This Privacy Notice outlines how Restons Solicitors Limited ("Restons") will use, store and share your personal data.

This Privacy Notice is supplementary to any Privacy Notice issued to you by our clients (the Data Controller in respect of your account) which will govern your personal data. In respect of your personal data, Restons is considered a data processor and reference should be made to the Privacy Notice issued to you by our clients in the first instance.

We will use your personal data fairly and lawfully and in accordance with the EU General Data Protection Regulation ("the GDPR") and Data Protection Act 2018 ("the Act"). For the purpose of the Act, Restons are the Data Processor.

A. Personal data we may collect and use

Where we get your personal data from:

You may share personal data about yourself and your circumstances with us through the use of our website or within telephone calls, emails or otherwise. We also receive personal data about you from third parties such as clients who have instructed us to act on your account.

What categories of personal data we collect:

The personal data that we collect ourselves and receive from third parties may include the following: your name, address, e-mail address, telephone numbers, debt information, payment history, credit reference information and any other information relating to your account.

Also, if you visit our website and/or app we may automatically collect information and personal data about your device for system administration, including where available your IP address, operating system/device identifier and browser type. We do this to help us analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website/app users and to assist us in managing your account.

To find out more about how these cookies are used and to opt-out of being tracked, please see our Cookies Policy found on this website.

Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.

Special categories of personal data:

Some categories of personal data are more sensitive, these are known as special categories of data, for example:

• Ethnic Origin
• Religious Beliefs
• Data concerning physical and mental health

Our clients who are regulated by the Financial Conduct Authority ("FCA") are required by them to understand whether the people we deal with on their behalf could be regarded as vulnerable and this may involve collecting and using special category personal data. We may, for debt collection purposes, therefore ask you to provide details regarding your special category personal data or you may voluntarily give such personal data to us.

If you ever disclose this type of personal data to us we will only keep this on record if it is necessary for the services we are providing. Where we do need to keep this data, we will always request your explicit consent. We may share any of your special category personal data with our clients for debt collection purposes only and again, only with your explicit consent.

If you disclose special personal data to us without us having the opportunity to obtain explicit consent, for example if you send a letter or email to us detailing your medical situation, then it will be deemed that you have given your consent for us to process that data and store it on our systems.

You have the right at any point to withdraw your consent for your special personal data to be held and processed by us. You may contact us by telephone or in writing should you wish to withdraw your consent.

B. How we use your personal data

We may use personal data held about you in the following ways:

1. For debt collection purposes and to manage your account; to tailor repayment plans to your individual circumstances; to carry out obligations arising from our clients purchasing your account; to locate you and to check/update your contact details.
2. To carry out account analysis for ourselves such as to determine whether or not you are likely to repay your debts.
3. To provide services to our clients in relation to debt collection (including to manage your account and to tailor repayment plans to your individual circumstances); analysing your account (such as to determine whether you are likely to repay your debts, assessing affordability and to enable our client to make financial decisions).
4. To administer our website.
5. To improve our website to ensure that content is presented in the most effective manner.
6. To allow you to participate in interactive features of our service, when you choose to do so.
7. To comply with regulatory obligations.
8. To prevent money laundering and fraud.

Please note that as a user of our website, you are responsible for keeping any passwords used to access your personal account information confidential.

If you require further information about the purposes for which we use your personal data then please contact our Data Protection Officer:

By letter: Data Protection Officer, Restons Solicitors Limited, 800 Mandarin Court, Centre Park, Warrington, Cheshire, WA1 1GG.

By email: dpo@restons.co.uk

C. Lawful basis for processing personal data

Our use of your personal data for the purposes set out above is to provide legal services to our clients and therefore it is in our legitimate interest to do so. As indicated above we may also pass your personal data to third parties in order to manage your account effectively, this is also for our legitimate business interests.

Additionally, we will rely on consent when processing special category personal data about you in relation to your health. This will only be in circumstances where you choose to divulge this information to us in order to help us understand your circumstances and therefore appropriately manage your account. You have the right to withdraw your consent for us to store/process your special category personal data at any time.

D. How long will your personal data be kept by us?

We will keep your personal data for as long as we are managing your account on behalf of our client.

We will then retain your personal data for six years from the date your account is closed with us. Please re-visit the Privacy Notice issued to you by our clients to establish how long they will retain your personal data.

E. Disclosure of your personal data to third parties

We may share your personal data with third parties as set out above under the heading "How We Use Your Personal Data".

Restons may also share your personal data with certain third parties as follows:

1. We may share your personal data with third parties who are our clients as set out above under the heading "How We Use Your Personal Data".
2. We may subcontract some of our services to sub-contractors and we may share your personal data with our sub-contractors as data processors.
3. We may share your personal data with our suppliers who provide goods and services to us to enable them to provide these to us. These suppliers are our data processors and may only use your personal data in the way we specify in-line with our client’s instructions - for example companies that provide us with an IT infrastructure or mailing service.
4. We may share your personal data with any person or company that you instruct to act on your behalf - for example a friend, family member, solicitor or a Debt Management Company.
5. We may share your personal data with the courts for the purpose of issuing legal proceedings against you and for any further enforcement that may take place.

We have systems in place to ensure that any personal information you provide to us will be processed in accordance with data protection legislation. Those systems are designed to ensure that such personal information will remain secure and prevent unauthorised access. Your personal information will remain confidential and will not be disclosed unless we are required to do so pursuant to a legal or regulatory obligation/process or disclosure is required to provide a service you have requested.

F. Where we process your personal data

The data that we collect from you will not be transferred to or stored anywhere outside of the European Economic Area ("EEA").

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website.

G. Your rights under data protection regulation

Right of Access

The Act gives you the right to access personal data held about you that we hold. As a Data Processor your request may be forwarded to our client who may contact you to validate the request prior to providing you with the data. This is because both we and our clients take the protection of your data seriously and we want to ensure it is provided to the correct recipient. In order to make this request please contact us on the below details.

Right to Portability

You have the right to request that we transfer your personal data that we hold about you to you or another Data Controller. You can exercise this right by contacting us on the below details.

Right to Rectification

We receive personal data directly from our clients, third parties and directly from you and we are reliant on you and other third parties providing us with correct information. If you believe that any of the personal data we hold is incorrect, it is important that you make us aware as soon as possible. You can exercise this right by contacting us on the below details.

Right of Erasure/Right to be Forgotten

Under data protection legislation you have the right to object to the use of your personal information, or to ask us to delete/remove your personal information if you believe we no longer have a lawful basis to process it. If you feel that we should not be processing your personal data then you can submit this request to the details below.

Right to Restrict Processing

If you believe that we are processing your personal data unlawfully or you believe that we no longer need your personal data then you have the right to request that we restrict the processing of your personal data. You can exercise this right by contacting us on the below details.

How to Contact:

If you have any queries relating to your rights listed above or would like to access your personal data then please contact our Data Protection Officer:

By letter: Data Protection Officer, Restons Solicitors Limited, 800 Mandarin Court, Centre Park, Warrington, Cheshire, WA1 1GG.

By email: dpo@restons.co.uk

H. Cookies

We may also store information about you by using cookies. A cookie is a small file which is downloaded onto your computer (or any other device) when you visit a website. In common with many other websites we use cookies to assist us in operating the website. Cookies enable you to remain logged into the website without the need to re-enter your user credentials/personal data. Cookies help us track website usage when you log into the secure area and display information relevant to you. Cookies will automatically be removed when you log out of the website or close your Internet browser.

You can choose to disable the use of cookies when you visit our website. You can do this through your browser settings. You can find more information about rejecting cookies from www.allaboutcookies.org . However, if you do reject cookies this may prevent you from accessing/using certain sections of our website.

I. Changes to our privacy notice

We reserve the right to amend this policy from time to time and if we do we will bring the new terms to your attention when you visit the site.

J. How to complain

If you would like to make a complaint or have a query about how we use your personal data, you can contact us on the below details:

By letter: Data Protection Officer, Restons Solicitors Limited, 800 Mandarin Court, Centre Park, Warrington, Cheshire, WA1 1GG.

By email: complaints@restons.co.uk

If you are not satisfied with our resolution of your concerns then you have the right to complain to the Information Commissioner’s Office. Their contact details are as follows:

Address: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk