INTRODUCTION

This Privacy Policy describes the information that TTI SPC and its servicer, Oakbrook Finance Limited ("Oakbrook") will gather about you as a customer in respect of debts we have purchased or otherwise in connection with our collections activity and how we use and process such information along with our legal basis for processing the data and how long we will keep the data.

Where the legal basis of consent is to be used, this will be gathered freely, and we will use clear, plain language that is easy to understand, and you will be able to remove your consent at any point.

References to “us” or “we” or “our” are references to TTI SPC, PO Box 31890 DMS House 20 Genesis Close Grand Cayman KY1 1208 and Oakbrook,  the Poynt North, 45 Wollaton Street Nottingham NG1 5FW. References to “you” are references to you as the data subject of the personal data we acquire and process for the purposes of our activities in managing your debts (the “Services”) acting as data controllers. TTI SPC is registered as a data controller with the Information Commissioners Office under registration number Z1472415 and Oakbrook is also registered under registration number Z3250811.

We respect your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights under the Data Protection Act 2018 and the UK General Data Protection Regulation ("GDPR").

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your personal data, including any data we acquired on purchasing your debt, other data you may provide when you engage with us or data we may obtain from other third party sources, such as insolvency service providers or the Official Receivers Office, in the course of collecting debts.

It is important that you read this privacy policy 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 privacy policy supplements the other notices and is not intended to override them.

CONTACT DETAILS

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact info@tti-spc.com or by writing to us at the address of BCI or Oakbrook, shown above.

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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated as at October 2022. Any further amendments will be made to the version on the website at tti-spc.com (the "Website").

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.

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, place of birth, national insurance number, residency and gender.

·       Contact Data includes postal address, email address and telephone numbers.

·       Financial Data includes details of your loan account status and repayments.

·       Transaction Data includes details about payments from you and other details of your engagement with us.

·       Technical Data includes your login data and other technology on the devices you use to access the Website.

·       Usage Data includes information about how you use the Website.

We do not generally collect any 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, information about your health and genetic and biometric data); however if you volunteer any such information to us we may process it with your consent for the management of your account.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions: where you provide your information to us

  • Automated technologies or interactions: As you interact with the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, SDKs and other similar technologies.

  • Third-parties or publicly available sources: We acquire information about you from third parties including credit reference agencies or fraud prevention agencies, the party who originally sold your debts to TTI SPC, publically available sources such as the electoral roll and third parties which are involved in the administration of your debt such as insolvency practitioners and the Official Receiver.

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:

•         For the purposes of our contract with you and the servicing of it.

•         Where it is necessary for our legitimate interests in managing our business assets and debts and your interests and fundamental rights do not override those interests.

•         Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We use your personal data to manage collections to your account and contact you if required for these purposes.  Our legal bases for using your personal data include contractual necessity, compliance with our legal obligations and our legitimate interests.  We may also rely on your consent where you volunteer information to us.

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.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties which process your personal data on our behalf in connection with the Services, with regulatory or law enforcement agencies or third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 data processors 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.

6. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that one of the at least one of the safeguards specified in part V of the GDPR is implemented such as the Standard Contractual Clauses.

7. DATA 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will ordinarily delete your personal data within six years of the end of our relationship with you to correspond with the statutory limitation period under UK law.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.