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Customer Privacy Notice

Lowell are committed to protecting your privacy and that’s why we have designed this website to make it easy for you to get all the information you need. See below to find out how we use your personal information, who we may share it with and how we protect it, as well as finding out about your rights and how to exercise them or see our detailed customer privacy notice for more information.

Click here to see our detailed customer privacy notice. 

If you would like a copy of our detailed privacy notice or if you have any questions about how either Lowell Portfolio I Ltd or Lowell Financial Ltd use and share your personal information, please contact our Data Protection Officer by:

  • writing to Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ.
  • by email at dpo@lowellgroup.co.uk

If you would like to hear a recording of our customer privacy notice, please call 0800 0212075.

Calls to this number is free from landlines. Charges from mobile networks may vary so please check with your provider before calling.

How we use our customers' personal data
Changes to this notice

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date.

Any changes to this notice will be highlighted so that you can see what has been changed.  

Where we have made a significant change to the information contained in this notice, we will let you know either by email if we have an email address for you or in the next letter that we send you.

This notice was last reviewed and updated in May 2018.

What information do we collect about you?

We collect:

  • your name
  • your contact details (including your current and previous addresses, telephone numbers and e-mail addresses)
  • your gender
  • your date of birth
  • details about your account with us 
  • financial information about you including your credit score, credit history and payment history, credit reference information, income and expenditure and any other details relating to your account with us and your ability to pay the amounts you owe and
    recordings of our calls with you.

We will regularly check your credit file to ensure the information that we hold about you on our systems is accurate, complete and up to date. This check is called a ‘soft search’ and may leave what is known as a “soft footprint”. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

Where you provide us with information about your family, lifestyle and social circumstances, employment status and your work history, we may record and use this information where it affects your account with us.

Where it has or may have an impact on your ability to pay the amounts you owe, we may collect information about your mental and physical health. For more details about how we use this information, please see the section Special categories of personal data in our full privacy notice.
 

We may also collect some limited information, including publicly accessible information such as media reports, about any current criminal convictions you have if we have reason to believe that you may be in prison. We will use this for the purposes of updating the information we hold about you and managing your account. We may also use this information for the purposes of crime and fraud prevention and for complying with our obligations under the anti-money laundering and counter-terrorist financing legislation. Please see the section Information relating to criminal convictions in our full privacy notice for more details.
 

We may also collect publicly accessible information about you, for example through a Google search, where we have been unable to contact you using the contact details that we hold for you.
 

If you use our websites, including registering for an online account, please see our Website User privacy notice and our Cookie notice for details of the information we collect through our websites.
 

For more details about what information we collect about you, please see the section What information do we collect about you? in our full privacy notice.

Who are the Lowell group?

The Lowell group is made up of the following companies incorporated in the UK

 

Lowell Finance Ltd Company number 05069513
Lowell Portfolio I Ltd Company number 04857418
Lowell Financial Ltd Company number 04558936
Lowell Solicitors Limited Company number 08647091
Fredrickson International Limited Company number 02679522
Lowell Receivables Financing 1 Limited Company number 11344999
Interlaken Group Limited Company number 03167536
SRJ Debt Recoveries Limited Company number 05064551
Tocatto Ltd Company number 05069843
Lowell Portfolio III Holdings Limited Company number 08336897
Lowell Portfolio III Limited Company number 08096778
Lowell Portfolio IV Holdings Limited Company number 08647094
Lowell Portfolio IV Limited Company number 08654105
Who are we?

Lowell are a group of companies which includes Lowell Portfolio I Ltd and Lowell Financial Ltd. Where we use “we”, “our” or “us” in this privacy notice, we mean both Lowell Portfolio I Ltd and Lowell Financial Ltd unless we say otherwise.


We buy customer accounts where there is an outstanding balance from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.


If you are a Lowell customer, this means that Lowell has bought your account and we will work with you to arrange repayment of the outstanding balance.


Lowell Portfolio I Ltd buys your account and Lowell Financial Ltd manages your account on behalf of Lowell Portfolio I Ltd. This means that if we write or speak to you, it will usually be Lowell Financial Ltd that you are dealing with.


Company

Lowell Portfolio I Ltd 

Lowell Financial Ltd

Company number

Company number 04857418 

Company number 04558936

Country 

Incorporated in the UK

Incorporated in the UK

Registered office

Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds LS10 1AB

Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds LS10 1AB

 

We are joint controllers of your information which means that we are both responsible for looking after it.

We also provide credit management solutions to other companies to help them manage the accounts that you have with them.

For details of the UK companies in the Lowell group, please see the section Who are the Lowell group below.

Why do we need your information?

We need your information to manage your account and collect the debt that you owe. This includes using your information to locate you, check your identity and confirm the information that we hold about you is correct.

As we have bought your account, we have a legitimate interest in collecting the amounts that you owe under the agreements that you have entered into.

We also use your information to:
  • understand how you manage your account and the likelihood that you will repay the amounts you owe
  • understand our customers’ behaviour and how you use our services
  • help us to develop and improve our products and services and
  • provide credit management solutions to companies to help them manage their customer accounts with you.
We have a legitimate interest in understanding how our customers’ manage their accounts and how they use our services so that we can continually develop and improve our services to provide you with the best customer experience possible.

We may also use your information to comply with our legal and regulatory obligations, for example:
  • the Financial Conduct Authority requires us to understand whether our customers may be vulnerable (including as a result of any physical or mental health conditions you may have) which may mean that you need additional support from us to manage your accounts and
  • to comply with our obligations under the anti-money laundering, counter-terrorist financing and other legislation and for crime and fraud prevention
We process and share your personal data with Cifas and other fraud prevention agencies on the basis that we have a legitimate interest in preventing fraud and money laundering and to verify your identity in order to protect our business and to comply with laws that apply to us.
Please see the sections Why do we need your information, Special categories of personal data and Information relating to criminal convictions in our full privacy notice for more details.

If you use our websites, please see our Website User privacy notice and our Cookie notice for details of how we use the information we collect through our websites.

We may use your information to contact you for market research purposes to improve our customer service.

You do not have to give us any information or confirm that the information we have obtained from the third parties detailed in Where do we get your information from? is correct.

If you don’t provide us with relevant information, we may not be able to manage your account in the way that is best for you or agree a payment plan which is tailored to your needs. The more we understand about your personal circumstances, the better equipped we are to offer suitable and affordable repayment plans and to provide you with any additional support you may need.
Where is your information stored?

Your information is generally stored on servers and filing systems in the UK but from time to time it may be stored in or accessed from countries outside the UK. Where this may happen, we always make sure that there are appropriate safeguards in place, such as the model contract clauses, binding corporate rules or the EU-US Privacy Shield, to guarantee that your information – and your rights – are protected to the same high standard as under UK law. 

For more details, please see the Where is your information stored? section of our full privacy notice.
How long do we keep your information for?

We only keep your information for as long as we need it and we will keep your information for no more than 7 years from the date you cease to have any active accounts with us.  

We keep your information for this long so that we can:
  • deal with any issues or concerns that you may have about how we handled your account
  • to answer any questions HM Revenue and Customs may have and
  • bring or defend any legal claims.

However, we won’t keep all of your information for so long, and we will delete some information much sooner. 

For more details, please see the How long do we keep your information? section of our full privacy notice.
Do we carry out profiling and automated decision-making?

We use the information we hold about you to calculate a score on the basis of a mathematical model to predict how likely you are to pay your balance or respond to any type of communication.  This is known as profiling which means that we use our computer systems to help us predict this information about you. This helps us to decide what is likely to be the best way for us to work with you to manage your account.

If you do not repay the amounts you owe us, we may make automated decisions about whether or not to take legal action against you and about what type of action we may take to enforce our legal rights to collect those amounts from you.

For more details about how we use your information for profiling, the automated decisions that we make, the consequences of those decisions for you and your rights in respect of profiling and automated decision-making, please see the section Do we carry out profiling and automated decision-making? in our full privacy notice.

What rights do you have?

Under the data protection rules, you have a number of rights in respect of your information, which include the right to:

  • access your information
  • ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
  • delete or erase your information (sometimes called the right to be forgotten)
  • stop or restrict our processing of your information
  • object to our processing your information
  • not be subject to automated decision-making and
  • request the transfer of some of the information we hold about you (known as data portability).

 
Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use your information, please see the What rights do you have? section of our full privacy notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by writing to Data Protection Officer, Lowell Financial Ltd, PO Box 1411, Northampton, NN2 1BQ.

 
Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, query or request relates to, please contact our Data Protection Officer using these contact details.

What if you have a complaint?

If you have any questions, concerns or complaints about the way either Lowell Portfolio I Ltd or Lowell Financial Ltd process your personal information, please contact our Data Protection Officer in the first instance by writing to Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ and they will do their very best to help you.

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, concern or complaint relates to, please contact our Data Protection Officer using these contact details.

If you are not happy with the way we have handled your complaint or are still concerned about our handing of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

Who do we share your information with?

We sometimes need to share some of your information with other organisations.

We may share information with third party debt collection agencies and third party law firms if we instruct them to act on our behalf in connection with your account.

We share information about you, including information about the payments you make, any payments you miss and details of any defaults with credit reference agencies. For more details about the information that we share with credit reference agencies, please see the Who do we share your information with? section of our full privacy notice and www.experian.co.uk/crain, www.equifax.co.uk/crain and www.TransUnion.co.uk/crain.

We also share your information with third party data providers to check that the information we hold about you is accurate and up to date.

We may become a member of Cifas, which is a fraud prevention agency. If we do, we will share the information we hold about you with Cifas and other fraud prevention agencies to prevent fraud and money laundering and to verify your identity. If fraud is detected, you may be refused certain services, finance or employment. For further details, please see the Who do we share your information with? section of our full privacy notice.

If fraud, money laundering or any other crime is detected, we may share information with the police and other law enforcement agencies.

We may also share some limited information, including call recordings for quality assurance purposes, with the previous owner of your account.

We use a number of carefully selected third parties to supply us with other products and services, such as IT and mailing services. We will only share your information with our suppliers where it is necessary for them to provide us with the services we need.

We may also share your information with our insurers, legal and other professional advisers where necessary.

We may share your information with the other companies in the Lowell group:
  • if we instruct them to collect the amount that you owe on our behalf 
  • if we instruct them to act on our behalf to recover the amount that you owe, to take legal action against you and to enforce any judgments that we may have against you 
    if we provide credit management solutions to help them manage the accounts you have with them and
  • including any company associated or otherwise connected with the Lowell group if we transfer your debt to them whether as part of a group reorganisation or otherwise.  If we transfer your debt to another member of the Lowell group, Lowell Financial Ltd will continue to manage your account on behalf of the new owner of your debt and your personal data will continue to be used and shared as set out in this privacy notice.
For details of the UK companies in the Lowell group, please see the section Who are the Lowell group below.

If we or any member of the Lowell group of companies merges, transfers or sells part or all of its business or assets or any of the share capital of Lowell Portfolio I Ltd or Lowell Financial Ltd to a third party, your personal information may be disclosed to that third party and its advisers for the purposes of negotiating and completing the merger, transfer or sale. If the merger, transfer or sale does complete, that third party may use or disclose your information as set out in this privacy notice.

If we provide credit management solutions to companies to help them manage the accounts that you have with them, we will confirm and verify the information that they provide to us is accurate, complete and up to date. We may also share information such as your contact details and information about how you manage your account with us in order to help our clients manage the accounts you have with them.

We may also share your information with third parties who carry out market research on our behalf to help us improve our customer service.

For more details about who we share your information with, please see the Who do we share your information with? section of our full privacy notice.
Where do we get your information from?

We collect some information directly from you, for example the information you give us when we speak to you on the phone or which you send to us by email or by letter or by using our websites.

If you use our websites, please see our Website User privacy notice and our Cookie notice for details of the information we collect through our websites.

We also obtain information from the previous owner of your account, credit reference agencies and third party data providers.

We will regularly check your credit file to ensure the information that we hold about you on our systems is accurate, complete and up to date. This check is called a ‘soft search’ and may leave what is known as a “soft footprint”. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

For more details about the information that we receive from credit reference agencies, please see the Where do we get your information from? section of our full privacy notice and www.experian.co.uk/crain, www.equifax.co.uk/crain and www.TransUnion.co.uk/crain.

We may become a member of Cifas, which is a fraud prevention agency. If we do, we will collect personal information about you from Cifas and other fraud prevention agencies (and share our information with them) for the purposes of preventing fraud and money laundering and to verify your identity. For further details, please see the section Who do we share your information with? below and the Where do we get your information from? section of our full privacy notice.

If we provide credit management solutions to other companies to help them manage the accounts that you have with them, they will provide information about you for us to confirm and verify that it is accurate and up to date.

We may monitor and/or record phone calls between our staff and you to resolve issues on your account, for training purposes and to improve our quality and service standards.

We may also combine the information we receive from other sources with the information that you give us and the information we collect about you.