Privacy Policy

Last Revised:  January 27, 2024 

Wise Financial Collection (“we”, “us” or “our”) respects your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1. 1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data, including through your use of this website, including any data you may provide through this website when you contact us and sign up to our newsletter.

It is important that you read this privacy notice together with any other privacy 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. 

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at [email protected]

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 notice and your duty to inform us of changes

This version was last updated on the 27 January 2024. 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.

 

1. 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.

The personal data we collect depends on our relationship with you. We collect personal data about our clients (including prospective and former clients.)

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, last name, date of birth, gender, job title, company name, your relationship to business/organisations and user name.
• Contact Data includes email address, address and telephone numbers.
• Financial Data may include bank or payment card details, details of income, records of loans, personal liabilities, government identifiers, and records of ownership of assets/shares.
• Technical Data includes internet protocol (IP) address 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 this website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional Data includes any information we may collect in the course of providing our services to you.
• Image Data includes images collected by CCTV at our sites.

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes.

Sometimes may 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, information about your health and genetic and biometric data). This is usually indirectly in the course of a professional engagement with a client.

We do not provide services to any individuals below the age of 18. 

We do not actively collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

1. 3. How is your personal data collected?

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

• Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Transaction Data, Marketing and Communications Data and Professional Data by providing it to our staff in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:

• volunteer it to us in the course of using our services;
• submit an enquiry; or
• request our newsletter to be sent to you.

We may also collect your Image Data when you visit our site.

• 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, and other similar technologies. Please see our cookie policy for further details.
• Public sources. We may collect your Identity Data from public sources such as such as Companies House, ID Global and the FAME system, which we may use to verify identification details.
• Third parties. We may collect your Identity Data and Financial Data from other professional services firms, providers of financial services and products and HMRC. We may collect your Identity Data from our business clients and prospective clients if you are an individual connected with them to enable us to deliver our services or enter into an engagement provide services. We may also collect your Identity Data from our individual clients and prospective clients if you are a family member or other individual connected to them to enable us to deliver our services or enter into an engagement provide services.

 

1. 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:

• to make contact with you for the first time (for example, where you have made an enquiry about our services);
• where we may be required to perform the contract we are about to enter into or have entered into with you;
• Where we are required to pass on your details to a third-party service provider to conduct the services you have requested;
• to promote our business services;
• to run and collaborate with clients in running training workshops and seminars;
• 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;
• to allow users to log on to the Document Exchange area of our website or portal or when you make a payment;
• to send you information and/ or invitations to you that we think may of be of interest to you and doing so is in accordance with the law;
• to administer the security of our information systems and websites and troubleshoot errors, monitor the effectiveness of changes and generally make sure our website works well for you;
• where we need to comply with a legal obligation; 
• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Where it is lawful for us to do so, for the purposes set out above and in accordance with this privacy notice, we may process the personal data of individuals without their knowledge.

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.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical and Marketing of Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us and unless you have opted out of receiving that marketing.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Cookies

For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

1. 5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Our clients.
• Contacts of the Wise Financial Collection network where necessary for providing a comprehensive service to you.
• Governmental or similar bodies including Companies House, the Charity Commission, the Financial Conduct Authority and HMRC.
• Providers of financial services and products.
• Providers of insurance products.
• Police and security services.
• Third parties who carry out services on our behalf, which involve the processing of personal data, such as IT service providers.
• 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 notice.

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.

 

1. 6. International Transfers

Some of our external third parties (service providers) are based outside the UK or European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK or European Commission; and/or
2. Where we use certain service providers, we may use specific contracts approved by the UK or European Commission which give personal data the same protection it has in Europe

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

 

1. 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.

 

1. 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.

 

1. 9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For more information on Your Legal Rights, please see section 10 below.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

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

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.

 

1. 10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your legal rights

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.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]