; and

e) information such as biometric information or others specifically relating to the physical, physiological or behavioural characteristics of a person, including, for example, using voice recognition or similar technologies to help you log in easier and to help us prevent fraud and other unlawful activities.

2.3 Where permitted by law, we may process information about you for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with relevant laws. This may involve sharing data with law enforcement and regulatory bodies.

3. How we obtain information

3.1 Your information is made up of any financial and personal information that you provide, and that we then subsequently collect and hold about you. Such information may includes:

a) information you give to us;

b) information that we receive from third parties - including other AAD businesses, third parties who provide services to you or us, credit reference, fraud prevention or government agencies (where provided by you), and other sources (where permitted by law);

c) information that we learn about you through our relationship with you and the way you operate your membership and / or services, such as the information you post, upload and interact with as well as account usage;

d) information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and

e) information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines (where permitted by law and permission granted by you).

4. Your rights

4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.

If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection Officer, please contact us at dpa@all-about-debt.co.uk. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and / or provide forum posting services to you.

Table A – Your Rights

Your Rights Description
Access

You have a right to get access to the personal information we hold about you.

If you would like a copy of the personal information we hold about you, please get in touch with us via our Secure Online Contact form or write to us at: All About Debt Limited, Office 34 New House, 67-68 Hatton Garden, London, EC1N 8JY.

Rectification

You have a right to rectification of inaccurate personal information and to update incomplete personal information.

If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.

If you would like to request that we rectify inaccurate personal information, please let us know by sending us a Secure Message.

Right to be forgotten

You have a right to request that we delete your personal information.

You may request that we delete your personal information if you believe that:

• we no longer need to process your information for the purposes for which it was provided;

• we have requested your permission to process your personal information and you wish to withdraw your consent; or

• we are not using your information in a lawful manner.

If you would like to request that we delete your account and personal information, please let us know by updating your preferences via the Privacy Preferences page.

Please note that if you request that we delete your information, we may have to suspend the operation of your account and / or restrict the forum posting services we provide to you.

Restriction

You have a right to request that we restrict the processing of your personal information.

You may request that we restrict processing your personal information if you believe that:

• any of the information that we hold about you is inaccurate;

• we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or

• we are not using your information in a lawful manner.

If you would like to request that we restrict processing your personal information, please let us know by updating your preferences via the Privacy Preferences page.

Please note that if you request that we restrict processing your information, we may have to suspend the operation of your account and / or restrict the forum posting services we provide to you.

Portability

You have a right to data portability.

Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format.

You may also request that we provide the information directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your personal information, which will be governed by their agreement with you and any privacy statement they provide to you.

If you would like to request the personal information you provided to us in a portable format, please get in touch with us via our Secure Online Contact form.

Objection

You have a right to object to the processing of your personal information.

You have a right to object to us processing your personal information (and to request that we restrict processing) for the purposes described in Section C of Schedule A – Purposes of Processing (below), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims.

Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information.

If you would like to request that we stop processing your personal information, please let us know by updating your preferences via the Privacy Preferences page.

Please note that if you object to us processing your information, we may have to suspend the operation of your account and / or restrict the forum posting services we provide to you.

Marketing

You have a right to object to direct marketing.

You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing.

For more information see the section entitled Marketing information below.

Withdraw consent

You have a right to withdraw your consent.

Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.

If you would like to withdraw your consent and request that we stop processing your personal information, please let us know by updating your preferences via the Privacy Preferences page.

Please note that if you do withdraw consent and object to us processing your information, we may have to suspend the operation of your account and / or restrict the forum posting services we provide to you.

Lodge a complaint

You have a right to lodge a complaint with the regulator.

If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer at dpa@all-about-debt.co.uk who will investigate the matter.

We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO) if you feel we aren't. For more information, visit the ico.org.uk.

5. Changes to the way we use your information

5.1 From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and / or provide forum posting services to you.

6. How we use your information internally

6.1 We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other AAD companies only.

6.2 We want to ensure that you fully understand how your information may be used so we have described the purposes for which your information may be used in detail in the table below - Schedule A – Purposes of Processing.

7. How we use your information externally

7.1 We will not share your information with anyone outside AAD (third parties) except:

a) where we have your permission;

b) where required to service and provide access, your account and relevant services;

c) where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;

d) with third parties providing services to us, such as market analysis and benchmarking, web development and sub-contractors acting on our behalf for instance the company who provides our web hosting and general site maintenance;

e) where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and / or assets held by our business;

f) in anonymised form as part of statistics or other aggregated data shared with third parties; or

g) where permitted by law, it is necessary for our legitimate interests.

7.2 If you ask us to, we will share information with any third party that provides you with account information or payment services. If you ask a third-party provider to provide you with account information or payment services, you’re allowing that third party to access information relating to your account. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

7.3 In the event that any additional authorised users are added to your account, we may share information about the use of the account by any authorised user with all other authorised users.

7.4 In the event that you link your assets and liabilities with your immediate family under a Fee Family, the sum of the combined assets and liabilities held within the Fee Family may be shared with other members of the Fee Family. In some instances this may allow other members of the Fee Family to calculate the combined assets and liabilities you hold with us.

7.5 AAD will not share your information with third parties for their own marketing purposes without your permission.

8. Transferring information overseas

8.1 We may transfer your information to organisations in other countries (including to other AAD group companies) on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

8.2 In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:

a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;

b) the transfer has been authorised by the relevant data protection authority; and/or

c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us: dpa@all-about-debt.co.uk.

9. Marketing information

9.1 Unless you have told us that you do not want to hear from us, we will send you relevant marketing information (including details of other products or services provided by us or other AAD group companies which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication.

9.2 If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by sending us a secure message or by updating your Privacy Preferences.

10. Communications about your account

10.1 We will contact you with information relevant to the operation and maintenance of your account (including updated information about how we process your personal information), by a variety of means including via online messaging, email messages and text message / telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.

10.2 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing (below).

11. How long we keep your information

11.1 By providing you with access to our forum, and an account, we create records that contain your information, such as customer access records, activity records, personal records (sych as your uploads and messages etc). Records can be held on a variety of media (physical or electronic) and formats.

11.2 We manage our records to help us to provide a better all round service and platform to our members (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records also help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.

11.3 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant member is located and the applicable local legal or regulatory requirements. We (and other AAD group companies) normally keep customer account records for up to six years after your relationship with us ends, whilst other records are retained for shorter periods, for example 60 days for emails and other online communication records. Retention periods may be changed from time to time based on business or legal and regulatory requirements.

11.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they’re needed.

11.5 If you would like more information about how long we keep your information, please get in touch via our Secure Online Contact form.

12. Security

12.1 We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please get in touch via our Secure Online Contact form.

13. Complaints & DPA officer

13.1 In the unlikely event that you should have cause for complaint, we ask that you first raise the matter directly using our Secure Online Contact form, giving sufficient information and outlining the grounds for complaint. An initial response to any complaint can be expected within 3 days and a full and considered response to the complaint should be completed within 7 days and any subsequent remedy implemented with the minimum of delay.

13.2 You can get in touch with our Data Protection Officer by sending an email to: dpa@all-about-debt.co.uk.

Schedule A – Purposes of Processing

We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other AAD group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in the tables shown below:


A – Contractual Necessity

We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and / or provide forum posting services to you. This may include processing to:

a) assess and process applications for membership, subscriptions, products or services;

b) provide and administer those products, memberships and services throughout your relationship with us, including opening, setting up or closing your account; collecting and issuing all necessary documentation; executing your instructions; processing transactions, including your posts, topics, uploads into any private sections on the forum, private messaging and email services; resolving any queries or discrepancies and administering any changes. Calls and communications to our mobile and online helplines may be recorded and monitored for these purposes.

c) manage and maintain our relationship with you and for ongoing customer service. This may involve sharing your information with other AAD group companies to improve the availability of our services, for example enabling members to have more say in how we do things;

d) administer any posting, uploads, image and account settings, including agreeing to provide free help and support debt & legal options; and

e) communicate with you about your membership or the products and services you receive from us.


B – Legal Obligation

When you open a new account, upgrade your membership, apply for a new product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and / or provide membership and related services to you. This may include processing to:

a) confirm your identity, including using login passwords, social linking, biometric information and voice-recognition technology and other identification procedures, for example fingerprint verification on your mobile device;

b) perform checks and monitor member transactions, posting style and location data for the purpose of preventing and detecting crime and to comply with law and regulatory licencing;

c) share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity and complying with production and court orders;

d) deliver mandatory communications to customers or communicating updates to our membership and service terms and conditions;

e) investigate and resolve complaints;

f) conduct investigations into breaches of conduct and corporate policies by our employees;

g) manage contentious regulatory matters, investigations and litigation;

h) perform assessments and analyse customer data for the purposes of managing, improving and fixing data quality;

i) provide assurance that we have effective processes to identify, manage, monitor and report the risk it is or might be exposed to; and

j) monitor members and their account dealings to prevent abuse.


C – Legitimate Interests

We may process your information where it is in our legitimate interests do so as an organisation and without prejudicing your interests or fundamental rights and freedoms.

a) We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:

• monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;

• ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;

• ensure network and information security, including monitoring authorised users' access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our telecommunications systems and websites, prevention or detection of crime and protection of your personal data;

• perform general, financial and regulatory accounting and reporting;

• protect our legal rights and interests; and

• enable a sale, reorganisation, transfer or other transaction relating to our business.

b) It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:

• identify new member opportunities and to develop enquiries and leads into new member applications and to develop our relationship with you;

• send you relevant marketing information (including details of other products or services provided by us which we believe may be of interest to you;

• understand our members actions, behaviour, preferences, expectations, feedback and financial background in order to provide a service and to improve our knowledge of the financial industry;

• monitor the performance and effectiveness of members, usage, our products and services;

• perform analysis on member complaints for the purposes of preventing errors and process failures and rectifying negative impacts on members;

• identify our members use of third-party products and services in order to facilitate the uses of member and their information detailed above; and

• combine your information with third-party data, such as economic data in order to understand member needs better and improve our services.

c) It is in our interest as a business to manage our risk and to determine what products and services we can offer and the terms of those products and services. It is also in our interest to protect our business by preventing spamming, fraud and general online crime. This may include processing your information to:

• carry out generic and insurance risk assessments;

• manage and take decisions about your membership and account;

• carry out checks (in addition to statutory requirements) on members and potential members, business partners and associated persons, including performing adverse media checks, screening against external databases and sanctions lists and establishing connections to politically exposed persons;

• share data with law enforcement agencies where required;

• for risk reporting and risk management.



Policy Updated: May 2018

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If you'd like to discuss this policy or query anything in it, please send us a message using our Online Contact Form or contact us using the details below:


dpa@all-about-debt.co.uk

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