Privacy Policy

Introduction

Money Wellness is a trading name of Gregory Pennington Limited (Company Registration Number 02855061). Money Wellness respects your privacy and is committed to protecting your personal data. This privacy policy applies to you if you provide your personal information to us.

If you click on a link that takes you to a third party website that is not ours we will not be responsible for how they use your personal data. We encourage you to read the third party’s own privacy policy to understand how they may use your data.

Information we collect What we collect and why Purposes for collecting your information Keeping your data up to date When we may contact you Who we share your information with and why How we hold your information Your rights Cookies Complaints Contact Us Changes to this policy

Information we collect

We collect your information in a number of ways:

when you make an application or enquiry to us;
from a third party about your existing relationship with them (e.g. a creditor providing information about an account you hold with them);
from a third party where you have previously agreed for your information to be shared with us (e.g. if they introduced you to us);
when you submit reviews or interact with us using social media;
when you use our online platforms (e.g. the customer app);
when we obtain up to date information about you to meet our legal or regulatory obligations;
when you participate in our market research, competitions and promotions; and/or
where you have given permission for your information to be provided to us.

We will usually ask you to take positive action to confirm your consent. This may be obtained either verbally or electronically (e.g. through the use of unticked, opt-in boxes).

What we collect and why

Personal details (e.g. name and date of birth)

to provide suitable initial and ongoing debt advice based on your financial circumstances.
so we can administer your debt solution.

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

to contact you about the product / service we are providing you with.
to act as an identifier with your creditors.

Income and expenditure

to provide suitable initial and ongoing debt advice based on your financial circumstances.
to determine a sustainable, affordable payment amount for your debt solution

Details about your debts, your creditors and other people you owe money to

to provide suitable initial and ongoing debt advice based on your financial circumstances.
so we can administer your debt solution.

Personal circumstances (e.g. employment, living arrangements, property, assets and dependents)

to provide suitable initial and ongoing debt advice based on your personal circumstances.
so we can administer your debt solution.

Special personal information (e.g. physical or mental health, sexual orientation, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data).

to provide suitable initial and ongoing debt advice based on your personal circumstances.
to enable us to better support you with our service.

Financial details (e.g. bank account details)

to collect your payments and administer your debt solution.

Credit reference agency data

to confirm certain information, including your lenders, balances, account numbers, address, insolvency history and details of judgments made against you (e.g. CCJs). Your credit file data will be provided by TransUnion International UK Limited (trading as TransUnion), subject to passing their authentication process. For more information about how TransUnion uses and shares your credit file information, please click here.

Your use of our websites, products and services

to help us understand you better and tailor our service to you.

Information about other people (e.g. when a joint application is made)

to provide suitable initial and ongoing debt advice considering your individual and joint circumstances.
so we can administer your debt solution.

Your calls with us

for training, development, monitoring and quality purposes.
to meet our legal and regulatory obligations.

Purposes for collecting your information

We will only use your personal information where it falls into at least one of the following categories:

it is necessary to enter into or fulfil an enquiry or a contract we have with you;
you have provided your consent;
it is considered to be a legitimate interest;
we have a legal or regulatory obligation to do so;
it is necessary to carry out a task which is in the public interest;
it is necessary to protect your vital interests; or
it is not against your rights.

The reason we collect information from you depends on the product or service:

initial Application/Advice: Where you make an application or enquiry for one of our products or services we’ll use your information to provide you with appropriate information about any solutions we may be able to offer to you. If you cannot provide this information we may not be able to progress with your application or enquiry. We may also use this information to contact you about and process your application.
Ongoing Services: Where we are providing you with a debt solution, (e.g. a Debt Management Plan, Debt Relief Order, Debt Settlement, Breathing Space or any other financial services solution), we will process your personal information to administer the solution. We will normally require you to agree to terms and conditions for our ongoing solutions and services. These will set out how we will provide the services to you and where we will be required, under the terms and conditions, to process your personal information.
Websites and Marketing: To help us understand you better and provide you with information about other products which may be suitable and relevant, we may use your personal information to create a profile of you and your circumstances. This allows us to provide more relevant, accurate and tailored services to you. If you don’t want us to profile your personal information in this way, you can contact us to let us know.
Reviews and Market Research: Where we have a copy of your personal information we may contact you to ask you to provide a review about the services you’ve received or where we are carrying out market research which may help us design future products and services or to help improve our current services. Although this information would really help us, you wouldn’t be required to provide us with this information unless you were happy to.
Legal or Regulatory Obligation: We are required to process your personal information where we have a legal or regulatory obligation to do so, (e.g. to adhere to anti-money laundering obligations).
Funding Obligation: We are required to process your personal information where we have an obligation to do so under any government funded contracts awarded to us.
Responding to Complaints or Enquiries: If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint or deal with the enquiry.
Internal Analysis: As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis. We will use as little personal data as we can to achieve this. We may also share this analysis with third parties who provide us with services and where we have a contractual obligation to do so.
Automated Decision Making: An automated decision is one which we rely on a computer or system to assess the information you provide to us to make a decision about you. This may include: assessing your eligibility for a product or service; detecting any fraudulent activity which may be taking place, or there is a risk that it could take place; or checking identity and residency statuses. If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. If you want to do this you’d need to contact us, or use the contact information which will be provided to you once you’ve received the automated decision.

Keeping your data up to date

It is important that the information we hold about you is accurate and current. Please keep us informed if your personal data, including your contact details, change during your relationship with us.

When we may contact you

Servicing
To help us keep you up to date about the products and services that we provide to you, and to ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text message, push notification, social media, any online customer platforms or other electronic means.

Following an enquiry or after we have provided you with debt advice, we, or one of our group companies (also known as partners), will contact you to discuss this enquiry or debt advice and associated debt solutions until you have entered into a debt solution.
If you start an application for a product or service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.

If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing an ongoing solution or service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement. If you do not provide us with an acceptable method of communication, we will not be able to provide our services to you.

Marketing
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 provide which we think you may be interested or that may benefit you. We may do this by letter, telephone, email, text message, push notification, social media, any online customer platforms or other electronic means.
You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing us at [email protected] or unsubscribing using the link or information within the message.

Who we share your information with and why

Companies you owe money to (e.g. creditors and debt collectors)

to arrange a payment arrangement so we can administer debt solutions for you.

Our group companies

to ensure you receive a seamless customer journey and have access to a wider range of products and services.

Debt solution regulators (e.g. the Insolvency Service, the Official Receiver, the Accountant in Bankruptcy and the DAS Administrator)

to submit applications for debt solutions on your behalf.
to administer debt solutions for you.
for quality and oversight purposes.

Debt solution providers

to help you enter into a suitable debt solution where we do not administer them ourselves.

Technology service providers

to provide technological platforms and development together with other support services.

Payment service companies

to process transactions for us (e.g. direct debit and card payments).

Printers

to print letters and information packs for us to send to you.

Advertisers and social media companies (e.g. Facebook, Google and Twitter)

to promote our services, to provide updates and to share any news and promotional updates.
we may collect personal information from social media platforms (e.g. 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.

Third parties who may have introduced you to our services

to inform them about what debt solution we have recommended and whether you choose to use our services.

Open Banking providers

so your banking information can be shared with us to help us provide you with our products and services.

Credit Reference Agencies

to obtain information about your financial history or your credit commitments so we can provide you with suitable products and services.

Customer feedback platforms

to help improve our current services.
to help us design future products and services.

Third parties who are acting on our behalf (e.g. providing outsourced services)

so we can ensure our products and services are efficient and of a high standard.
to help improve our current services.
to help us design future products and services.

Money and Pensions Service (MaPS)

to meet our obligations in regards to the services we provide. There may be instances where we are joint controllers of your data with MaPS. This means that we will jointly determine the purpose and means of processing your data. We will ask for you to consent to us sharing your data with MaPS.

Our regulators (e.g. the Financial Conduct Authority, the Insolvency Service, the Information Commissioner’s Office or any other regulatory body or authority)

to enable our regulators to sufficiently supervise us.
to fulfil our legal and regulatory obligations.

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 [email protected]

Tracing agents

to obtain up to date contact information to help us to continue to provide our products and services to you.

Professional advisers and insurers

to ensure we continue to provide high quality products and services to you.

Other

to provide our services where we have obtained your consent.
where we are required to do so under a legal/regulatory obligation or court order, such as the police, local authorities or the courts.

We will have a contract in place with any provider who directly provides us direct services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

International Transfers

We will only share your personal information outside the UK, where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the UK.

If we do share your personal information outside of the UK, we will make sure that it is protected in the same way as if it was being used within the UK to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as it would within the UK, or only share the data to a business partner outside the UK or in a non-EEA country where the privacy laws provide the same protection as within the UK or the EEA and where appropriate technical and organisational measures are in place to ensure the data is protected and secure.

More information on this can be found on the Information Commissioner’s Office website.

How we hold your information

Your information is securely stored. We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

security policies and standards;
colleague security awareness;
role based access controls to prevent unauthorised access to information;
encryption and anonymisation technology;
anti-malware technologies;
security monitoring;
security testing;
secure archiving and deletion; and
compliance with industry regulation and legislation.

How long we keep your information for

Whilst you continue to be our customer, we will keep a record of your personal information to ensure that we provide you with a quality service and meet our legal and regulatory obligations. Your personal data will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. We will retain recorded telephone calls for at least 6 years from the date the call was made.

If you do not go ahead with any product or service offered by Money Wellness, your personal information will normally be deleted after 2 years: except for any recorded telephone calls which will be retained for at least 6 years from the date the call was made or where we have another reason to keep your information, for example, if you have given your consent to receive marketing or promotional messages from us.

When your personal information records are due for erasure, we will delete the information or anonymise it so that it cannot be linked back to you.

Your rights

You have the following rights:

1. to be informed about the collection and use of your personal data.

we provide full details of how we use your information in this Privacy Policy.
we may request consent from you to use your information for additional activity.

2. to request access to and receive a copy of the personal data we hold about you.

you may make a subject rights request at any time by clicking here.

3. to request that we correct inaccurate personal information we hold about you.

you may request make a request for rectification at any time by clicking here.

4. to request that we delete your personal data.

you may request make a request for erasure at any time by clicking here.

5. to request that we restrict the use of your personal data (for example, not to be contacted in a particular way).

you may request make a request for restriction at any time by clicking here.
If we send you marketing communications and you do not wish to receive these you are able to opt out at the bottom of the communication.

6. to move, copy or transfer the personal data we hold about you (also called “data portability”).

you may request make a request for data portability at any time by clicking here.

7. to object to us processing your personal data.

You may withdraw the consent you have given us to process your personal data at any time by clicking here.

Due to contractual, legal and/or regulatory requirements, there may be instances where we cannot meet your requests. For example, we may need to send you communications or there may be occasions where we are unable to delete the data we hold about you. We will discuss the actions we can take when you make your request.

Cookies

Cookies

The aim of our Cookies Policy is to provide you with clear and thorough information about the cookies that we use on our website, the reasons why we use them and the options you have when it comes to adjusting your cookies preferences, in case you wish to do so.

What are cookies?

Cookies are small text files that are placed in your computer or mobile device when you visit a website. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used.

There are two types of cookies, regarding its lifespan:

Temporary Cookies: these cookies form part of the security process and expire when you close your web browser;
Permanent Cookies: these cookies stay in your device for a longer period or until you manually delete them;

Regarding the Entity that sets the cookies, there are two types of cookies:

First-party Cookies: these are cookies set by the website that you are visiting, either by us or by a third-party at our request;
Third-party Cookies: these are cookies set by a third-party rather than the provider of the website that you are visiting;

What cookies we use and why?

View your cookies here.

Disabling/Enabling Cookies

You have the ability to accept or decline cookies by modifying the settings on your browser and by clicking on the link below. Please remember though that disabling certain cookies may affect the functionality of our website.

Manage your cookies here.

Further information on the use of and managing cookies can be found at allaboutcookies.org

Complaints

If you wish to make a complaint about how we use your information, you may find our Complaints Policy (here) helpful. Alternatively, you can contact our Data Protection Officer in the following ways:

Email: [email protected]
Post: Data Protection Officer, Money Wellness, Think Park, Mosley Road, Trafford Park, Manchester, M17 1FQ

We have a legal and regulatory obligation to deal with your complaint appropriately.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues in the following ways:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113
Website: www.ico.org.uk

We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

Contact Us

If you have any questions about how we may use your personal information you can contact us on the details below:

Email: [email protected]
Post: Money Wellness, Think Park, Mosley Road, Trafford Park, Manchester. M17 1FQ
Phone: 0161 518 8282

Changes to this policy

We will occasionally update our privacy policy. We encourage you to periodically review our policy to be informed of how we use your information.

This privacy policy was last updated 01/02/2023.