Mobile App Privacy Notice

This app is operated by Lowell Financial Ltd:

• to provide you with information about being a Lowell customer and what it means for you and
• so that you can use it to manage your account with us and make payments.

Where we use “we”, “our” or “us” in this privacy notice, we mean Lowell Financial Ltd unless we say otherwise.  Where we use “this app”, we mean the Lowell mobile app.

Lowell Financial Ltd is part of the Lowell group of companies.  We manage customer accounts on behalf of Lowell Portfolio I Ltd which is another company in the Lowell group.

Lowell Portfolio I Ltd buys 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.

Lowell Financial Ltd manages the accounts, which means that if we write or speak to you or if you use this app, it will usually be Lowell Financial Ltd that you are dealing with.

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

We collect the information you provide directly to us in this app including by filling in our budget calculator.

If you start to fill in our budget calculator but don’t get all the way through, the details you input will be stored on your device for up to 60 days to give you time to finish it.  Your information will not be shared with Lowell until you reach the budget summary.

We also collect information directly from your device.  Please see the section What Information do we collect about you? below for more details.

When you download this app, to set up your account we collect your:

• name
• date of birth
• your Lowell reference number
• postcode
• landline telephone number
• mobile telephone number
• email address
• login information (including a password)

As a user of this app, you are responsible for keeping your login information including your password confidential.  If you believe that your login information or password has been compromised or someone else has accessed your account, please get in touch and let us know.

We collect any information you provide directly to us in this app, for example if you update your contact details or if you set up a payment plan or make a one-off payment.

If you use our budget calculator, we will collect information about your income and expenditure and your ability to pay the amounts you owe.

For more details about how we use the information you provide directly in this app, please see our Customer Privacy Notice.

We also collect information about you and the device you are using, including:

• which feature of this app you use
• your internet protocol address known as your IP address which is used to connect your device to the internet
• your device’s operating system and platform
• the type and version of the browser you are using
• browser plug-in types and versions
• MAC addresses
• traffic data, which is aggregated information about the number of visitors, sessions, users and visits to this app
• location data
• time zone setting
• weblogs

We may also combine the information you give us and the information we collect about you with information that we receive from other sources, such as the previous owner of your account.

We need the information we collect automatically about your use of this app to:

• operate this app
• improve our app to ensure that content is presented in the most effective manner
• allow you to use the interactive features of this app when you choose to do so
• analyse how users use this app (including behaviour patterns and the tracking of visits across multiple devices)
• improve your user experience.

We have a legitimate interest in providing this app to you to manage your account and in understanding how you use it and how we can improve it for you.

We need the information you provide directly to us including by filling in any of the forms to:

• allow you to use this app to manage your account
• help you and us understand your ability to pay the amounts you owe
• allow you to make payments through this app.

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.

You do not have to give us any information or confirm that the information we have obtained from other sources is correct.

If you don’t provide us with your information, you may not be able to use this app to manage your account.  We may also 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.

For more details about why we need the information you provide directly to us in this app and how we use it, please see our Customer Privacy Notice.

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

We use Worldpay to securely process payments to your account. We will share the details about your payment, including your bank account information or debit card details, the amount and frequency of your payment and your Lowell reference number with Worldpay so that Worldpay can collect your payment and we can apply it to the correct account. Worldpay’s privacy notice is available at www.fisglobal.com/en-gb/privacy.

We use Google and Firebase Analytics to collect information about how our customers use this app, as well as anonymous data that you enter into our forms.  We use the information to understand how our customers use this app (including behaviour patterns and the tracking of visits across multiple devices).  Google and Firebase Analytics don’t collect information that identifies a user of our app. All the information that is collected is anonymous and is only used to improve how this app works. We do not allow Google to make any attempt to establish the identities of any users of this app.

We use Dynatrace to help us monitor the performance of our app to ensure you get the possible service.  We also use Dynatrace to provide us with notifications when your app crashes or doesn’t work as expected.  This allows us to resolve any technical problems quickly and with minimal disruption. Dynatrace does not receive any data that can be used to identify you.  You can choose whether or not to share this data with Dynatrace and you can change your mind at any time by changing your settings in the app.

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

If you use this app to manage your account, we share:

• 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 our Customer Privacy Notice and experian.co.uk/crain, www.equifax.co.uk/crain and www.TransUnion.co.uk/crain
• if you agree to our use of marketing tags, we share the information they collect about you and your use of this app with our trusted social media, advertising and analytics partners - particularly Facebook and Instagram. This helps us to customise our social media messages and analyse use of this app and the effectiveness of our messages.
• information with third party data providers to check that the information we hold about you is accurate and up to date
• information with the police and other law enforcement agencies, if fraud, money laundering or any other crime is detected
• 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.

If we become a member of a fraud prevention agency, we will share information with that agency 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 more details about who we share the information you provide directly to us in this app with, please see our Customer Privacy Notice.

The following information is stored on your device:

• biometric data, such as your fingerprint or face if you use it to verify your identity and access this app
• log-in tokens which verify your identity
• the content of forms you’ve started to fill out but haven’t yet completed (this will be deleted after 60 days)

We will not collect or access this data.

The information that we do collect about you 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 Standard Contractual Clauses or binding corporate rules, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

We only keep your information for as long as we need it.

If you use this app, we will keep the information we collect for no more than 7 years from the date your account with us is closed.  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
• bring or defend any legal claims and
• comply with our professional, legal and regulatory obligations.

Our retention schedule considers the different types of information that we hold about you, why we need it and how long we need it for.  We agree not to keep it for any longer than we need it as set out in that retention schedule.

We use Google and Firebase Analytics to collect information about how our customers use this app, as well as anonymous data that you enter into our forms.  We use the information to understand how our customers use this app (including behaviour patterns and the tracking of visits across multiple devices).  Google and Firebase Analytics don’t collect information that identifies a user of our app. All the information that is collected is anonymous and is only used to improve how this app works. We do not allow Google to make any attempt to establish the identities of any users of this app.

We do not carry out any other profiling or automated decision-making in respect of the information we automatically collect about you when you use this app.

For more details about the profiling and automated decision-making we carry out in respect of the information we hold about you and your account, please see our Customer Privacy Notice.

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

• access the information which we hold about you
• 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 the information we hold about you, please see our Customer Privacy Notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by:

• email to dpo@lowellgroup.co.uk
• letter to Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE.

You can uninstall the app at any time.  This will remove this app from your phone but it will not delete your profile, so you can re-install this app at any time.

You can also de-register at any time.  This means that your profile will be deleted.  We will still keep all your personal data to manage your accounts.  Please see the section How long do we keep your information for? for more details.

If you have any questions, concerns or complaints about the way we process your personal information, please contact our Data Protection Officer in the first instance by

• email to dpo@lowellgroup.co.uk
• letter to Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE and they will do their very best to help you.

If you are not happy with the way we have handled your complaint or are still concerned about our handling 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.

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.

This notice was last reviewed and updated in May 2021.