This privacy notice applies to processing activities carried out by Polonius Limited. The purpose of this privacy notice is to explain how we collect and use your personal data. In this privacy notice ‘we’ ‘us’ or ‘our’ are references to Polonius Limited. Polonius Limited is a data controller in respect of personal data that we process in connection with our business, which is a debt purchase company.

The personal data we collect and process

The categories of personal data we collect and process are:

  • Basic personal information such as your name, gender, address history, date of birth, telephone number(s), email address;
  • Information about your family and personal circumstances (such as marital status and dependents);
  • Details of your income and expenditure;
  • Details of your employment status and/or benefit awards;
  • Photographic identification such as a passport and/or driving licence;
  • Current and historic financial information including account details, transactional history and outstanding balances;
  • Banking details such as an account number and sort code;
  • Details of health and medical conditions but only where you have given explicit consent.

Why we collect and process personal data

We collect and process personal data for the following reasons:

  • To help us manage your account (for example, to recover debts you owe to us or to trace you if we need to);
  • To check your details and information you have provided us with;
  • To confirm your identity;
  • To share information about you and how you manage your account and repayments with a credit reference agency;
  • If we suspect or identify fraud, money laundering or any other criminal activity;

How we obtain personal data

We obtain personal data from a number of sources which include:

  • Information you supply to us;
  • Information if you have previously had an account with us;
  • Information that we acquire through our relationship with you and the way you operate your account such as repayments;
  • Information supplied by the company we purchased your account from;
  • Information obtained from a credit reference agency.

The credit reference agency used by Polonius Limited is Experian. If you would like a copy of the information held by Experian, you can get in touch by:

  • Writing: Customer Support Centre, Experian Ltd, PO Box 9000, Nottingham, NG80 7WF
  • Calling: 0800 013 888 or 0344 481 0800
  • Online: www.experian.co.uk

Credit reference agencies retain a record of the enquiries we make and may record, use and supply the information we give them. This information may be used by other lenders, insurers and other organisations. We, law enforcement agencies and other organisations may also access and use this information to prevent and detect fraud, money laundering and other criminal activity.

The three main credit reference agencies Callcredit, Equifax and Experian use and share personal data they receive with each other. For more information please refer to the Credit Reference Agency Information Notice (CRAIN): https://www.experian.co.uk/crain/index.html

Sharing your personal data with third parties

We may share your personal data with third parties such as:

  • A third party nominated by you, who acts on your behalf such as a relative, advice agency, debt management company or legal representative;
  • Details of your account information and transactional history with a credit reference agency;
  • A third party who acts as our agent such as a debt collection agency, or our legal representative;
  • A lender if we transfer or sell our rights to the agreement to another lender or debt purchase company;
  • A third party where we are required by law such as enforcement agencies, juridical bodies, government entities, tax authorities and regulatory bodies.

How long we will keep your data for and how we will protect it

If we purchase your account from another lender or debt purchase company, we will retain your personal data for six years from the date your account is settled, or six years from the date your account is sold to a third party, or longer is required to do so by a regulator or law. This will help us answer any enquiries or resolve any complaints you may have. After this period, your personal details will be deleted or anonymised.

Data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical and organisational measures.

Your data rights

If you wish to exercise any of your data rights please contact us using the details stated at the end of this privacy notice.

  • Access – You have the right to access the personal data we hold about you.
  • Rectification – You have the right to rectify inaccurate personal data we hold about you. If personal data is incomplete taking into account the purposes of the processing you also have the right to have incomplete data completed. If any personal data has been disclosed to a third party, such as a credit reference agency we will also inform them that the personal data has been rectified.
  • Erasure – In specific circumstances, you can ask us to delete your personal data. If the processing of your personal data is necessary for compliance with a legal obligation or the establishment, exercise or defence of legal claims we will not be able to delete your personal data.
  • Restriction – In specific circumstances, you have the right to restrict processing of your personal data.
  • Portability – Where technically feasible you have the right to have your data transmitted by us to another data controller.
  • Objection – You have the right to object to us processing your personal data, unless we can demonstrate compelling and legitimate grounds for processing, which may override your own interests, or where we need to investigate and protect us or others from legal claims.
  • Withdraw consent – Where you have given consent to the processing of your personal data you have the right to with your consent at any time. This will not affect the lawfulness of processing which is based on consent prior to your withdrawal.
  • Complaints – If you wish to raise a complaint about how we have handled your personal data you can contact us directly. We hope that we can address any of your concerns you may have, but you can contact the Information Commissioner’s Office (ICO) if you wish. The ICO helpline is 0303 123 1113 or refer to their website www.ico.org.uk

How to contact us

Our contact details are:

Address: Polonius Limited, Level 5, Mill Court, La Charroterie, St Peter Port, Guernsey, GY1 1EJ
Telephone: 0800 022 6614

Privacy Notice: 18 March 2019