HOW WE USE YOUR DATA

This privacy policy outlines how Lowell Portfolio l Limited and Lowell Financial Ltd will use, store and share your personal data and supplements any fair processing notice provided to you.

We will use your personal data fairly and lawfully and in accordance with the Data Protection Act 1998 (“the Act”). For the purposes of the Act, we (Lowell Portfolio l Limited and Lowell Financial Ltd) are both data controllers.

PERSONAL DATA WE MAY COLLECT AND USE

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 that we have purchased your account from, 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 use a third party service, Google Analytics, to collect your reference number, other non-personally identifiable information that you enter and details of your behaviour patterns, including the tracking of visits across multiple devices. Google’s remarketing and advertising reporting has been enabled to provide additional information for the analysis of visitor characteristics and behaviour. 

We do this to help us analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account.  We do not allow Google to make any attempt to establish the identities of any users of our website. 

To find out more about how these cookies are used and to opt-out of being tracked, please see our “Cookies” section below.

We collect limited sensitive personal data as required by the Financial Conduct Authority (“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.

USES MADE OF YOUR PERSONAL DATA

Lowell Portfolio l Limited will own any data purchased from its clients but Lowell Financial Ltd will process this data in accordance with this privacy policy.

Lowell Financial Ltd may use personal data held about you in the following ways:

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:

By letter: The Data Protection Officer, Lowell Financial Ltd, Ellington House, 9 Savannah Way, Leeds LS10 1AB.

By email: enquiries@lowellgroup.co.uk

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, and 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 your last account 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”.

Lowell Financial Ltd may also share your personal data with certain third parties as follows:

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.

We may share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of Lowell Portfolio I Limited or Lowell Financial Limited, our clients, our employees agents and subcontractors or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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 FCA 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 for debt collection purposes only.  Any sharing of your sensitive personal data with clients 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 or stored anywhere outside of the European Economic Area (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.

COOKIES

“Cookies” are small pieces of information sent by a web server (such as that used to run this website) to your computer, which are then stored on the computer’s hard drive. Although cookies contain identifying information, except where we mention that we collect your reference number below via Google Analytics, they do not contain any information that identifies you personally, but they allow us to recognise you when you return to our website

We do not use persistent cookies i.e. those that are pushed out to a user’s machine and stored. This website uses Session Cookies. These are temporary cookies, which only exist in the period you access the website (or more strictly, until you close the browser after accessing the website). Session cookies help the website remember what you chose on the previous page, therefore avoiding the need to re-enter information and improve your experience whilst using the site. These cookies do not contain personal information and cannot be used to identify you.

We also use cookies to help us improve our service to you. For example, we use Google Analytics, a popular web analytics service provided by Google. Google Analytics uses cookies to help us to analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account. The cookies collect your IP address, your Lowell reference number and certain non-personally identifiable information that you enter.  Google’s remarketing and advertising reporting has been enabled to provide additional information for the analysis of visitor characteristics and behaviour. Find out more about how these cookies are used on the Google Privacy site.

You can change your browser settings so that cookies are not accepted. If you do this, you may lose some of the functionality of this website, including the use of the secure area of the website.

For further information about cookies and how to disable them please go to: www.aboutcookies.org.

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.

OTHER WEBSITES

Our site may, from time to time, contain links to and from the websites of third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites. 

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this policy from time to time and if we do we will bring the new terms to your attention when you visit the website.

COMPLAINTS AND ACCESS TO PERSONAL DATA

The Act gives you the right to access personal data held about you.  If you would like to access this personal data, are unhappy with how we use your personal data then please contact our Data Protection Officer:

By letter: The Data Protection Officer, Lowell Financial Ltd, Ellington House, 9 Savannah Way, Leeds LS10 1AB.

By email: enquiries@lowellgroup.co.uk

If you are not satisfied with our resolution of your concern then please contact the Information Commissioner’s Office on 0303 123 1113. 

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

By letter: The Data Protection Officer, Lowell Financial Ltd, Ellington House, 9 Savannah Way, Leeds LS10 1AB.

By email: enquiries@lowellgroup.co.uk