Data Protection and Privacy

Who are we and how can you contact us

Adlib Finance Ltd, trading as We Reclaim, Unit 1, The Barn, Woodrow Farm, Woodrow Lane, Bromsgrove, B61 0PL is a data controller of your personal information. This means information about you or from which we can identify you. Protecting your privacy is important to us .This privacy notice explains how we collect, store and process your personal information. We can be contacted at any time at the above address, including if you have queries about this privacy notice or wish to exercise any of the rights mentioned in it. You can also contact us at enquiries@wereclaim.co.uk (We do not guarantee that any emails sent to us, by you, will be received safely. Please contact us via telephone if you are in any doubt or wish to check the status of an email sent to us.

What is the purpose of this Privacy Notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website and also to other personal information that you give us when we provide you with our services.

We ask that you read this Privacy policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use and store your personal data.

This privacy policy applies to you if you provide your personal information to us, even if you decide not to proceed with any product or service we offer

Third-party links outside of our control

This 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.

The Personal Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or information we are required to collect to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

When we speak with you about your mis-sold Payment Protection Insurance (PPI) Policies or mis-sold Packaged Bank Account (PBA) claim requirements, we do so on the basis that both parties are entering a contract for the supply of services.

To perform that contract and to arrange the services you require we have the right to use your Personal Data for the purposes detailed below:

Pre-Submission checks with the Bank/Lender or data controller, specified to determine the validity of the PPI or PBA claim(s).

Submission, pursuit, and resolution of a mis-sale claim if determined to be valid, or claim regarding undisclosed commissions.

Regular contact with you to update you on your account and about related services you may be interested in.

We have the right to use your Personal Data, provided it is in our legitimate business interest to do so and your rights are not affected, either during initial discussions with you or when the contract between us has come to an end for whatever reason. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to contact you to seek feedback on the service you received.

On occasion, we will use your Personal data for contractual responsibilities we may owe our regulator, the Claims Management Regulator, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing your Personal Data to meet a legal, compliance or other regulatory obligation to which we are subject to.

The information that we need for these purposes is known as your “personal data”. This includes

Your personal details (e.g. title, full current and previous names (if applicable), date of birth)

Address details (current and previous addresses)

Contact details (e.g. phone number, email)

Special personal information * (e.g. health information)

Financial information

Employment information

Information on how you use our website(s) and products and service

How we will deal with your Special Data

Where you ask us to assist you with your mis-sold Payment Protection Insurance (PPI) Policy or mis-sold Packaged Bank Account (PBA) claim(s), we may ask you information about your ethnic origin, your health, and medical history (“Special Data”)

We will record and use your Special Data to illustrate to the seller (or institution responsible for potential redress) of the Payment Protection Insurance (PPI) Policy or mis-sold Packaged Bank Account that the product may not meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

We will use Special Data in the same way as your Personal Data generally, as set out in this Privacy Notice.

Information on Special Data must be capable of being exchanged freely between claims management companies such as our Firm, Banks & other Lending institution, insurance underwriters,  the Financial Ombudsman and the Financial Services Compensation Scheme (where applicable) to enable your claim to fully illustrate your eligibility or ineligibility for the alleged mis-sold product the claim requires.

If you fail to provide personal data

Where we need to collect your 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 our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

How we collect your Personal Data

When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means.

Information received from a third party, for example where you have previously agreed for your information to be shared with us if you have been introduced to us by another company.

When you participate in market research, competitions and promotions provided by us, or on our behalf.

By adding reviews or interacting with us using social media such as Twitter or Facebook.

When we may need to obtain up to date information about you to meet our legal or regulatory obligations.

Where you have given permission for your information to be provided to us.

We may also obtain some information from other third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of your Personal Data, for example software that can verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner.

How we use your personal information / Data

We will only collect and use your personal data when the law allows us to. Most commonly, we will use your personal data to the extent deemed reasonably necessary to serve our legitimate business purposes

ContractualWhen it is necessary to enter into or fulfil a contract we have with you

ConsentWhere necessary we will only collect and process your personal information if you have consented for us to do so. For example, when you make an enquiry on our website to be contacted regarding a service we provide and have given your preferred contact information/method.

Legal ObligationWhere we have a legal or regulatory obligation to do so.

Legitimate InterestsWe may use and process some of your personal information where we have sensible and legitimate business grounds for doing so and it is necessary to protect your vital interests; or it is in our legitimate interest to do so and it is not against your rights.

Other – We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services and may also provide aggregate information to third parties. These statistics will not include information that can be used to identify you.

How we may contact you regarding products and services

If you have provided us with your consent or where we are legally entitled to do so, we may contact you to let you know about other offers, products and services that we can provide, which we think you may be interested in or that may benefit you. We may do this through post, emails, text messages, telephone, social media or other electronic means.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Adlib group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by email at enquiries@wereclaim.co.uk or in writing at We Reclaim, Unit 1, The Barn, Woodrow Farm, Woodrow Lane, Bromsgrove, B61 0PL

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the service(s) we provide.

Cookies

A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website; we will use the persistent cookies to: enable our website to recognise you when you visit

Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites, including this one.

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 in writing at We Reclaim, Unit 1, The Barn, Woodrow Farm, Woodrow Lane, Bromsgrove, B61 0PL

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who do we share your information with

We control the use of your data as you have directed.

We will treat any and all information received confidentially and will only use that information to allow  to facilitate the provision of our service, with the exception of where the law requires us to disclose it, or where it is necessary to disclose the information to comply with a regulatory or legal process.

To allow us to provide our services to you, the following third parties provide critical functions to our business and will process your personal information as directed by us and in accordance with strict data security arrangements:

Our Services: during our services we will provide your data, under your specific instruction, to named lenders, loan brokers, insurance underwriters/ or the institution responsible for any potential redress and, if required, The Financial Ombudsman Service and The Financial Service Compensation Scheme.

Our Advertising: we use third party advertising representative, who designs, hosts and manages our advertisements. They will also set cookies on your device in accordance with our cookie policy. They are our data processor, which means they only process your data under our contract with them and under our strict instruction. You may opt-out of these at any time. They receive a copy of the data that you have submitted through our website, including your IP address. We also use third party advertising services who provide analytical information about our advertising to help us improve this in the future. In any event, the data held by analytics firms is on an anonymised basis meaning they cannot identify you;

Our Systems and IT: we use third party firms who provide essential storage arrangements (including call recordings), software and support to our infrastructure;

Our Regulators: we may be required to provide your data to our Regulators, who include the Claims Management Regulator, the Legal Ombudsman Service and the Information Commissioner’s Office.

We do not sell your data to third parties in any circumstances. We have carefully selected our third parties due to their commitment to keeping your data safe, and all data is processed within the European Union and subject to the same legislation. If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.

We may also share data with the following organisations:

Payment Service companies that process transactions for us (e.g. Direct Debits and card transactions, automated payment service)

Communication providers (e.g. telephone line providers, and email and text/live chat service providers)

PR & Marketing agencies who help to promote our products and services and manage our brands.

Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account

Third parties who may have introduced you to our services

Other Third Parties: Where we have your consent to do so, or where we are required to do so under a legal or regulatory obligation, for example where we are required to do so by a court order, the police, local authorities or the courts. We might share some of your information with the emergency services if we think you are in any immediate danger.

Fraud Prevention Agencies

The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information is used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email us at enquiries@wereclaimco.uk or in writing at We Reclaim, Unit 1, The Barn, Woodrow Farm, Woodrow Lane, Bromsgrove, B61 0PL

International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

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.

DATA RETENTION

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.

By law we have to keep basic information about our customers including contact, identity, financial and transaction data for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

YOUR LEGAL RIGHTS

Under the terms of data protection legislation, you have the following rights

Right to Be Informed

This privacy notice, together with our Cookies Policy, fulfils our obligation to tell you about the ways in which we use your information as a result of you using this website or our services.

Right to Access

You have the right to ask us for a copy of any personal data that we hold about you. This is known as a “Subject Access Request”.

Right to Rectification

If you wish to amend any inaccurate data that we hold, please notify us specifically by telephone, post or email, or during the course of the provision of our services. We will make the amendment as soon as possible. If any data held is incomplete, you can complete this at any time. We may require this to be completed to allow us to provide our services (e.g. if we do not have your full address).

Right to Be Forgotten

From 25 May 2018, you can ask that we erase all personal information that we hold about you. Where it is appropriate that we comply, your request will be fully actioned within 30 days.

Right to Object

You have the right to object to:

The continued use of your data for any purpose listed in section  above for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time. The continued use of your data for any purpose listed in section above for which the lawful basis of processing is that it has been deemed legitimate.

Right to Restrict Processing

You can restrict us from processing your data in the following circumstances:

You believe your data is inaccurate;

You believe your data has been unlawfully processed but do not want us to delete your data;

We no longer need your data but it is required by you for making or defending a legal claim; or you object to the processing, as described below, but we are verifying this.

If you make a restriction request, we will still store a copy of your data but cannot use this. We will inform you if the restriction needs to be lifted. You can make this request using reasonable means including by telephone, post or email. If you request for your data to be restricted, we will confirm whether this can take place and the next steps that we will take. If we cannot restrict your data, we will explain why and confirm any actions required to allow us to do so.

Right to Data Portability

In some cases you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you want to request this you’ll need to contact us.

Rights Related To Automated Decision-Making

If you would like to object to automated decision making without any individual involvement, and to the profiling of your data, please notify us specifically by telephone, post or email, or during the course of the provision of our services.

There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

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.

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.

Social Media

We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms you should be aware that:

The social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and

Each social media platform will process any personal information you provide through the platform and will be processed in accordance with its own privacy policy. The privacy policies are available to view on each social media platform.

Recording Calls

We may record any telephone call you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.

We may keep a copy of the telephone calls for up to 6 years from the date the telephone call was made.

Queries, Requests or Concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us: Data Protection, We Reclaim, Unit 1, The Barn, Woodrow Farm, Woodrow Lane, Bromsgrove, B61 0PL

You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

No fee required – with some exceptions

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 admin 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.

If you have any concerns or complaints as to how we have handled your Personal Data you may lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

Policy Amendments

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes, although anything that will affect you will be communicated directly to you. Last Updated 24/05/2018