Introduction
Welcome to TM Legal Services Limited privacy notice. TM Legal Services Limited company registration number 10214188, with its registered office address situated at 10 Whitehills Business Park, Whitehills Drive
Blackpool, FY4 5LW. (“TMLS”). Also referred to as “we”, “us” or “our” in this privacy notice.
TM Legal Services Limited is registered with the Information Commissioners Office (“ICO”) with the ICO registration number ZA212742.
TMLS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when your account is passed over to us to act and tell you about your privacy rights and how the law protects you.
Please also use the Schedule to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are;
Purpose of this privacy notice
This privacy notice aims to give you information on how TMLS collects and processes your personal data, including any data you may provide via the Courts, over the telephone, via email or via our website www.tm-legalservices.co.uk (“the Website”).
The Website is not intended for children and we do not knowingly collect data relating to children.
Welcome to TM Legal Services Limited privacy notice. TM Legal Services Limited company registration number 10214188, with its registered office address situated at Unit 10, Whitehills Business Park, Whitehills Drive
Blackpool, Lancashire, FY4 5LW. (“TMLS”). Also referred to as “we”, “us” or “our” in this privacy notice.
TM Legal Services Limited is registered with the Information Commissioners Office (“ICO”) with the ICO registration number ZA212742.
TMLS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when your account is passed over to us for us to enforce a County Court Judgment and tell you about your privacy rights and how the law protects you.
Please also use the Schedule to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are;
Purpose of this privacy notice
This privacy notice aims to give you information on how TMLS collects and processes your personal data, including any data you may provide via the Courts, over the telephone, via email or via our website www.tm-legalservices.co.uk (“the Website”).
The Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy may be amended from time to time so please check back to ensure you are aware of any changes.
Data Controller
TMLS are the Data Controller and become responsible for your personal data when your account is passed to us for enforcement of a County Court Judgment.
We have appointed a Data Protection Officer (“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 set out below.
Contact Details
Data Protection Officer
Email address: dpo@tm-legalservices.co.uk
Postal address: Unit 10, Whitehills Business Park, Whitehills Drive, Blackpool, Lancashire, FY4 5LW.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at dpo@tm-legalservices.co.uk.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 16th May 2018 and historic versions can be obtained by contacting us at dpo@tm-legalservices.co.uk.
The data protection law in the UK will change on 25 May 2018. This privacy notice sets out your rights under the new laws.
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.
Third-party links
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.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
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, email address, telephone numbers and details of employment.
• Financial Data includes bank account details, salary details, assets, liabilities, details on any dependants, income and expenditure and payment card details.
• Transaction Data includes details about payments to and from you, details of any arrears, details of arrears charges and associated costs.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
• Profile Data includes your username and password, payments made by you, your financial situation, marketing preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, payment line and services.
• Communications Data includes your preferences in relation to how we communicate with you.
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.
We do not generally collect any Special Categories of Personal Data (Sensitive 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 and genetic and bio-metric data and any information about criminal convictions and offences. We will not hold this information without your express permission.
If you fail to provide personal data
Where we need to collect personal data by law, or as part of the County Court Judgment 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.
3. How is your personal data collected?
Initially we are provided with your personal data by a debt collection company, when they assign the matter to us upon the receipt of the County Court Judgment. They are the Data Controller of your personal data and we also become a Data Controller of your personal data when the County Court Judgment is assigned to us.
• Direct interactions. You may give us your Identity, Contact and Financial Data by completing a call back form via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
• contact us to discuss your County Court Judgment;
• requesting information from us;
• via the County Court;
• create an account on our Website;
• use our 24 hour payment line;
• complete a survey; or
• give us some feedback.
We may also receive some personal data from you including via:
• Automated technologies or interactions. As you interact with our Website, 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 Websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below;
• Technical Data from analytics providers such as Google based outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment services based inside the EU.
• Identity and Contact Data from the Credit Reference agencies we use based inside the EU.
• Identity and Contact Data from publicly available sources such as the Electoral Register based inside the EU.
• Identity and Contact Data from online tracing tools.
• Cifas, a fraud prevention agency or similar fraud prevention agencies.
• The Insolvency Service or insolvency practitioners.
• Debt Management Companies.
4. How 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 understand your personal circumstances and assess your income and expenditure in relation to payment proposals.
• Where we need to instruct the County Courts in relation to enforcement action.
• Where we need to enquire about your Identity and Contact Data from online tracing tools.
• 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.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.