Privacy Policy 2018-11-15 12:36:49


Privacy Statement

Introduction

In accordance with Article 14 of the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard the processing of processing of personal data and on the free movement of such data, and repealing Directive 95/EC (hereinafter the ("GDPR"), informs you that the Data Controller of your personal data is Cromwell Insolvency Limited trading as Cromwell & Co Insolvency Practitioners and Liquidations Online (a limited company registered in England and Wales under registration number 10152348, with its registered address being 5 Mercia Business Village, Torwood Close, Coventry, CV4 8HX).

Contact point for matters concerning data protection is Cromwell Insolvency Limited trading as Cromwell & Co Insolvency Practitioners and Liquidations Online (a limited company registered in England and Wales under registration number 10152348, with its registered address being 5 Mercia Business Village, Torwood Close, Coventry, CV4 8HX) Telephone Number: 0800 061 4002 [email protected]

When collecting and using personal data, it is our policy to be transparent about why and how we process personal data. This privacy statement outlines how and why we collect and/or use personal data. It also provides information about your rights. Personal data is any information relating to an identified or identifiable living person. When "you" or "your" are used in this privacy statement, we are referring to the relevant individual who is the subject of the personal data.

By visiting our website, you choose to submit information and agree to the use of such personal data in accordance with the terms set out in this privacy statement.

Third Party Organisations

Our website may contain links to other websites which may not be governed by this privacy statement. Cromwell Insolvency Limited makes no representations or warranties regarding how your information is stored or used on/by third-party servers. We recommend that you review the privacy statement of each third-party website to determine their use of your personal information.

Data Controller

Cromwell Insolvency Limited is a ‘Data Controller'. As such, we are required to inform you how your information is held and used under the Data Protection Act 2018 / General Data Protection Regulation ("GDPR"). If you have a question about how we as an organisation will use your personal data, please email us via [email protected]

Collection of Information

As a visitor, you are not required to submit any of your personal information in order to use our website. However, our website may collect and/or store your personal information that is specifically and voluntarily provided. This information may consist of, but may not be limited to, your name (forename and/or surname), your residential address, your company's / companies address(es), your date of birth, your email address(es), telephone number(s) and any financial information (personal or that of your company) that you voluntarily choose to disclose. Please note that we will not collect any of the above information ("personal data") without your knowledge. We will collect, use, share and store personal data voluntarily supplied by you via our website, telephone, correspondence or by any other means.

In the event that you supply personal data relating to a third party, you confirm that you have obtained their expressed consent for such information to be supplied to us and for it to be used by us.

In running and maintaining our website, we may also collect and process information about your use of our website, including details of your visits, such as pages viewed and the resources that you access. Such information may include traffic data, location data and other communication data.

Use of Personal Data

Your personal data will be processed by us for the purposes of communication, promoting our products and/or services, to comply with legal requirements to prevent and/or detect fraud, money laundering and other crimes, carry out regulatory checks and to periodically send promotional emails to you about our products and/or services. Please note that you will only receive such promotional emails where we have obtained your specific consent of receiving the same. You may at any time request that we discontinue sending you such materials.

In a creditors' voluntary liquidation, a director/majority of directors is/are required under Section 99 of the Insolvency Act 1986 and Rule 6.3 of the Insolvency (England and Wales) Rules 2016 to compile a Statement of Affairs to be presented to creditors and subsequently filed with the Registrar of Companies. If you are an individual creditor, your name and address will be required to be detailed on the Statement of Affairs and circulated to all known creditors. Your name and address will not be filed with the Registrar of Companies if you are a consumer or employee creditor.

In addition, we may use your personal data for one or more of the following purposes:

  • To provide information to you on other products / services that may be of interest to you. Such additional information will only be provided where you have consented to receive such information; and
  • To inform you of any changes to our website, services or products.

Disclosing Personal Information

We do not ordinarily share personal data with third parties, although such information may be disclosed to providers that handle information on our behalf, such as outsourced IT support, document management systems (Windows Microsoft OneDrive), case management systems (Turnkey IPS) and email marketing management systems. Any such third party will be required to take adequate security measures to protect your personal data under relevant legislation. Please note that such third parties are prohibited by us to use your personal data for their own purposes.

In certain circumstances, we may have an obligation to disclose your personal information to law enforcement agencies, regulators or other government agencies, to comply with regulatory and/or legal obligations.

Should we be instructed by you to carry out an insolvency process, such as a liquidation, administration or voluntary arrangement, legislation requires us to undertake an identification check for each director, shareholder and individual. In these circumstances, we will validate your name, address and any other personal information supplied by you with a reputable credit reference agency, such as Callcredit UK, which may keep a record of that information. You should notify us in good time if you do not consent to such a check being made. Please note that a formal credit check will not be performed, and your credit rating will not be affected.

We may also disclose your personal information to the legal purchaser of all or part of our business.

Access to Information

You are legally entitled to request details of the personal information we hold about you. If at any time you would like us to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your personal information is processed by us, access your personal information, exercise your right to data portability or withdraw your consent to processing, please contact us via [email protected]. We aim to respond to any such requests promptly, and in any event, within the legal time frame.

Retention of Personal Information

We will only retain your personal data for as long as necessary in order to fulfil the purpose for which it has been collected and in line with statutory and professional rules of retention. In the majority of cases, we will retain your personal data for a maximum period of six years from the date of disclosure, or for formal appointments, six years from the date the insolvency procedure has been brought to a close.

Right to Complain

If you have any concerns about alleged breach of privacy law or any other regulation by us, you can contact us in writing at Cromwell Insolvency Limited trading as Cromwell & Co Insolvency Practitioners and Liquidations Online, 5 Mercia Business Village, Torwood Close, Coventry, CV4 8HX or by emailing us via [email protected]. We will deal with any complaint promptly and give you information about how it will be handled. You also have the right to lodge a complaint with the Information Commissioner's Office ("ICO") which is the UK's data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website at www.ico.org.uk or by writing to them at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.