This Policy explains when and why we collect personal information about people who visit our website or who instruct us following a recommendation from a third party to consider using our services. The policy also explains, how we use your personal information, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check our website occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to email@example.com or by writing to us at Buchanan Business Park Suite 12. Cumbernauld Road, Stepps, Glasgow, Scotland, G33 6HZ
WHO ARE WE?
We are a business that specialises in assisting people who have unmanageable debts to propose Individual Voluntary Arrangements (IVAs) to their creditors to resolve their financial difficulties. Our business administers IVAs from their commencement until their conclusion.
HOW DO WE COLLECT INFORMATION FROM YOU?
We obtain information about you when you use our website, for example, when you contact us about our services. We also collect information directly from you by email and from companies or businesses who have advised you regarding your debts before you were introduced to us. We use publicly available online resources to obtain additional information, and this is likely to include information for Anti-Money Laundering purposes to confirm your identity and information from organisations such as H M Land Registry to confirm details of property ownership as well as other sources of information which may be directly relevant to your financial circumstances.
WHAT TYPE OF INFORMATION IS COLLECTED FROM YOU?
The personal information we collect is likely to include your name, address, email address, information about your finances bank account details, details and evidence of your income and expenditure, ownership of assets and the amounts you owe to your creditors. We are likely also to collect information concerning your domestic and family circumstances which is directly relevant to your financial circumstances.
HOW IS YOUR INFORMATION USED?
We use your information for the following purposes:
- to prepare a statement of your financial position
- enable us to advise you if an IVA is an appropriate solution for your financial difficulties.
- prepare your IVA proposal for consideration by your creditors.
- monitor your ongoing compliance with your obligations once your IVA has been approved.
- comply with our statutory obligations under the terms of the Insolvency Act 1986 and the Insolvency Rules 2016 and also to comply with best practice guidance issued by insolvency licensing bodies from time to time.
- seek your views or comments on the services we provide.
- notify you of changes to our services.
- send you communications which you have requested and that may be of interest to you.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations, and this includes for example holding details of all the information you provide in connection with a proposal for an IVA for 6 years following completion or termination of your IVA.
WHO HAS ACCESS TO YOUR INFORMATION?
- We will not sell or rent your information to third parties.
- We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers, agents, subcontractors, and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to assist with preparing financial projections for your business or to provide you with advice regarding the options available to you for resolving your financial difficulties).
When we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
When you are using our telephone or online payment process, your payment is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.
Whenever we transfer your personal information, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Your creditors will be provided with a full copy of your IVA proposal which will contain your personal information. On occasions at the request of your creditors, we may also provide them with additional information or documents e.g., copies of your wage slips, copy valuation of your house etc. This information and documentation will be provided in the context of complying with statutory and best practice obligations when acting for you concerning an IVA.
In the event of an IVA being approved by your creditors we will register the details of your IVA on the IVA Register which is maintained by the Insolvency Service. The Register is open for public inspection. Details of the registration will be provided by the Insolvency Service to Credit Reference Agencies.
HOW CAN YOU ACCESS INFORMATION HELD ABOUT YOU?
You have the right to ask for a copy of the information Fresh Start Insolvency Ltd holds about you and this will be provided to you on request without charge.
SECURITY precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
If you provide us with copies of documents containing personal information, we have processes in place with a view to ensuring these documents are protected from being accessed by third parties when transmitted to us and are treated securely once they are in our possession and control.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.
Use of ‘cookies’
It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website.
Links to other websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third party site.
Transferring your information outside of Europe
Our services are only provided to individuals in the United Kingdom. We will not transfer any personal information we hold about you outside of Europe.
Review of this Policy
We keep this Policy under regular review. This Policy was last updated in September 2022.
The debt write off amount for each customer differs depending upon their individual financial circumstances and is subject to the approval of their creditors.
We provide initial advice for free and there is no obligation to proceed with an IVA. We will check if you qualify to propose an IVA and your IVA will be subject to your creditors agreeing to its terms. Your monthly IVA payments may be different to the example provided and will be based on your personal circumstances. All fees will be clearly explained to you in writing.
Fresh Start Insolvency Ltd company number SC606381, registered office, Data Protection Act Registration Number ZB481786. Our company specialises in the preparation and supervision of Individual Voluntary Arrangements created by the Government in the Insolvency Act 1986. IVAs were created to help people to become free of unmanageable debt in a fixed period.
Adam Boys is authorised to act as an Insolvency Practitioner in England, Wales, and Northern Ireland by the Insolvency Practitioners Association.
Get in touch
Buchanan Business Park, Suite 12. Cumbernauld Road, Stepps, Glasgow, Scotland, G33 6HZ