Arkle Insolvency Limited ("we", "us") is committed to protecting and respecting your personal information. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting www.arkleinsolvency.co.uk you are accepting and consenting to the practices described in this policy.

DATA CONTROLLER
Arkle Insolvency Limited, The Granary, 50 Barton Rd, Worsley, Manchester M28 2EB, United Kingdom.

WHEN WE MAY USE YOUR PERSONAL INFORMATION (LAWFUL BASES)
We only use personal information when we have a proper reason to do so. This may include sharing it outside Arkle Insolvency Limited. The law says we must have one or more of these reasons:
• To fulfil a contract we have with you;
• When we have a legal duty;
• When it is in our legitimate interests (and your rights do not override those interests);
• When you have given consent.

PURPOSE OF PROCESSING
We process your data to assess your financial position, advise you on the best solutions for your circumstances and, where appropriate, administer the chosen solution.

OUR LEGAL BASIS
We process your personal data to provide our services under a contractual (or pre-contractual) obligation. Once an Insolvency Practitioner is appointed, we also process personal data to comply with the law and therefore have a legal duty to use your personal information.

We rely on our legal obligations under the Insolvency Act 1986 and its subordinate legislation (as amended from time to time), and the Insolvency (Northern Ireland) Order 1989 and its subordinate legislation.

The information we hold about you comes from a variety of sources.

DATA YOU GIVE US
• When you apply for or enquire about our services
• When you speak to us on the phone
• When you use our website
• In emails and letters

DATA FROM THIRD PARTIES WE WORK WITH
• From sub-contractors (technical, payment, delivery), advertising networks, analytics providers, and search-information providers
• From other websites/services we operate — where we told you at collection that we may share and combine that data, and for what purpose
• From authorised third parties such as partners, civil partners, spouses, friends or relatives assisting with our services to you
• From other organisations such as credit-reference and fraud-prevention agencies
• Identity verification via online searches
• Creditor and bank statements, and publicly available sources (e.g., Land Registry, local council websites, valuation websites)

INFORMATION WE COLLECT AUTOMATICALLY (WHEN YOU VISIT OUR SITE)
• Technical details: IP address, browser type and version, time-zone setting, browser plug-ins, operating system and platform
• About your visit: full URLs and clickstream to/through/from the site (including date and time), products you viewed or searched for, page response times
• Diagnostics & interactions: download errors, time spent on pages, interactions (scrolling, clicks, mouse-overs), how you navigated away from a page, and any phone number used to call our customer service team

On our website we use cookies to recognise you from other users. This will allow us to provide a good experience and help improve the website.

We use Facebook for paid advertising.  When you visit this site by that channel, a cookie is stored on your device (subject to your privacy settings), which allows us to re-target you with ads once you leave this site and visit other websites which use Facebook to display ads.

We use Google for paid advertising.  When you visit this site by that channel, a cookie is stored on your device (subject to your privacy settings), which allows us to re-target you with ads once you leave this site and visit other websites which use Google to display ads.

We use Bing for paid advertising.  When you visit this site by that channel, a cookie is stored on your device (subject to your privacy settings), which allows us to re-target you with ads once you leave this site and visit other websites which use Bing to display ads.

We may collect and process the following information about you, where relevant:
• Name (including any former names), address and contact details
• Date of birth
• Number and ages of any dependants
• Current and former marital status
• Current and former residential addresses, occupancy and ownership details
• Current and former employment details
• Involvement in any business (e.g., sole trader, partnership, limited company directorships/shareholdings)
• Current and historical banking arrangements
• Current and historical assets, including any disposals
• Current and historical liabilities to creditors
• Current income and expenditure
• Status of any ongoing legal proceedings
• Information and explanations about the circumstances of any insolvency and steps taken to address it
• Current and historical tax affairs

SPECIAL CATEGORIES (ONLY WITH YOUR CONSENT)
• Health information or information about criminal offences — collected only with your explicit consent and only where relevant to your financial circumstances.

The information we hold about you will be used to:
• Enable us to perform our legal obligations under applicable legislation
• Carry out our contractual obligations to provide the information, products and services you request
• Provide service and business updates (including changes to our services)
• Ensure our site content is presented in the most effective manner for you and your device
• Troubleshooting and data analysis
• Provide other services and goods that we offer

MARKETING & THIRD-PARTY COMMUNICATIONS
• We may provide you with information about goods and services similar to those you have purchased, agreed to, or enquired about
• We may provide you — or permit selected third parties to provide you — with information about goods or services we feel may interest you
• If you are an existing customer, we will contact you by electronic means (email or SMS) only about goods and services similar to those previously purchased or discussed
• If you are a new customer, we (or selected third parties) will contact you by electronic means only if you have consented
• If you do not want us to use your data in this way, or to pass your details to third parties for marketing purposes, please tick the relevant box on the form where we collect your data

COMBINING INFORMATION FROM OTHER SOURCES
• Information we receive from other sources will be combined with information we have already received from you

You agree that we have the right to share your personal information with:
• Any member of our group (subsidiaries, our ultimate holding company, and its subsidiaries) as defined in section 1159 of the UK Companies Act 2006
• Third-party companies we sub-contract to so we can fulfil our obligations, including:
– Analytics and search-engine providers who assist with site improvement and optimisation
– Providers that conduct credit searches on our behalf
• (With your permission) The Insolvency Group Limited and J3 Debt Solutions Limited
• These companies must handle your information securely and in accordance with current legislation

DISCLOSURES WE MAY MAKE
• If we sell or buy any business or assets, to the prospective seller or buyer
• Where required to comply with a legal obligation, or to enforce/apply our Terms and conditions of supply and other agreements, or to protect the rights, property, or safety of us, our customers, or others (including sharing for fraud protection and credit-risk reduction)
• If your Individual Voluntary Arrangement (IVA) is approved: it will be published on the IVA Register (run by the Insolvency Service). Details from the Register are shared with credit reference agencies and are open for public inspection

REGULATORY, RECORD-KEEPING & TRANSACTIONS
• We use your information to maintain case records as required by legislation and our Recognised Professional Body (RPB)
• We share data with our RPB to support any monitoring and inspection regime in force
• We process financial transactions (collect payments from you and distribute payments to your creditors)

CRIME & FRAUD PREVENTION
• We have a legal obligation to prevent and detect crime, fraud, and corruption

DATA HANDLING STANDARD
• Your data will be held and processed in accordance with current legislation

DATA SECURITY & STORAGE
The personal data you provide is stored on our secure servers to help protect its integrity and confidentiality. However, no method of transmission or storage is 100% secure. While we take appropriate measures to safeguard your data, we cannot guarantee absolute security.

TRANSFERS TO ASSOCIATES
When you submit your data to us, we may transfer it to our associates. These transfers may be cross-border depending on where the associate is located. This means your data may be processed and stored outside your state or country, where data-protection laws may differ. By agreeing to this policy, you consent to such transfers.

INTERNATIONAL THIRD-PARTY TRANSFERS
Where information is shared with third parties, companies, or sub-contractors located outside the European Economic Area (EEA), we will ensure they handle your data in line with current legislation and maintain appropriate standards of accuracy and security.

RETENTION
We will store the information we collect about you online for the timescales set out below.

RETENTION PERIODS
• We are required under our regulatory framework to retain case files and associated information for 6 years after the Insolvency Practitioner leaves office.
• In some circumstances, we may need to retain information for longer, but only where required by the legislation in force at the time.

IF YOUR APPLICATION DOES NOT PROCEED
• Rejected or withdrawn IVA at a creditor meeting: retained for 6 years.
• No creditor meeting called: retained for 12 months.

At your request, we will tell you what personal data about you is being processed, on what basis, and by whom.

WITHDRAWING CONSENT
• If you no longer want your data processed for one or more purposes, you may withdraw consent.
• We’ll action this as soon as reasonably possible, but it may not take effect immediately and you may still receive communications in the meantime.

RECTIFICATION (CORRECTING YOUR DATA)
• You can ask us to amend inaccurate, incomplete, or outdated personal data at any time (using the contact details below).
• We may ask for evidence to support the changes you request.

ERASURE (“RIGHT TO BE FORGOTTEN”)
You may request that all personal data we hold about you be deleted from our records and erased from information stored by third parties processing data on our behalf where:
• You have validly objected to our use of your personal information; or
• Our use of your personal information is contrary to law or our other legal obligations.
Please note: where we must retain information to perform our legal obligations, those obligations may override all or part of your request.

DATA PORTABILITY
• If your data is processed by automated means, you have the right to receive it in a structured, machine-readable format and to transmit it to another data controller without hindrance.
• This applies only where the lawful basis for processing is consent or performance of a contract.

Under the Data Protection Act, you have the right to access the personal information we hold about you. We will supply this information within 1 month from the date of your request. To make a request, please email: complaints@arkleinsolvency.co.uk
.

Any changes we make will be posted on this page and, where appropriate, we’ll notify you by email. Please check back regularly for updates.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: complaints@arkleinsolvency.co.uk

If you’re unhappy with how we’ve used your personal information, please contact us:
• Phone: 0161 527 7560
• Email: complaints@arkleinsolvency.co.uk

• Post: Complaints Officer, Arkle Insolvency Limited, The Granary, 50 Barton Road, Worsley, Manchester, M28 2EB

COMPLAINING TO THE ICO
You also have the right to complain to the Information Commissioner’s Office (ICO). Learn how to report a concern at www.ico.org.uk