Website Usage Terms
These terms explain the basis upon which you can use our website and also explains how we use any personal information that we collect about you when you use this website. By using our website, you are bound by these terms.
Use of our website
You must only use our website for the legitimate management of an account.
You must not:
- Tell anyone your username or password, unless we specifically agree that you can do so;
- Give us false information;
- Try to log in as someone else;
- Try to access or copy the data of another person or organisation;
- Use our website for any illegal, unlawful or immoral purpose;
- Try to bypass our security measures; or
- Create or access an account for someone else, unless we specifically agree that you can do so.
We may cancel or deny your access to our website at any time. We shall endeavour to provide you with our reasons for doing so, but there may be circumstances where we are unable or unwilling to do so.
Disclosure of passwords
You are responsible for keeping any username and password confidential. If you believe that your password has been disclosed, you must change it immediately. If you believe someone has unlawfully accessed your account, we ask that you inform us immediately.
Cookies are text files placed on your computer to collect standard internet log file information and visitor behaviour information and typically may be used to store information that would enable a website to improve your overall experience, for example by being able to remember who you are and where in our website you have visited. In many cases, a website needs to use a cookie in order to function correctly. There are different types of cookies, two of the most commonly used ones are as follows:
Session Cookies - these cookies are present on your computer only for the time that you are visiting our website that creates them. It is deleted when you close your browser. Session cookies are generally used to ensure that a website functions correctly.
Persistent/Analytical Cookies - these cookies remain on your computer after you visit our website that creates them, but do expire after a set length of time. A persistent cookie would be used to store information that would enable a website to later more optimise your viewing experience, or to gather information for statistical purposes. Whilst persistent cookies remain on your computer after your browser is closed, they can be manually deleted if required.
We use two different cookies on this website, as follows:
- A Session Cookie is used so that our website may keep track of which Robinson Way web server you were connected to when you first loaded our website. Many websites including this website use more than one web server to handle and spread the traffic. It is important for our website to be able to know which web server is dealing with your traffic and so the session cookie contains this information.
- An Analytical (Persistent) Cookie is used by our live web chat system to hold a unique code that enables us to recognise your previous visits. If you have used the chat service before then we may be able to recall previous chats so that your interaction with us is easier, At no time is any private information about you held in this cookie, nor can it be used to track your visits to other websites or any other activity.
- Use of these cookies can be prevented at any time by altering the cookie settings within your applicable browser. However, functionality of this website will be impaired as a result.
- If you wish to prevent cookies from being placed onto your machine by this website, but either cannot or do not wish to implement the measures as suggested above, then please refrain from using this website.
Who are we and what do we do?
Robinson Way Ltd is part of the Hoist Finance AB (publ) group of companies. Robinson Way Ltd services your account on behalf of our clients, your data controller (as named in your original hello letter), with regards to debt collection, debt administration, exercising the rights of the lender, and processes associated with servicing credit. Our contact details and information on how you can get in touch with us are set out at the end of this privacy notice.
What information do we hold, why do we process it & how long for?
In our role as servicer, we use your information only for the purposes of debt collection, debt administration, exercising the rights of the lender, and processes associated with servicing credit. This could be to enter into a dialogue to agree on an appropriate payment plan or for us to better understand your individual circumstances.
In order to pursue the above purposes and to service your account appropriately and fairly, we process the following categories of information, always subject to strict technical and organisational measures, such as access rights and encryption, to keep your information secure:
|Type of information||Reason for processing||Legal bases for our processing of your information||How long do we hold your information for|
Contact and account information, including your name, address, and details of previous communication with us, for example records and recordings of telephone calls, emails, and mailings.
To be able to contact you, keep records of any previous conversations or correspondence and in general keep a full and up to date understanding of your circumstances with regards to your dealings with us.
The Legal basis for processing this information is based on the legitimate interests we pursue being the servicing of the credit arising under the original credit agreement, to which our client (noted in your hello letter) is the controller and has appointed Robinson Way Ltd as processor.
Once your account has been returned to our client, satisfied or unsatisfied, we will hold your data to comply with legal obligations to which we are subject, such as Anti Money laundering legislation and DISP (Dispute Resolution Rules).
7 years from when account is closed with a zero balance, at which point it will be deleted or anonymised (excluding call recordings, which are deleted after 12 months from when the call took place). This is the default position for Robinson Way Ltd. If our client, your data controller, requires us to reduce or increase the time period we hold your data, this can be accommodated. Please contact us using the details below if you wish to know more about how long we will hold your details specifically.
Payment information, including your bank account & sort code.
To be able to process payments in accordance with when you have asked these to be taken and provide refunds if required.
7 years from when the account is closed with a zero balance, at which point it will be deleted. This is the default position for Robinson Way Ltd. If our client, your data controller, requires us to reduce or increase the time period we hold your data, this can be accommodated. Please contact us using the details below if you wish to know more about how long we will hold your details specifically.
Litigation information, including court information and the specific outcomes and costs.
As part of our collection strategies we may take litigation action against you. You will be notified prior to any action being taken, but in the event it is, we will hold up to date and relevant information on all actions and outcomes so to be able to provide you with the best level of service possible.
7 years from when the account is closed with a zero balance, at which point it will be deleted or anonymised. This is the default position for Robinson Way Ltd. If our client, your data controller, requires us to reduce or increase the time period we hold your data, this can be accommodated. Please contact us using the details below if you wish to know more about how long we will hold your details specifically.
Credit reference information, including historical addresses, credit application data, and CAIS information.
We require this information to help form a better understanding of your circumstances as well as to improve the accuracy of the information we may already hold.
7 years from when we acquired the information from the CRA, at which point it will be deleted or anonymised.
Sensitive Information, including that regarding your health or any other factor that may have an impact on your ability to deal with us.
We are required by the UK’s Financial Conduct Authority, the FCA, to take steps to understand the personal and financial circumstances of our customers so we can provide the most appropriate and fair outcomes. This includes information of circumstances which may make our customers more susceptible to detriment. Therefore, the processing of sensitive information can be crucial to protecting the interests of our customers.
This sensitive information will only be processed with your consent, except only in exceptional circumstances to be able to protect your interests where it would be unreasonable to expect you to provide this information yourself. You have the right to withdraw this consent at any time.
7 years from when account is closed with a zero balance or when consent is removed, whichever comes first, at which point it will be deleted or anonymised. This is the default position for Robinson Way Ltd. If our client, your data controller, requires us to reduce or increase the time period we hold your data, this can be accommodated. Please contact us using the details below if you wish to know more about how long we will hold your details specifically.
Where do we get the information from?
We initially receive the information from the current owner of your account, our client.
However, we also get information directly from you, such as when you talk to one of our agents or send us a letter, email or text providing us with your new address, payments details or circumstances.
Finally, we may also obtain information from third parties in order to increase the accuracy of the information we hold and/or to gain a better understanding of your circumstances. These third parties are credit reference agencies, the Land Registry, and other organisations which provide services to improve the quality of the data we hold about you.
We may also retain records of your access to, and use of our website to enhance your experience. Please see the cookies page for further information.
Disclosure of your information
We do not disclose your information except in the following limited circumstances, which we believe you will understand:
We may share your personal information within the Hoist Finance AB (publ) group of companies, to which we belong. For example, our IT infrastructure is managed at Group level. They help to keep our systems operational and secure allowing us to provide the best services to you that we can.
We may share your personal data with carefully vetted organisations, which must comply with our strict security and privacy requirements and follow our guidelines, for the following purposes:
- To assist us in managing your account and/or maintaining accuracy of the information we hold about you. Examples of this are data aggregators, to gain more up to date and accurate information, and businesses that carry out satisfaction surveys to better our service..
To provide us with specialised services to run our business. For example, third parties that we use to print and send letters or digital communications and help us run efficient and secure IT infrastructure. Finally, we may also disclose your personal information to third parties:
- In the event we as a business are purchased, in which case we may disclose your personal data to the prospective buyer of such business.
In the vast majority of cases, your information will be kept within the EU/EEA. Only for limited purposes may data temporarily be processed from outside the EU/EEA. This is where the support teams of our service providers are located outside the EU/EEA to provide 24/7 technical support. In all cases, we have technical, organisational, and contractual protections in place to keep the information safe and to ensure an adequate level of protection. Such transfers will be subject to standard data protection clauses adopted by the European Commission, a copy of which may be obtained by contacting us.
Your statutory data protection rights
As a data subject you have the following rights regarding your information that we hold;
Right to access: You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please request this from us directly. We will respond within one month of your request being received. All requests for information will be free of charge unless deemed by us to be unfounded, excessive, or for further copies of the same information. Any fee will be based on the administrative costs of providing the information.
Right to rectification: We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We may ask that you provide reasonable proof to verify your request.
Right to restrict processing: If you believe the personal information we hold is inaccurate, unlawful, or that we do not have legitimate interest to process it, you can request that we restrict any processing until this is rectified.
Right to object to processing: Where your particular situation merits that we do not process your information for the performance of a task carried out in the public interest or based on our legitimate interest, you have the right to object to the processing.
Right to data portability: This right allows you to obtain in a structured, commonly used format, and reuse the information you have provided to us for your own purpose and have it transmitted directly to different services. This applies only to information we use based on your consent or on basis of a contract.
Rights related to automated decision making & profiling: You have the right to safeguards against the risk of potentially damaging decisions being taken without human intervention. This right applies where a decision is based solely on automated processing and produces a legal effect or similar significant effect. If this is the case we must ensure you are able to obtain human intervention, express your point of view, and have the opportunity to challenge it. We will also explain the logic behind the decision.
Profiling is defined as any form of automated processing intended to evaluate certain personal aspects of an individual to analyse or predict aspects of their personal circumstances behaviours or abilities. Processing must be fair and transparent, use appropriate mathematical or statistical procedures, use appropriate controls to minimise inaccuracies and secure personal data.
As part of our collections strategies we may profile you and take automated decisions when looking to litigate. Any litigation action, if successful, will show on your credit rating and could impact your ability to obtain new credit in the future. You will always be notified by letter to the current address we hold before any litigation action is taken. If you disagree with this actions or wish to know more please contact us using details on the letter provided or use the link to contact us.
Right to erasure (“right to be forgotten”): You may ask us to delete the information we hold on you where it is no longer necessary for the purpose for which it was collected, where you withdraw any consent you provided for its processing, where you object to our processing of it (see above), or where our processing is unlawful. Please note, however, that we are also subject to certain legal obligations that prevent us from immediately deleting all of your information. For example, we legally obliged to keep certain data for anti-money laundering purposes for at least five years. However, any data we are prohibited from deleting will be blocked and erased after we are no longer obliged to keep it.
Right to lodge a complaint: You have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office: https://ico.org.uk/.
Changes to these terms and our privacy notice
We keep these terms and our privacy notice under regular review and we may change or update this privacy notice at any time. Where we make any changes to our approach to data protection or the way in which we use your data, we will place any updates to this notice on our webpage. Please visit this webpage on a regular basis to see if there are any updates to this policy.
How to contact us
You may also directly contact our Data Protection Officer, our Head of Risk & Compliance, using the contact details above or by the following email: firstname.lastname@example.org