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Home > Privacy Policy


PRIVACY POLICY

ACI is committed to making sure you can trust us with your personal information.


THIS PRIVACY POLICY APPLIES TO PERSONAL INFORMATION PROVIDED TO US, BOTH BY YOU
AND BY OTHERS ON YOUR BEHALF. IT SETS OUT OUR KEY PRINCIPLES AND PROVIDES AN
OVERVIEW OF HOW WE MAKE SURE THIS HAPPENS.

Your privacy and other related rights under the provisions of the UK General
Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 and the EU
General Data Protection Regulation (EU GDPR) which applies across the European
Economic Area (EEA).

This notice describes how we collect, store, use and share personal information.
It also explains the rights you may have in relation to the personal information
that we hold about you.

Please read this privacy [and cookie] policy, and any other privacy notice or
policy that we may have provided to you or provided access to. We want to be
sure that you are fully aware of how and why we are using your data.


1. WHO WE ARE

ACI UK Limited “ACI” (company registration number 03775287) is a specialist debt
resolution company who help customers manage their outstanding debts. ACI Ltd
are authorised and regulated by the Financial Conduct Authority under
registration number 708400 and registered with the Information Commissioners
Office (“ICO”) with the ICO registration number ZA116228.

We are the data controller of all personal data received as part of any
portfolio purchase made by ACI; or

We are joint data controller when acting as the FCA regulated master servicer on
behalf of Perch Capital; or

We are a data processor when servicing accounts on behalf of another company.


2. WHAT IS PERSONAL DATA AND WHY DO WE USE IT?

Personal data is defined under the UKGDPR as any information relating to an
identified or identifiable natural person (‘data subject’); an identifiable
natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.

In essence, personal data is your personal information. Please see section 3 for
the type of personal data that we collect. We collect and process personal data
primarily to provide you with our products and services. Section 4 of this
privacy notice tells you what you can expect us to do with your personal data
when you use one of our services.

The Website(s) are not intended for children and we do not knowingly collect
data relating to children.


3. WHAT KINDS OF PERSONAL INFORMATION DO WE HOLD ABOUT YOU?

When we collect your personal data, we will let you know if any of it is
optional. If it is, we will explain why it would be useful to us, and you can
decide whether it is something you are happy for us to have.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.

We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together follows:



   

 * Identity Data includes first name, maiden name, last name, username or
   similar identifier, marital status, title, date of birth and gender.

   

 * Contact Data includes address, previous addresses, email address, telephone
   numbers

   

 * Financial Data includes bank account details, salary details, assets,
   liabilities, details of other debts that you hold, details on any dependants,
   income and expenditure, details from Credit reference Agencies, payment card
   details and any other relevant information about your finances.

   

 * Account Information includes details about accounts held by you with our
   client, including balances, account numbers, payments to and from you,
   details of any arrears, details of arrears charges and associated costs.

   

 * Online Information – Includes IP address (your computer’s internet address)
   if you use our websites.

   

 * Profile Data includes your username and password, payments made by you, your
   financial situation, marketing preferences, communication preferences,
   feedback and survey responses, certain publicly available data such as
   details of property that you own and details of business interests.

   

 * Usage Data includes information about how you use our Website, payment line
   and services.

   

 * Voice Recordings - Our calls are recorded for training and monitoring
   purposes and may be shared with our regulators, professional advisors, and
   other companies within the Group.  The call recordings will be retained in
   accordance with our Data Retention Policy.

   

 * Special Categories of Personal Data(Sensitive Personal Data) - We do not
   generally collect special categories of personal data about you (this
   includes details about your race or ethnicity, religious or philosophical
   beliefs, sex life, sexual orientation, political opinions, trade union
   membership. However, we may on occasion collect information about your
   health, which may affect your ability to manage your finances or communicate
   with us and genetic and biometric data.  We will not hold this information
   without your express permission.

   

We also collect, use, and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data
does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this
privacy notice.


4. HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:



   

 * Where we need to communicate with you.

   

 * To perform our contractual obligations with other Group companies.

   

 * Where we need to understand your personal circumstances and assess your
   income and expenditure in relation to payment proposals.

   

 * We may use your Identity, Contact, Technical, Usage and Profile Data to form
   a view on what we consider to be an affordable repayment plan for you.

   

 * Where we need to instruct third parties to act on our behalf, which may be
   outside of our Group of companies.

   

 * To report to our external advisors and investors.

   

 * Where we need to consider relevant circumstances when making decisions about
   the progression of cases.

   

 * Where we need to enquire about your Identity and Contact Data from online
   tracing tools.

   

 * Where we need to comply with a legal or regulatory requirements and
   obligations.

   

 * To deal with queries and complaints.

   

 * Verifying your identity, preventing fraud and financial crime.

   

 * Identifying vulnerable customers to help determine whether we need to take
   further steps to ensure these customers are not disadvantaged in any way.

   

 * Assessing, developing, and managing our products, systems, business, and
   brand

   

 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.

   


5. WHERE DO WE GET YOUR PERSONAL INFORMATION FROM?

   

 * Your Lender - Initially we are provided with your personal data by the lender
   which originally provided you with your loan.  We become a Data Controller of
   your personal data when they assign the debt to us.

   

 * Directly from you - You may give us your personal information by completing a
   call back form via our Website(s) or by corresponding with us by post, phone,
   email or otherwise.

   

 * County Court – we may collect information as part of the County Court Claim /
   enforcement process.

   

 * Automated technologies or interactions.As you interact with our Website(s),
   we may automatically collect Technical Data about your equipment, browsing
   actions and patterns. We collect this personal data by using cookies, server
   logs and other similar technologies. We may also receive Technical Data about
   you if you visit other Website(s) employing our cookies.

   

 * Payment Services providers – we may obtain Contact, Financial and Transaction
   Data from providers of technical, payment services.

   

 * Credit Reference agencies – we may obtain Identity and Contact Data

   

 * Publicly available sources – we may obtain Identity and Contact Data from
   sources such as the Electoral Register.

   

 * Tracing companies - Where we need to collect personal data by law, or as part
   of the collections process or as part of the County Court Claim/ enforcement
   process and you fail to provide that data when requested, or we have been
   provided with out-of-date personal data by the original lender, we may have
   to obtain this personal data via online tracing tools and/or third-party
   tracing agents.

   

 * CIFAS, a fraud prevention agency or similar fraud prevention agencies.

   

 * The Insolvency Service or insolvency practitioners.

   

 * Debt Management Companies.

   


6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

As you would expect, our employees will access your personal information for the
purposes mentioned above. For example, our staff need access to your information
to support you when you get in contact with us.

We will also share your personal information with the following categories of
third parties. We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and in
accordance with our instructions.



   

 * Companies within the Group that may act as joint data controllers or data
   processors.

   

 * Service providers - including I.T. providers, SMS messaging services, call
   recording services and system administration services, survey

   

 * Professional advisers - including lawyers, bankers, debt recovery agents,
   bailiffs, auditors, and insurers who provide consultancy, banking, legal,
   debt recovery services, tracing agents, repossession agents, insurance, and
   accounting services.

   

 * Legal & Regulatory bodies including HM Revenue & Customs, regulators, HM
   Courts & Tribunals Service, and other authorities.

   

 * Mediators

   

 * Court Advocates

   

 * Process Servers

   

 * Third parties, including Debt Management Companies who you may authorise to
   deal with matters on your behalf.

   

 * Customer satisfaction survey administrators.

   

 * Investors

   

In the event ACI was to merge or sell any part of its business or assets, it
will be necessary to pass your personal information to the prospective
buyer/party.

Credit Reference Agencies (“CRA’s)

This section explains how we work with credit reference agencies and explains
what we do and why we do it. We will share your personal information with CRAs,
and they will provide us with information about you. The data we exchange can
include:



   

 * Name, address, and date of birth

   

 * Details of any other credit you may have, including shared credit

   

 * Financial situation and history

   

 * Fraud prevention information

   

 * Public information, from sources such as the Electoral Register and Companies
   House.

   

We will use this data to:



   

 * Assess whether you can afford to make repayments

   

 * Make sure what you have told us is true and correct

   

 * Help detect and prevent financial crime

   

 * Manage your account with us

   

 * Trace and recover debts

   

We will go on sharing your personal information with CRAs for as long as you
have an account with us.  This will also include details of funds going into the
account, and the account balance. We will also include details of your
repayments and whether you repay in full and on time. We will also tell the CRAs
when you settle your accounts with us. The CRAs may give this information to
other organisations that want to check your credit status.

The credit reference agencies have their own privacy policies which set out how
they process and look after your data.  Please see below the links to the
privacy notice for each of the three main Credit Reference Agencies:

https://www.equifax.co.uk/crain

https://www.transunion.co.uk/crain

https://www.experian.co.uk/crain/


7. WHAT ARE OUR LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION?

Data Protection legislation sets outs specific grounds under which your personal
data may be lawfully processed. The legal grounds for the processing of personal
data by us will depend on the purpose for which the processing is being carried
out.

We will only use your personal data when one of these grounds has been
satisfied. Below you can see how we use your personal data and the legal grounds
for processing this:



Legal Grounds Use of your Information Necessary for the performance of a
contract



The personal data you provide or that of a joint party to the contract may be
processed when it is necessary to enter or perform a contract. E.g., where we
process your information relating to a loan contract



   

 * To register you as a new account.

   

 * Managing your account.

   

 * Where we need to communicate with you.

   

 * Where we need to understand your personal circumstances and assess your
   income and expenditure in relation to payment proposals.

   

 * To find a payment solution that reflects your own situation.

   

 * To set up a payment arrangement and manage it until the final payment is
   made.

   

 * To deal with queries and complaints.

   

 * Where we need to enquire about your Identity and Contact Data from online
   tracing tools

   

 * Notifying you about changes to our terms

   

 * To perform our contractual obligations with other Group companies.

   



Necessary for compliance with a legal obligation



Your Personal data may be processed where ACI has a legal obligation to perform
such processing.



   

 * Verifying your identity, preventing fraud and financial crime.

   

 * To instruct a third party to issue a Court Claim.

   

 * To enforce a County Court Judgment

   

 * To continue to collect payments against your County Court Judgment after
   enforcement.

   

 * To report to our external advisors and investors.

   

 * Where we need to comply with a legal or regulatory requirements and
   obligations with HMRC, regulators, HM Courts & Tribunals Service, and other
   authorities

   



Consent



Your personal data may be processed when we receive your consent. The consent
you provide must be freely given, informed, specific, unambiguous, and given
with a positive affirmative action. Your consent can be withdrawn at any time by
using the contact details provided below.

We process special category information to be able to treat you as a vulnerable
customer (if due to personal circumstances you are in a vulnerable position).
You may, at your discretion provide us with this type of information on a
voluntary basis and based on your consent. Necessary to protect vital interests.



This will usually only apply in "life‑or-death" scenarios.

We may disclose your information to the Police or other authorities if we have
serious concerns about your wellbeing.



Necessary for legitimate interests

We also use your personal data when we have a “legitimate interest”, and that
interest is not outweighed by your privacy rights. Each activity is assessed,
and your rights and freedoms are considered to ensure that we are not being
intrusive or doing anything beyond your reasonable expectation. We will assess
the information we need, so we only use the minimum.

If you want further information about processing under legitimate interests, you
can contact us using the details below. You also have the right to object to any
processing done under legitimate interests. We will re-assess the balance
between our interests and yours, considering your circumstances. If we have a
compelling reason, we may continue to use your personal data.

We use legitimate interests for the following:



Use of your information Legitimate Interest Assessing, developing, and managing
our products, systems, business, and brand To define types of customers for our
services.



To keep the Website updated and relevant and provide a better customer
experience.

To develop our business and to inform our strategy.

To deliver relevant Website content to you and measure or understand the
effectiveness of the content we serve to you To study how customers use our
services, to develop them, to provide a better customer experience, to grow our
business. To administer and protect our business and the Website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data) For running our business, provision of administration and
IT services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise Asking you to leave a review or
take a survey. To study how customers use our services, to develop them and grow
our business).



To understand the customer experience and provide better customer service.




8. OVERSEAS TRANSFERS

We don’t ordinarily use third parties located outside the European Economic Area
(EEA). However, we may sometimes use third parties located in other countries to
provide support services.  If we do, your personal data may be processed in
countries outside the EEA.

These services will be carried out by experienced and reputable organisations on
terms which safeguard the security of your information and comply with the
European data protection requirements.  Some countries have been assessed by the
European Commission (EC) as being ‘adequate’, which means their legal system
offers a level of protection for personal information which is equal to the EC’s
protection.   Where the country hasn’t been assessed as adequate, the method we
have chosen to safeguard your information is ‘standard contractual clauses’
within the legal agreement to safeguard the processing of your personal data.

The European Commission and the UK have recognised ‘standard contractual
clauses’ as offering adequate safeguards to protect your rights and we’ll use
these where required ensuring adequate protection for your information as
prescribed by the GDPR. The European Commission approved standard contractual
clauses are available here.

We will use these recognised ‘standard contractual’ clauses if and when we
conduct any activity that involves processing personal data outside the EEA.

We will always ensure your personal data is provided with adequate protection
and all transfers of personal information outside the EEA are done lawfully.


9. SECURITY

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered,
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions, and they
are subject to a duty of confidentiality.

In the event of a potential data security breach, we will notify you and the
Information Commissioner’s Office if we are legally required to do so, or there
is a risk to your rights and freedoms because of the breach.

The Website may include links to third-party websites, plug-ins, and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.


10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will keep your personal data for as long as it is considered necessary for
the purpose for which it was collected, and to comply with our legal and
regulatory requirements. This will involve retaining your personal data for a
reasonable period after your relationship with us has ended.

In the absence of specific legal, regulatory, contractual requirements or
technical reasons, your personal data is kept for 6 years after our relationship
with you has ended.

In certain circumstances you can ask us to delete your data: see Right to
Erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.


11. DO WE MAKE SOLELY AUTOMATED DECISIONS ABOUT YOU OR PROFILE YOU?

Automated decisions are where a computer makes a decision about you without a
person being involved. Profiling means any form of automated processing of
personal data consisting of the use of personal data to evaluate certain
personal aspects relating to a person.

We do not make any solely automated decisions or profile your data.


12. WHAT ARE MY RIGHTS?

Your rights are outlined below. The easiest way to exercise any of your rights
would be to contact our Data Protection Officer at the contact details provided.
We will provide a response within one month, if not sooner. There is normally no
charge for exercising any of your rights. We may ask you for proof of identity
when you request to exercise some of these rights to ensure we are dealing with
the correct individual



   

 * Access to your personal data - You have the right to find out what personal
   data we hold about you, in many circumstances.

   

 * Correcting or adding to your personal data - If any of your details are
   incorrect, inaccurate, or incomplete, you can ask us to correct them or to
   add information.

   

 * Withdrawing your consent - If you have provided consent for us to use your
   personal data, you have the right to withdraw it at any time. If you withdraw
   consent, then we are not allowed to use your personal data going forward.
   However, it would not invalidate processing that was carried out before you
   withdrew consent.

   

 * Transferring your personal data to another organisation (Data portability) -
   In some circumstances, you can ask us to send an electronic copy of the
   personal data you have provided to us, either to you or to another
   organisation.

   

 * Objecting to the use of your personal data for legitimate interests - You
   also have the right to object to any processing done under legitimate
   interests. We will re-assess the balance between our interests and yours,
   considering your circumstances. If we have a compelling reason, we may
   continue to use your personal data if that interest is not deemed to be
   outweighed by your privacy rights. However, we will inform you of that
   decision and reasoning for continuation of processing.

   

 * Objecting to direct marketing - You have a specific right to object to our
   use of your personal data for direct marketing purposes.

   

 * Objecting to automated decision making - You have a right to object if we
   have made an automated decision, including profiling, which has legal and
   significant effect against you. You may also have the right to challenge the
   decision and ask for a human review. These rights do not apply if we are
   authorised by the law to make such decisions and appropriate safeguards are
   in place to protect your rights.

   

 * Restricting the use of your personal data - If you are uncertain about the
   accuracy or our use of your personal data, you can ask us to stop using your
   personal data until your query is resolved. We will let you know the outcome
   before we take any further action in relation to this personal data.

   

 * Right to Erasure - You can ask us to delete your personal data in some
   circumstances. we may not always be able to comply with your request of
   erasure for specific legal reasons which will be notified to you when you
   make a request.

   


13. COOKIES

We use cookies in connection with the operation of our website. A cookie is a
small file that is sent by a web server (where we host our website) to a web
browser (from where you view our website), and which is then stored by the
browser.

Usually, cookies do not hold any data by which you can be identified, although
if we do hold personal data about you (for example, because you have subscribed
to a service that we offer) the cookie may be linked to that data.

In addition to cookies used by us, our service providers may also use cookies,
and those cookies may also be stored in your browser when you visit our website.

If you wish to do so then usually you can prevent cookies from being downloaded
to your browser and may delete those that have already been downloaded. How this
is achieved varies between different browsers. Consult the website of your
browser provider for more details.

You should be aware that if you block or delete cookies this may have a
detrimental impact upon your ability to access our website and the services that
we provide. It may mean that not all of the facilities on our website will be
accessible by you, or it may mean that you are unable to access any services
which we provide. We regret that we cannot, for technical reasons, provide any
further service unless your browser is set to accept cookies.

For further information about the cookies, we use please contact our Data
Protection Officer.


14. RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY

If you are unhappy with how we are using your personal data, you have the right
to complain to the Information Commissioner’s Office. We would encourage you to
contact us first to give us the opportunity to deal with your concerns in the
first instance.

The Information Commissioner`s office can be contacted by



   

 * Visiting their website ico.org.uk

   

 * Phone on 0303 123 1113

   

 * Write to Information Commissioner`s Office Wycliffe House, Water Lane,
   Wilmslow, Cheshire, SK9 5AF

   


15. CHANGES TO OUR PRIVACY POLICY

Making sure that we keep you up to date with privacy information is a continuous
responsibility and we keep this notice under review. We will update our notice
as changes are required.

If we need to use your personal data for a new purpose which we have not
previously told you about, we will contact you to explain the new use of your
personal data. We will set out why we are using it and our legal reasons.

This privacy notice was last updated on the 5 May 2022.


16. CONTACT US

We have appointed a Data Protection Officer’s (“DPO”) who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise your
legal rights, please contact the DPO using the details below:

Email: dpo@aciuk.co.uk

Post: Data Protection Officer, Unit 10, Whitehills Business Park, Whitehills
Drive, Blackpool, Lancashire, FY4 5LW


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ACI is a trading name of ACI-UK Limited. Company registration number 03775287.
Incorporated in England and Wales. Registered Offices: 10 Whitehills Business
Park, Whitehills Drive, Blackpool, Lancashire FY4 5LW.
Authorised and regulated by the Financial Conduct Authority for Consumer credit
regulated activity, Firm Reference No. 708400. Registered with the Information
Commissioners Office, Registration No: ZA116228. Credit Services Association
Membership No. 987 (CSA Code of Practice).


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