Privacy Policy

Effective from June 27th, 2018

Privacy Policy

The Insolvency Practice Ltd. trading as www.ivapractice.co.uk is committed to preserving the privacy of all visitors to www.ivapractice.co.uk.

Please read the following privacy policy to understand how we use and protect the information that you provide to us.

Any personal data obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling, and in accordance with Data Protection Act 2018 (DPA 2018).

By registering on this site, you consent to the collection, use and transfer of your information under the terms of this policy.

Our Privacy Promise

We promise:
• To keep your data safe and private
• Not to sell your data
• To give you ways to manage and review your marketing choices at any time.

How we may contact you

With your consent we may contact you via telephone, email, post, SMS, automated messages, fax and WhatsApp.

How you contact us

If you contact us by telephone using the specified numbers on our website or advertising/marketing correspondence, your call may be recorded for training, quality and regulatory purposes.
If you contact us via email, webchat, Whatsapp or post this information may be held securely by ourselves for training, quality and regulatory purposes.

Information that We Collect from You

We may obtain personal information from you through websites, mobile applications or other similar devices, channels or applications operated on behalf of any of the following brands: IVA Practice & The Insolvency Practice
When you visit, register or access services on www.IVAPractice.co.uk you may be asked to provide certain information about yourself including your name and contact details., including your email address and telephone number.
In the course of providing the services to you, we may also store information about how you use our sites, for example the pages viewed, the website from which you came to visit our site, details of your financial circumstances including the level of your debt and amount you can afford towards repaying your debts
We may also collect information about your usage of our Website as well as information about you from messages you post to the website and e-mails or letters you send to us.
Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the sites is correct, complete, accurate and not misleading and that you disclose all relevant facts
If you are providing us with another person’s information you should first ask them to read this Privacy Policy. By giving us information about another person you are confirming that they have given you consent to provide the information to us and that they understand how their details will be used.

What personal data will we need to collect?

To be able to provide our services we will need to collect certain categories of personal data. This will include:
Contact Details: Your full name, address, contact number, e-mail address etc. We need this so that we can keep you updated on the progress of your IVA and contact you when necessary. We also need this information to draft your proposal to creditors.

Personal & Financial Details: Your date of birth, gender, any previous names that you were known by, your living arrangements, employment details, details of any dependants, creditor details (including the names of your creditors, reference numbers and balances), details of any assets you hold and your payment information. We need this so that we can decide whether an IVA is appropriate for you and so that we can draft and send a proposal to your creditors. Once you enter into an IVA, we need this information to ensure that we can collect payments and take any changes in circumstances into consideration when administering the IVA.
Income and Expenditure: Details of your financial position including all sources of income and your household expenditure. We need this so that we can draft your proposal to creditors and set the correct level of payments to be paid into your IVA.
Special Personal Data: In some circumstances we may need to collect special personal data however we will not do so without express consent from you and we will only do so where it is necessary for the purposes of assisting with your financial situation. Special personal information is (physical or mental health, sexual orientation, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data) and call out sharing this data with third parties.
Creditor Reference Agency Data: We will ask for your consent to obtain information from a credit reference agency to obtain information about your financial situation, including information about your creditors, their status, outstanding balances and account numbers. We will also use this information to confirm your identity and to comply with anti-money laundering legislation.
Call Recordings, Chat Logs and E-mails: When you contact us by telephone, your call may be recorded for training and monitoring purposes. We also keep any e-mail correspondence and online chat logs to help us to manage your IVA.
Electronic signature: We can send documents to you by email which you will need to review, consider and where you decide to proceed, sign using an electronic signature. We will also collect information such as your name, the date and time of the event.

Use of your Information

We will only collect and use your personal information in accordance with data protection laws. Our grounds for processing your personal information are as follows:
1. Consent – Where necessary we will only collect and process your personal information if you have given your consent for us to do so, for example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent.
2. Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are to:

You have a right to object to our use of your personal information for these legitimate interests including where we may use your personal information to create a profile to inform customer demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information. Please contact our Compliance Team at contactus@ivapractice.co.uk should you wish to exercise this right.

Disclosure of your Information

The information you provide to us will be held on our computers and may be accessed by or given to third parties and our staff for the purposes set out in this policy or for other purposes approved by you. Those parties process information and provide support services on our behalf. We may also pass aggregate information on the usage of our site to third parties, but this will not include information that can be used to identify you.
We may share your personal information with these organisations:

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Automated Decision Making

information you provide to us to make a decision about you. This may include:

If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. If you want to do this you’d need to contact us at contactus@ivapractice.co.uk or use the contact information which will be provided to you once you’ve received the automated decision.

Sending data outside of the European Economic Area (EEA)

Information may be transferred to third parties who may be located outside the European Economic Area. We will ensure that your personal information is protected to the level of standards in accordance with the Data Protection Act 2018 (DPA 2018). If your information is shared with a third party, we will instruct and state restrictions to will protect your information. Our third-party partners will also have their own privacy policies, which we recommend you refer to.

Other types of advertising

When you visit our website or similar websites Google may use our advertisements promoting our products and services which may appear on other third party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preference Manager.

Cookies

Cookies are small amounts of information which we store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to the site. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalise the content of the site for you. You may set up the browser on your computer to reject cookies although, in that case, you may not be able to use certain features on our Website. If you do not wish to receive cookies in the future, please let us know.

Cookie Name Purpose More Information
Facebook fr Remarketing and conversion tracking Click here for more information about Facebook cookies
Google Analytics _utm(x), _ga(x), _gid, amp_token These cookies are used to collect information about how visitors use our website. They keep track of when a visitor enters and leaves the website and any search engines and keywords that are used, including any personal and/or special categories of data. Click here for more information about google analytics and how to disable this cookie.
Twitter guest_id, personalisation_id Remarketing and conversion tracking

Security and Data Retention

The amount of time we hold your information depends on the basis it was provided. Please see the following examples:
1. If you do not give consent to contact you for advertising and marketing reasons, we may still need to keep your information as this would reflect your preferences.
2. Information is also kept relating to any transactions you may enter via our website. This information will be kept for a minimum of six years, which will commence at the end of the relationship. We are required to do so to ensure that if any disputes or complaints are raised, we have your information to enable us to address the complaints or disputes. Your information will be kept purely for business needs.
3. In order to provide you with a service, we will be required to keep your information for however long this may take us.
4. Another reason for us to keep information about you is for legitimate business needs (where relevant), so we can comply with the law.
We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires.
We will take all reasonable steps to protect your personal information but cannot guarantee the security of any data you provide online. By using our Website and not advising us to the contrary, you agree to our using data in the way set out above and to accept the inherent security risks of providing information online without holding us responsible for any breach of security unless due to our negligence or wilful default.

Accessing and Updating

You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at contactus@ivapractice.co.uk

Your Rights

You have the following rights:
(i) Right to access: the right to request copies of your personal information from us for free;
(ii) Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
(iii) Right to erase: the right to request that we delete or remove your personal information from our systems;
(iv) Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
(v) Right to data portability: the right to request that we move, copy or transfer your personal information;
(vi) Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research and customer demographics (see section 5 above).
Contact
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to The Compliance Manager, Money Advisor Limited, 3rd Floor Churchgate House, Churchgate, Bolton, BL1 1HL.

Complaints & Queries

To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact our Compliance Team at contactus@IVApractice.co.uk If you are not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator which in the UK is the Information Commissioner’s Office.
This Privacy Policy shall be governed and construed in all respects in accordance with the laws of England and Wales.

Changes to this Privacy Policy

We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the Sites. The date of the most recent revision will appear on this page. If we make significant changes to this policy, we may also notify you by other means such as sending an email. Where required by law we will obtain your consent to make these changes. If you do not agree with any changes, please do not continue to use the Sites.