Hudson Weir Ltd is the company providing the services.

This privacy policy will apply to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer. Within this privacy policy, we have set out how Hudson Weir will use your personal data to provide our service to you. Through the continued use of this site, you agree to and are bound by our policies.

The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

This will likely include the collection of:

• your personal details (e.g. name, date of birth)
• address details
• contact details (e.g. phone number, email)
• special personal information* (e.g. health information)
• financial information
• employment information
• information on how you use our website(s) and products and services
• any information relating to your company such as directorship and addresses

Special personal information

Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you.

Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this special data as set out in this privacy policy, unless we have a legal obligation to process this type of data.

Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

Information about other people

If you provide personal information about someone else, for example when providing information for the SIP6 report to creditors, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, 2 directors in a liquidation), your personal information and any information about the service provided to you will be shared with the other person.

We will use the personal information about the other person in the ways as described in this privacy policy.

How do we collect your personal information?

We collect your information in a number of ways.

• When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means
• Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company
• By adding reviews or interacting with us using social media such as Twitter or Facebook etc
• When you use online platforms, such as an online portal such as FastDox
• When we may need to obtain up to date information about you to meet our legal or regulatory obligations

We can only use your personal information where it falls into one or more of the following categories:

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

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, for example, sending you an email, text message or letter to welcome you to our services.

We will process the personal data we collect about you for the purposes set out below at purposes for processing your personal data.

After you have made your initial application/enquiry, if you also decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).

Ongoing Services

Where we are providing you with a service, such as Creditors Voluntary Liquidation or Individual Voluntary Arrangement (IVA) we will process your personal information to administer the services we provide. This may include contacting you where we may need further information or sending you updates on the progress of the services; we provide to you.

Where we provide ongoing services, we will normally require you to agree to the terms and conditions of the service. 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. For example, we would need to share information with your creditors to enable us to set up and administer an Individual Voluntary Arrangement.

Individual Voluntary Arrangement (IVA), Company Liquidation, Creditors Voluntary Liquidation (CVL), Members Voluntary Liquidation, Company Administration and Bankruptcy.

The information below specifically explains how and why your personal data will be used so that the services can be provided to you.

What personal data will we need to collect?

To be able to provide our services we will need to collect certain categories of personal data. This will include:

• Contact Details: Your full name, address, contact number, e-mail address etc. We need this so that we can keep you updated on the progress of your IVA / liquidation / other service and contact you when necessary. We also need this information to draft your reports or proposals to creditors.
• Personal & Financial Details: Your date of birth, gender, any previous names that you were known by, your living arrangements, employment details, details of any dependants, creditor details (including the names of your creditors, reference numbers and balances), details of any assets you hold and your payment information. We need this so that we can decide whether an IVA is appropriate for you and so that we can draft and send a proposal to your creditors. This can also be used in liquidations to determine your means, should there need to be any commercial settlement chosen. Once you enter into an IVA, we need this information to ensure that we can collect payments and take any changes in circumstances into consideration when administering the IVA.
• Income and Expenditure: Details of your financial position including all sources of income and your household expenditure. In the case of IVA, we need this so that we can draft your proposal to creditors and set the correct level of payments to be paid into your IVA. In the case of corporate liquidations, it may be necessary in agreeing a financial settlement.
• Special Personal Data: In some circumstances, we may need to collect special personal data however we will not do so without express consent from you and we will only do so where it is necessary for the purposes of assisting with your financial situation.
• Call Recordings, Chat Logs and E-mails: When you contact us by telephone, your call may be recorded for training and monitoring purposes. We also keep any e-mail correspondence and online chat logs to help us to manage your IVA, bankruptcy or corporate insolvency service.

Who will the data be shared with?

• Your Creditors and their Representatives: [for IVA’s only] Your personal data will be shared with your creditors, their agents, debt collectors, bailiffs and solicitors dealing with the debts. This is key to allow us to provide the service we have agreed to provide you and also ensures that we comply with our regulatory obligations.
• The Insolvency Service: [for IVA’s only] If your IVA is accepted then details about you and your IVA will be recorded on the Insolvency Register which is accessible by the public. The information we share includes your name, gender, date of birth and address. We have a legal obligation to supply this information. The IVA register is provided to credit reference agencies, as well as being open for public inspection.
• Our Regulators: From time to time we may have to share your information with regulatory bodies. These include The Institute of Chartered Accounts of England and Wales, the Information Commissioners Office or any other regulatory body or authority who may request certain information as part of their supervisory role. We are under legal and regulatory obligations to provide this.
• Solicitors: We may from time to time need to instruct solicitors to assist with the administration of your IVA / bankruptcy / corporate insolvency service or to assist us with legal, regulatory and contractual obligations.
• IT Providers: We use third-party software companies to help manage your data. These include:
  • IPS, a case management system.
  • Virtual Cabinet, a case management system.
  • Telephony companies, so we can communicate with you.
  • External printing company, who print correspondence that we send to you.

These companies help us to provide our services to you. We have contracts in place with all providers to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

• Agents: Where we have a duty to investigate any potential compensation claims that you may be entitled to, for example, payment protection insurance misselling claims, we will share some of your information with claims management companies.
• Other Third Parties: We may also share your personal information where we have your consent to do so, or where we are required to do so under a legal or regulatory obligation, for example where we are required to do so by a court order, the police, local authorities or the courts or in the event that your contact details require to be updated and you cannot be traced. We might share some of your information with the emergency services if you are in any immediate danger.
• Overseas: Hudson Weir Ltd includes a company inside the European Economic Area, Contabooks SRL as well as companies outside of the European Economic Area namely; Insolve Assist (Pty) Ltd as well as a Bangladesh branch of Howlader and Co Ltd our linked Chartered Accountancy firm. These companies provide back-office support for our insolvency solutions. These companies comply with the same legislation as our UK based companies, as well as local law. Any contractors in these jurisdictions have signed, explicit, detailed confidentiality agreements and only have access to the UK server. Your data is processed and protected in the same way as it is in the UK and your rights to access, correct, delete and restrict the data used remain the same.

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 notifications, social media or may send you messages by any online customer platforms or other electronic means.

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 a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.

It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.

If you do not go ahead with any product or service with us, your personal information will normally be deleted after 12 months unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing information from us. We will delete your information sooner if you ask us to.

If you become our customer by using one of our services, we will keep your data to ensure that we provide you with our services and comply with our legal and regulatory obligations. Your data will be stored for 6 years from the date that we cease to provide you with our services. We cannot delete this data if you ask us to because we are required to keep it by law. After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Legal or Regulatory Obligation

We are required to process your personal information where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering or our regulatory obligations.

Responding to complaints or enquiries

If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.

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 or personal data with third parties who provide us with services including conducting research for us and/or where we have a contractual obligation to do so.

We may also share your personal information with the following organisations:

• IT Service Providers who provide IT platforms or other IT services
• Communication providers (e.g. telephone line providers, and email and text service providers)
• Printers who print the letters and information packs which we send to you
• Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account
• Third parties who may have introduced you to our services

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

We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

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].

We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, 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
• 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.

We will only share your personal information outside the European Economic Area (EEA), 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 EEA.

If we do share your information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA 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 the EEA (this may include defined model clauses), or only share the data with a business partner in a non-EEA country where the privacy laws provide the same protection as within the EEA or where they are part of a Privacy Shield.

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:

• Company security policies and standards
• staff security awareness
• role-based and biometric access controls to prevent unauthorised access to the information
• encryption and anonymisation technology
• anti-malware technologies
• security monitoring
• security testing
• secure archiving and deletion
• compliance with industry regulation and legislation

When you visit our website or similar websites Google may use our advertisements promoting our products and services which may appear on other third-party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

We do not have any control over the advertisements you see on other third-party websites however you can request to opt out or customise these advertisements by using the Google Ads Preference Manager.

Use of Pure Chat: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Pure Chat (“Pure Chat”) and utilise Pure Chat to collect data for analytics purposes when you visit our website or use our product.

As a data processor acting on our behalf, Pure Chat analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Pure Chat’s use of cookies, please visit https://www.ruby.com/privacy-ruby/.

We may also use Pure Chat as a medium for communications, either through email, or through messages within our product(s).

As part of our service agreements, Pure Chat collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Pure Chat, please visit https://www.ruby.com/privacy/.

Pure Chat’s services are governed by Pure Chat’s terms of use which can be found at https://www.ruby.com/terms/.

Access to your personal information

You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below.

Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it where you have given your agreement.

Right to have your personal information corrected

If the personal information we hold about you is incorrect you have the right to request that we correct this.

Right to stop or limit the processing of the data we carry out

You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.

Portability

In some cases, you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you want to request this, you’ll need to contact us.

If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer using the address or email below:

Data Protection Officer

Hudson Weir Insolvency Practitioners
58 Leman Street London,
E1 8EU, United Kingdom

Email: [email protected]

If you are not happy with how we process your personal information you should contact us in the first instance. If you’re not happy with how we have dealt with your complaint you have the right to lodge a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/

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. You should read its own privacy policy to understand how they may use your personal data.

When using this website, some information may be collected automatically using ‘cookies’. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used. Cookies can be temporary or permanent.

Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

Why are cookies used?

They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off – this won’t stop a website from working, but it might mean it won’t work as well as it could, or that you have to do the same thing more than once.

They help website owners. Cookies tell website owners things like: what search engine a visitor used to find the website, how often they’ve visited it, how long they’ve spent on it, and so on.

We’ve set out below the cookies that we may use and those that are set by third parties on our website.

Google Analytics	ON site behaviour tracking
Adwords	Track Conversions
Bing Ads	Track Conversions

Except for essential cookies, all cookies will expire after 10 years.

Disabling/Enabling Cookies

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

None of the features of our website will be affected – giving you the full experience.

If you are using Microsoft Windows Explorer:

Open ‘Windows Explorer’

Click on the ‘Search’ button on the tool bar

Type ‘cookie’ into the search box for ‘Folders and Files’

Select ‘My computer’ in the ‘Look In’ box

Click ‘Search Now’

Double click on the folders that are found

Select any cookie file

Use the ‘Delete’ button on your keyboard

If you are not using Microsoft Windows Explorer, then you should select ‘cookies’ in the ‘Help’ function for information on where to find your cookie folder.

Any updates to this privacy policy will be found on this page. If we make any important or significant changes to the way we may collect and use your personal information we will endeavour to notify you of this change.
Updated: 29/07/22