Website User Notice

This website, www.lowell.co.uk, 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 set up an online account to manage your debt with us and make payments online.

Where we use “we”, “our” or “us” in this privacy notice, we mean Lowell Financial Ltd unless we say otherwise.  Where we use “our site” in this privacy notice, we mean www.lowell.co.uk.

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

Lowell Portfolio I Ltd buys customer debts 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 debts, which means that if we write or speak to you or if you use this website, it will usually be Lowell Financial Ltd that you are dealing with.

We also provide credit management solutions to your original creditor to help them manage the relationship that you have with them.

We collect the information you provide to us directly by filling in any of the forms including our budget calculator.

We also collect information directly from your device.  We use cookies to collect some of this information. Please see our Cookie Notice for details of the information we collect through our site.

Each time you visit our site, we may automatically collect information about you and the device you are using, including:

• information about which pages you visit and which resources you use on our site
• 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 page visits to our site
• location data
• time zone setting
• weblogs

We also collect any information you provide to us directly by filling in any of the forms on our site including our budget calculator.

If you set up an online account with us, we will also collect:

• your name
• your login information
• your Lowell reference number
• your date of birth
• your postcode
• your landline telephone number
• your mobile telephone number
• your email address

Please note that as a user of our website and online account functionality, 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 that someone else has accessed your account, please notify us immediately by contacting us.

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

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.

Please see our Cookie Notice for details of the cookies we use on our site.

We need the information we collect automatically about your visit to our site to:

• administer our site
• improve our site to ensure that content is presented in the most effective manner
• allow you to participate in interactive features of our services when you choose to do so
• analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices)
• improve your online experience
• measure and analyse our advertising
• remember pages you have been looking at so that we can tailor and enhance our advertising.

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

• allow you to manage your account online
• help you and us understand your ability to pay the amounts you owe
• allow you to make payments online.

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 relevant information, we will not be able to provide you with an online account and 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.

For more details about how we use the information you provide directly to us by filling in the forms on our site, please see our Customer Privacy Notice.

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

You are able to choose from the following methods to make payments on your accounts:

• debit card or Direct Debit
• Google Pay

To process these payments we share details about your payment with Worldpay as well as with Google (if you pay via Google Pay). We need to share your bank account information or debit card details, the amount and frequency of your payment and your Lowell reference number so that your payment can be collected and applied to the correct account.

We use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices).  Google Analytics doesn’t collect information that identifies a visitor to our site. All the information that is collected is anonymous and is only used to improve how our site works. We do not allow Google to make any attempt to establish the identities of any users of our site. Please see our Cookie Notice for more details about Google Analytics.

If you agree to our marketing cookies, we share the information they collect about you and your use of our site with our trusted social media, advertising and analytics partners - particularly Facebook and Instagram. This helps us to customise our social media ads and analyse traffic driven to our site from advertising and the effectiveness of our ads.  You can find more details about our marketing cookies in our Cookie Notice.

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 click to download the Snoop app, Snoop will use this link (provided by technology company AppsFlyer) to understand that you have accessed this from the Lowell.co.uk website. Only information on your device type is collected to ensure you automatically get to the right app store (Google Play / Apple App Store) to download the app. No personally identifiable information is collected through this link.

If you start our benefits calculator, Lowell receive a report from entitledto which provides information such as how many individuals have started and completed the calculator and how many might be eligible for additional financial support.

The report also provides details of the information entered into the calculator such as income (eg salary and existing benefits) and household (eg age, number of dependents, whether you rent or own a home).

The report is completely anonymous. It does not contain any personal information that allows us to identity you or your account with Lowell.

If you have an online account with us, 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 our Customer Privacy Notice and experian.co.uk/crain, www.equifax.co.uk/crain and www.TransUnion.co.uk/crain
• third party data providers to check that the information we hold about you is accurate and up to date
• if we become a member, with Cifas, a fraud prevention 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
• 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.

For more details about how we use the information you provide directly to us by filling in the forms on our site, please see our Customer Privacy Notice.

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.

Unfortunately sending information via the internet is not completely secure.  Although we do our best to protect your information, we cannot guarantee the security of any information you transmit to our site; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

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 notices and cookie notices and we do not accept any responsibility or liability for those notices or your use of those websites.

We only keep your information for as long as we need it, please refer to the Cookie Notice for more details.

If you have an online account with us 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 about how long we keep the information you provide directly to us by filling in the forms on our site, please see our Customer Privacy Notice.

We use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices), administer our site and manage your account.  Google Analytics doesn’t collect information that identifies a visitor to our site. All the information that is collected is anonymous and is only used to improve how our site works. We do not allow Google to make any attempt to establish the identities of any users of our site. Please see our Cookie Notice for more details about Google Analytics.

We use Facebook cookies to customise our social media ads - particularly on Facebook and Instagram – and to analyse traffic driven to our site from advertising and the effectiveness of our ads. You can find more details about Facebook cookies in our Cookie Notice

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

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 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 the information we hold about you and your account, please see our Customer Privacy Notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by letter at Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE.

If you have any questions, concerns or complaints about the way Lowell Financial Ltd processes your personal information, please contact our Data Protection Officer in the first instance by writing to Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE 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 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.

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