Togglit
Togglit

Qualco UK t/a Togglit Privacy Policy

Your data is important to you. Qualco UK (QUK) values your privacy, and we want to be clear about the data we collect, how we use it, and your rights to control that information.

We are both a processor and a controller of your data and acts in accordance with the requirements set out in the UK Data Protection Act 2018.

Our contact details

Name: Data Protection Officer

Address: Qualco UK, Building 1, The Heights, Wellington Way, Weybridge, KT13 0NY

Phone Number: +44 20 3398 0200

E-mail: dataprotection@qualco.co.uk

The type of personal information we collect

We currently collect and process the following information: Personal identifiers, contacts, and characteristics:

  • Name
  • Date of Birth
  • Phone Number
  • Email Address
  • Property Address

Personal information is any information that can be used to identify a living person. For example email addresses, customer financial information, employee data or website user stats. You can find more about what constitutes personal information on the ICO website..

How we get your personal information and why we have it

The data we receive is provided either directly by you or provided indirectly from other sources. Who we receive it from, the type of personal data we receive, and our purpose for receiving it are detailed in the table below.

Who we receive data from: Types of personal data: Purpose for receiving data:
Creditor Client
  • Name
  • Date of Birth
  • Phone Number
  • Email Address
  • Property Address
 To fulfil our contractual obligations to manage your account.
Credit Reference Agencies
  • Name
  • Phone Number
  • Email Address
  • Property Address
  • Affordability
  • Credit Scores
 To ensure that the information we hold is accurate and up to date. To understand characteristics related to your credit score and affordability.
Togglit Website
  • Name
  • Date of Birth
  • Phone Number
  • Email Address
  • Property Address
 So that we can service your account and meet your personal requirements.
Togglit Portal
  • Name
  • Date of Birth
  • Phone Number
  • Email Address
  • Property Address
 So that we can service your account and meet your personal requirements.
Debt Recovery Agencies
  • Name
  • Date of Birth
  • Phone Number
  • Email Address
  • Property Address
 To manage your accounts effectively.

What we do with your personal data

We are required by law to always have a ‘lawful basis’ (meaning a reason or justification) for processing your personal data. There are a number of these set out in data protection law. We consider the following to be most relevant to our processing of your personal data:

  • The processing is necessary to comply with a legal obligation (“Legal Obligation”).

  • The processing is necessary for the purposes of legitimate interests pursued by us or third party, and these are not overridden by your interests or fundamental rights (“” (“Legitimate Interest”).

  • The processing is on the basis of your consent (“Consent”).

The table below sets out the purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.

Purpose Processing Detail Lawful Basis
Debt Management

We manage debt owed through a debt collection agency network.

We also receive payments and set up repayment plans through an online payment service offering.

We use the data we hold to understand customers’ financial positions.

Legitimate Interest
Data Management

Personal data we receive is reviewed for any irregularities to ensure the data we hold is as accurate as possible.

Where permitted, we check the data against other sources to validate the information.

Legitimate Interest
Contact Information We use the personal data we hold to communicate with you. Legitimate Interest
Legal Requirements Personal data may be used in line with our legal obligations such as enforcing our legal rights or complying with a court order. Legal Obligation
Regulatory Requirements We may share, or hold, your personal data to meet the requirements of the FCA regulations or permissions. Legitimate Interest
Marketing and Support With your consent, we may use your personal data to send you information regarding new products or services that may suit your needs. Consent

Who we share your data with

The details of organisations who we currently share personal data with can be found here:

  • Credit Reference Agencies and other data providers: We share debt account information with Credit References Agencies and other data providers to validate and append additional information related to an individual’s debt account.

  • Creditor Clients: We work with creditors to validate outstanding debt to ensure the debt amount is correct.

  • Insolvency Practitioners and Trustees: We receive requests from Insolvency Practitioners and Trustees to assist consumers in managing debt. Through your authorisation, we work with these entities to help consumers eliminate debt.

  • Debt purchasers: We help clients understand how to best manage debt portfolios and facilitates the sale of these portfolios.

  • Public bodies, law enforcement and regulators: The police and other law enforcement agencies such as public bodies like local and central authorities and our regulators, can sometimes request us to supply them with personal data. This can be for a range of purposes such as preventing or detecting crime, fraud, apprehending or prosecuting offenders, assessing or collecting tax, investigating complaints or assessing how a particular industry sector is working.

  • Processors: We use other organisations to perform tasks on our behalf (for example, IT service providers and call centre providers). Examples include:

    • Debt Collection Agencies (DCAs): We work with agencies to engage consumers and facilitate the repayment of debt. All these agencies operate and retain data within the UK.

How we store your personal information

Your information is securely stored.

We are based in the UK, and we keep our main databases there. All information and personal data held by us is stored on encrypted services at a secure physical location (whether these be our own servers or those of cloud service providers that we use). We also have internal policies and controls in place to ensure that personal data is kept secure to minimise the risk of any personal data being lost, misused, disclosed or accidently destroyed.

How long we keep your data for

We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which we are processing it. For example, we will typically retain personal data for so long as customers receive those services and for a period of up to 6 years following closure of a debt account.

In some cases, it may be necessary for us to retain your personal data for different periods. The factors that direct how long we will retain personal data include the following:

  • Any laws or regulations that we are required to follow;
  • Whether we are in a legal or other type of dispute with each other or any third party.
  • The type of information held about you;
  • Whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.

Requesting for your personal data to be deleted

You have the right to submit an objection about the processing of your personal data to us.

In specific circumstances, you have the right to request that your personal data is erased, however this is not an absolute ‘right to be forgotten’. You only have a right to have personal data erased and to prevent processing if one of the below conditions applies

  • Where the person data is no longer necessary in relation to the purpose for which it was originally collected/processed
  • When the individual withdraws consent
  • When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing
  • The personal data was unlawfully processed
  • The personal data must be erased in order to comply with a legal obligation
  • The personal data is processed in relation to the offer of information society services to a child

If one of the above conditions applies, we will erase your data from our systems.

Marketing Activities

You also have the right at any time to unsubscribe from any direct marketing activity undertaken by us.

You may withdraw your consent for your personal data to be used for further marketing activity at any time by contacting us using the details provided in Section 1.

How we dispose of your information

We have an obligation to dispose of personal information in a secure manner. Where a retention period has expired personal information held on computer hard drives and approved external storage media will be wiped with a suitable software tool.

What are your rights in relation to your personal data

Under data protection law, and subject to certain limitations or exemption, you have the right to:

  • Access your personal information and ask us for copies of your personal information.

  • Ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete

  • Ask us to erase your personal information in certain circumstances.

  • Ask us to restrict the processing of your personal information in certain circumstances.

  • Object to the processing of your personal information in certain circumstances.

  • Ask us to transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Will we make decisions about you

In relation to scoring, automated decisions will be made in consultation with our clients regarding how best to engage with you. These decisions inform which agency would be the best fit for you, if any, based on your current situation. We also consider the best method of communication with you, what type of contact should be made, and how frequently.

Restricting our use of your personal data

In some circumstances, you can ask us to restrict how they use your personal data. Your rights are set out at Article 18 of the GDPR.

This is not an absolute right, and your personal data may still be processed where certain grounds exist. This is:

  • With your consent;
  • For the establishment, exercise, or defence of legal claims;
  • For the protection of the rights of another natural or legal person;
  • For reasons of important public interest.

Only one of these grounds needs to be demonstrated to continue data processing. We will consider and respond to requests we receive, including assessing the applicability of these exemptions.

How to complain about our use of your personal data

If you have any concerns about our use of your personal information, you can make a complaint to us at:

Name: Data Protection Officer

Address: Qualco UK, Building 1, The Heights, Wellington Way, Weybridge, KT13 0NY

Phone Number: +44 20 3398 0200

E-mail: dataprotection@qualco.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

  • Wycliffe House
  • Water Lane
  • Wilmslow
  • Cheshire
  • SK9 5AF

Helpline number: 0303 123 1113

ICO Website: https://www.ico.org.uk

Changes to this privacy notice

We may change this online privacy notice in the future. If we make changes to this online privacy notice, it will post the revised privacy notice and its effective date on this website.

Date of Privacy Policy: MAY 2024

Privacy Policy Terms & Conditions Cookie Policy Complaints Process