Scotland Debt Relief - Privacy Policy

Thank you for visiting Scotland Debt Relief. We are 0910385 B.C. Ltd., the owner and operator of Scotland Debt Relief (the "Scotland Debt Relief Website"). Your security and privacy are important to us.

Overview

The primary purpose of the Scotland Debt Relief Website is to be a useful resource and guidance tool. We also want you to feel secure when visiting the Scotland Debt Relief Website and we are committed to maintaining your privacy when doing so. We take our ethical responsibilities and your privacy seriously.

This Privacy Policy explains the way we use information that you provide to us in order to offer you with great services. This Privacy Policy will explain the types of personal information we collect, the methods we use to collect and process information, who we may need to share the information with in order to provide you with services, and your rights in regards to the information we collect.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it. You can contact us with questions at the contact details provided below.

This Privacy Policy applies only to your use of the Scotland Debt Relief Website. As the owners and operators of the Scotland Debt Relief Website, we are responsible for the information that you will provide to us, and the manner in which it will be used.

This Privacy Policy does not apply to any third party websites that are linked to from the Scotland Debt Relief Website. We have no control over how your data is collected, stored or used by other websites and we recommend that you check the privacy policies of any such websites before providing any data to them.

What Data Do We Collect?

Broadly speaking, there are two categories of information we collect: (1) information that we must have in order for you to use the Scotland Debt Relief Website; and (2) information that we need to collect on our forms in order to provide you with our service and match you with a debt advisor.

Personal information is gathered from you in two ways: (a) directly (for example if you submit an online form or otherwise supply any personal details to us); and (b) indirectly (for example, through the Scotland Debt Relief Website's technology). We will obtain personal information about you directly (such as your name, email address, phone number, amount of debt, etc.) when you provide this information by completing an online form on the Scotland Debt Relief Website. For example, we will obtain your personal data when you sign up to our e-newsletter, request a free consultation, or contact us for any reason.

Depending upon your use of the Scotland Debt Relief Website, we may collect some or all of the following personal data when you fill in our forms:

  1. Name
  2. Email address
  3. Phone number(s)
  4. Country of residence
  5. Your amount of unsecured debt
  6. Your types of debt
  7. How far behind on bills you are
  8. The number of different debts that you have
  9. Your estimated credit rating
  10. Your employment status
  11. How much you can afford to repay each month
  12. Your residency status (rent/own)
  13. Description of your debt problem

The following information is automatically collected for fraud and security purposes.

  1. Your IP address;
  2. Web browser type and version;
  3. Operating system; and
  4. A list of pages you visit on the Scotland Debt Relief Website starting with the webpage you came from.

What do we do with your personal data?

After you submit the forms on the Scotland Debt Relief Website, the information you provided is stored on servers of our web services provider - Amazon Web Services. Our agreement with Amazon Web Services requires Amazon Web Services to maintain our data in a location in Canada. We will then analyse your data in order to match you with a debt advisor. If we succeed in matching you with a debt advisor, the debt advisor will attempt to reach you by phone, email and/or text message for your free consultation. Here is the process, in more detail:

In our analysis of your data we use the software services of a software vendor of ours - Boberdoo.com, LLC, a company that is located in the United States of America (the U.S.) ("Boberdoo"). Boberdoo is a third-party company that helps us match you with a third-party debt advisor. Because we use Boberdoo's software in our analysis of your data, your data is transferred to Boberdoo's servers. Boberdoo entered into an agreement with us that obligates it to maintain the same standards for data privacy and protection that we maintain. Boberdoo is required to delete or anonymise your personal data immediately after matching you with a debt advisor.

If we can find a debt advisor to match you with, your data will be transferred, through the Boberdoo platform, to one of the following debt companies located in the United Kingdom, and a representative of the debt company will reach out to you directly. These companies are separate third-party companies, which are not controlled by us. The companies also entered into agreements with us, which obligate them to keep your data secure and protected.

You may be matched with Breitrock GmbH, a partner that uses Leadspedia (located in the United States) to securely store and match you with a debt advisor. Breitrock has a 30 day retention policy and will delete or anonymize your personal data within 30 days. Breitrock are under contract with us to keep your personal data secure and protected.

There are additional third-party companies that will have access to your data:

  1. Data8 Limited, a UK company that confirms that you provided a valid phone number. Once your phone number is confirmed, Data8 Limited will delete the data you provided (phone number).
  2. PCA Predict, a service provided by a company called GB Group plc, which helps look up your address. Once your address is inserted, PCA Predict will delete the data you provided (i.e., address).
  3. AnswersWanted Services Inc., a company located in British Columbia, Canada, which provides the Scotland Debt Relief Website with software development, systems admin, and technology support. AnswersWanted Services Inc. may have access to your data in the course or providing services to the Scotland Debt Relief Website.
  4. Amazon Web Services, Inc., a company that is located in the U.S., which provides us with web hosting services and related services with respect to the Scotland Debt Relief Website.

In addition to the information we request on our forms, we will collect your IP address and have it saved on our servers for fraud prevention, analytics and security reasons.

We use encryption when we transfer your data to any third-party company we work with, as described in this Privacy Policy.

All of our third-party partners are required to be in compliance with data protection requirements, as applicable in the UK and EU.

With your permission and/or as permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone or text messages. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that our marketing practices are in compliance with applicable laws.

All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR").

How Long Do We Store Your Personal Data?

Information that you provide using the forms on the Scotland Debt Relief Website is kept for no longer than 90 days from the day you provided the information, after which we will delete or anonymize such data.

For security purposes we will continue to store your email address and IP address after the lapse of 90 days. Your email address, as saved on our servers, will be encrypted, and your IP address will be saved in an anonymized form. Maintaining your email address and IP address is required, among other things, in order for us to be able to comply with some of the requirements under GDPR, relating to your rights to access, restriction of processing, erasure, correction, objection or portability of your data.

What Happens If our Business Changes Hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business be transferred along with the transferred part of the business. The new owner of the business will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us. In the event that any of your data is to be transferred in such a manner, you will not be notified in advance and informed of the changes.

Your Data Related Rights

Under the GDPR, you have certain rights in relation to your data, which include the right to:

  1. Request a copy of the data that we have about you.
  2. Request that we provide you with an electronic copy of the personal data that you have provided us with (data portability).
  3. Request that we correct the data that we have about you.
  4. Request that we restrict our use of your data.
  5. Request to erase your data.
  6. Notify us that you object to particular ways in which we are using your personal data.
  7. File a complaint with the governmental authority in your country which is mandated with regulating data privacy matters (in the U.K. the relevant authority is the Information Commissioner's Office).

In certain circumstances we will not be able to comply with your request. For example, we may have a legitimate interest permitting us not to act as you requested. To exercise your rights, to correct information that we have about you, or to ask questions about your rights, please contact us through the contact details provided in this Privacy Policy.

How Can You Control Your Data?

When you submit information via the Scotland Debt Relief Website, you may be given options to restrict our use of your data. We aim to give you effective controls on our use of your data including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (the "TPS"), the Corporate Telephone Preference Service (the "CTPS"), and the Mailing Preference Service (the "MPS"). These may help to prevent you receiving unsolicited marketing. However, these services will not prevent you from receiving marketing communications to which you gave consent.

You are under no obligation to provide us with any information. However, we do require certain information in order to be able to provide you with our services and connect you with a debt advisor.

To request the removal or correction of your data please complete the form found here. We will do our best to fulfill your request within 7 business days.

To the extent that you gave us consent with respect to the collection and use of your data, such consent can be withdrawn at any time by using this form. We will do our best fulfill to your request within 7 business days.

Removal of data or withdrawal of consent will limit our ability to provide our services to you.

The Legal Basis for Our Use of Your Data

We will process your data, as described in the Privacy Policy, according to one of the following recognized legal grounds for processing under the GDPR:

  1. The processing of your data is necessary for us to provide you with our services in accordance with the contractual relationship between you and us;
  2. The processing of your data is required for us to comply with our legal obligations, including maintaining records which we may legally be required to keep;
  3. The processing of your data is required in connection with our legitimate interests, or those of a third party recipient of your personal data;
  4. The processing of your data is done according to an express consent that you gave us.

Security

We have put in place appropriate and industry-accepted technical and security measures in order to prevent your data from being lost or used without proper authorization.

Cookies

As part of our advertising process some analytics services and advertising networks set cookies and have access to your IP address after you complete our forms. See our "Cookies" policy here.

Your Acceptance of this Privacy Policy

Your use of the Scotland Debt Relief Website indicates to us that you agree with this Privacy Policy.

If you do not wish to accept this Privacy Policy, please leave the Scotland Debt Relief Website immediately.

Contacting us

If you have any questions about the Scotland Debt Relief Website or this Privacy Policy, please contact us by email at [email protected].

You can also send a letter to 0910385 B.C. Ltd., 4720 Kingsway, Suite 2600, Burnaby, BC, Canada, V5H4N2.

In addition, you can contact our EU representative, DPR Group, BPM 335368, at 372 Old Street, EC1V 9AU, London, United Kingdom, [email protected].

In addition, you can contact our Data Protection Officer, Allan Shpeley, at 4720 Kingsway, Suite 2600, Burnaby, British Columbia, V5H 4N2, Canada, [email protected].

Changes to our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on the Scotland Debt Relief Website. We recommend that you check this page regularly to be informed of updates. If we substantially change this Privacy Policy, we will notify you of such changes. Notifications will be sent to you only if less than 90 days had passed since you last used the Scotland Debt Relief Website.

Last Updated: May 21, 2018