Privacy

We respect individuals' rights to privacy and to the protection of personal information. The purpose of this Privacy Policy is to explain how we collect and use personal information in connection with our business. 'Personal information' means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

We may update our Privacy Policy from time to time and when we do we will communicate any changes to you and publish the updated Privacy Policy on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

Policy Contents

1. Who we are

1.1 This privacy policy (the 'Privacy Policy') applies to all personal information processing activities carried out by All About Debt Limited (AAD).

1.2 AAD is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this policy, references to 'we', 'us' or 'our' are references to AAD Consumer Forum.

1.3 Our company number is 08825488 and our registered address is Office 34 New House, 67-68 Hatton Garden, London, EC1N 8JY. Our contact details and address to request information can be located at all-about-debt.co.uk and further down the page of this policy.

1.4 We are registered with the DPA and our registration number is: Z3513615.

2. The information we process

2.1 We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this policy. Our members are responsible for posting their own content so you remain in control of all personal information at all times. Personal information may include:

a) basic personal information, including name and email address, date of birth and contact details;

b) financial information, including account and transactional information and history that you may upload to secure areas of the website;

c) information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details) where disclosed by you, on the forum or website;

d) information about your financial circumstances, including personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history and needs and goals;

e) education and employment information;

f) goods and services provided;

g) visual images and personal appearance (such as copies of identification or CCTV images); and

h) online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your forum profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online security authentication, mobile phone network information, searches, site visits and usage patterns.

2.2 We may also process certain special categories of information for specific and limited purposes, such as preventing crime or to make our services accessible to other members. We will only process special categories of information where we've obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out in Schedule A – Purposes of Processing (below), for which the information is provided). This may include:

a) information about racial or ethnic origin,

b) religious or philosophical beliefs;

c) trade union membership;

d) physical or psychological health details or medical conditions; and

e) information such as biometric information or others specifically relating to the physical, physiological or behavioural characteristics of a person, including, for example, using voice recognition or similar technologies to help you log in easier and to help us prevent fraud and other unlawful activities.

2.3 Where permitted by law, we may process information about you for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with relevant laws. This may involve sharing data with law enforcement and regulatory bodies.

3. How we obtain information

3.1 Your information is made up of any financial and personal information that you provide, and that we then subsequently collect and hold about you. Such information may includes:

a) information you give to us;

b) information that we receive from third parties - including other AAD businesses, third parties who provide services to you or us, credit reference, fraud prevention or government agencies (where provided by you), and other sources (where permitted by law);

c) information that we learn about you through our relationship with you and the way you operate your membership and / or services, such as the information you post, upload and interact with as well as account usage;

d) information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and

e) information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines (where permitted by law and permission granted by you).

4. Your rights

4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.

If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection Officer, please contact us at dpa@all-about-debt.co.uk. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and / or provide forum posting services to you.

Table A – Your Rights

5. Changes to the way we use your information

5.1 From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and / or provide forum posting services to you.

6. How we use your information internally

6.1 We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other AAD companies only.

6.2 We want to ensure that you fully understand how your information may be used so we have described the purposes for which your information may be used in detail in the table below - Schedule A – Purposes of Processing.

7. How we use your information externally

7.1 We will not share your information with anyone outside AAD (third parties) except:

a) where we have your permission;

b) where required to service and provide access, your account and relevant services;

c) where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;

d) with third parties providing services to us, such as market analysis and benchmarking, web development and sub-contractors acting on our behalf for instance the company who provides our web hosting and general site maintenance;

e) where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and / or assets held by our business;

f) in anonymised form as part of statistics or other aggregated data shared with third parties; or

g) where permitted by law, it is necessary for our legitimate interests.

7.2 If you ask us to, we will share information with any third party that provides you with account information or payment services. If you ask a third-party provider to provide you with account information or payment services, you’re allowing that third party to access information relating to your account. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

7.3 In the event that any additional authorised users are added to your account, we may share information about the use of the account by any authorised user with all other authorised users.

7.4 In the event that you link your assets and liabilities with your immediate family under a Fee Family, the sum of the combined assets and liabilities held within the Fee Family may be shared with other members of the Fee Family. In some instances this may allow other members of the Fee Family to calculate the combined assets and liabilities you hold with us.

7.5 AAD will not share your information with third parties for their own marketing purposes without your permission.

8. Transferring information overseas

8.1 We may transfer your information to organisations in other countries (including to other AAD group companies) on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

8.2 In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:

a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;

b) the transfer has been authorised by the relevant data protection authority; and/or

c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us: dpa@all-about-debt.co.uk.

9. Marketing information

9.1 Unless you have told us that you do not want to hear from us, we will send you relevant marketing information (including details of other products or services provided by us or other AAD group companies which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication.

9.2 If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by sending us a secure message or by updating your Privacy Preferences.

10. Communications about your account

10.1 We will contact you with information relevant to the operation and maintenance of your account (including updated information about how we process your personal information), by a variety of means including via online messaging, email messages and text message / telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.

10.2 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing (below).

11. How long we keep your information

11.1 By providing you with access to our forum, and an account, we create records that contain your information, such as customer access records, activity records, personal records (sych as your uploads and messages etc). Records can be held on a variety of media (physical or electronic) and formats.

11.2 We manage our records to help us to provide a better all round service and platform to our members (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records also help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.

11.3 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant member is located and the applicable local legal or regulatory requirements. We (and other AAD group companies) normally keep customer account records for up to six years after your relationship with us ends, whilst other records are retained for shorter periods, for example 60 days for emails and other online communication records. Retention periods may be changed from time to time based on business or legal and regulatory requirements.

11.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they’re needed.

11.5 If you would like more information about how long we keep your information, please get in touch via our Secure Online Contact form.

12. Security

12.1 We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please get in touch via our Secure Online Contact form.

13. Complaints & DPA officer

13.1 In the unlikely event that you should have cause for complaint, we ask that you first raise the matter directly using our Secure Online Contact form, giving sufficient information and outlining the grounds for complaint. An initial response to any complaint can be expected within 3 days and a full and considered response to the complaint should be completed within 7 days and any subsequent remedy implemented with the minimum of delay.

13.2 You can get in touch with our Data Protection Officer by sending an email to: dpa@all-about-debt.co.uk.

Schedule A – Purposes of Processing

We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other AAD group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in the tables shown below:

Policy Updated: May 2018