Privacy Policy

 

www.fightthedebtco.uk is provided by Fight the Debt Ltd, company number 16491290, whose registered office address at 4 Diamond Terrace, London, England, SE10 8QN trading as Fight The Debt (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

This privacy policy is divided into the following sections:

• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UK and EEA
• Cookies and other tracking technologies
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
• Do you need extra help?

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. These other third party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third party websites, please consult their policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

• [your name, address and contact information, including email address and telephone number [and company details]]
• [any delivery addresses specified for your order]
• [information to check and verify your identity, eg date of birth]
• [your gender[, if you choose to give this to us]]
• [location data[, if you choose to give this to us]]
• [your billing information, transaction and payment card or other payment method information]
• [bank account and payment details]
• [details of any information, feedback or other matters you give to us by phone, email, post or via social media]
• [your account details, such as username and login details]
• [your activities on, and use of, our website]
• [your personal [or professional] interests]
• [your professional online presence, eg LinkedIn profile]
• [information about the services we provide to you]
• [your contact history, purchase history and saved items]
• [information about how you use our website and technology systems]
• [your responses to surveys, competitions and promotions]
• [insert other types as appropriate]

You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Providing [products AND/OR services] to you	To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us
Enforcing legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect our business, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: —your consent as gathered —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the [products AND/OR services] or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information
The audit of [insert details of audits or quality checks here or in a separate row as appropriate (to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above)]	For our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below.

Purpose	Processing operation	Lawful basis relied on under the UK GDPR and EU GDPR	Relevant categories of personal data
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices	Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018 —the EU GDPR	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	—your name, address and contact information, including email address and telephone number [and company details] —your account details (username)
	Addressing and sending communications to you	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	[Insert]
	Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)	Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you	—your name, address and contact information, including email address and telephone number [and company details] —your account details (username)
[Insert next purpose]	[Insert processing operations relating to purpose]	[Insert for each processing operation]	[Insert for each processing operation]

 

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us here
• using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside our group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

• third parties we use to help deliver our services to you
• other third parties we use to help us run our business, eg website hosts and website analytics providers
• [our bank[s]]

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

We will not share your personal data with any other third party.

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available from us.

If you stop using your account we will delete or anonymise your account data after [seven] years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK and EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

• our service providers located outside the UK, and
• [insert details of other recipients where relevant]

As we are based in the UK we will also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. We rely on adequacy decisions
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Transferring your personal data out of the UK and EEA—further information

If you would like further information about data transferred outside the UK/EEA, please contact [us OR our Data Protection Officer] (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies and similar technologies, eg web beacons, action tags, single-pixel gifs on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, our use of them, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We keep data encrypted.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• the Information Commissioner [in the UK]
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

Changes to this privacy policy

We may change this privacy policy from time to time.

How to contact us

Individuals in the UK

You can contact us  by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details
Fight The Debt Ltd 4 Diamond Terrace, London, SE10 8QN [email protected]

Individuals in the EEA

Individuals within the EEA can contact us direct (see above).

[Do you need extra help?]

[If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).]