We are a “data controller” for the purposes of the Data Protection Act 1998, (i.e. we are responsible for, and control the processing of, your personal information).
- the personal information we collect about you
- what we do with your information, and
- who your information might be shared with.
For us, data protection is a sensitive topic. Our activities to comply with the GDPR are in order to respect your privacy.
Controller for the data processing on our website https://clearmydebt.today is
Hotwire Media Ltd.
Office 7, Eastgate
Email: [email protected]
Phone: 0203 637 6160
2. What is personal data and how do we collect it
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
a) Data collected on clearmydebt.today
Generally, you can use our website without giving away any personal data. However, we save certain data in our server log files when you connect to our website. The server log files contain information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views). Therefore, we use “session” cookies (for further cookie uses see forth sec. 8). Session cookies will be deleted from your computer when you close your browser. We save and use your IP-address as well as a time stamp only for internal reasons.
b) Personal data submitted to us
We collect your personal data if you submit them to us via a form, for example.
If you request a service we would typically collect the following:
- your first name
- your surname
- your phone number
- your email
- details required to provide the service request
3. Purposes we use your personal data for
We only process personal data in accordance with the GDPR or any other national data protection law.
a) Processing is necessary for the performance of a contract (Art. 6 par. 1 lit. b) GDPR)
We process your personal data mainly to provide you with our services, especially in order to give you access to your account as a buyer and to use it for transactions with other buyers.
b) Processing is necessary for the purposes of legitimate interests (Art. 6 par. 1 lit. f) GDPR)
In certain cases, we process data for our legitimate interests to provide you with the services of our website and to maintain the security of our IT systems. This concerns data stored in the server log files, for example.
4. Disclosures to third parties
Where you request a service from us, this will usually necessitate passing your personal data to a solicitor, insurance or finance broker. We will inform you at the time the request is made who this is. We have no control over the privacy policies of these third-party partners and we encourage you to review their individual policies and act accordingly within your rights.
In addition, we may disclose information about you:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.
We use the service Google Analytics (see forth under sec. 10), where data is transferred and then processed outside of the European Union, namely in the United States of America. However, Google LLC, the provider of Google Analytics, is under the EU-US-Privacy-Shield, which ensures a standard of data protection, comparable to the EU.
In addition, personal information that you submit for publication on the website will be published on the internet and may be available via the internet around the world.
5. Data retention
We save data processed on a contractual basis for three years after the contract is terminated.
Data processed because of a legitimate interest is saved for three years after it has been collected.
As soon as the storage period expires, the personal data are routinely erased in accordance with legal requirements.
6. Rights of the data subject
Pursuant to the GDPR, you have certain rights as a data subject:
- You shall have the right to obtain from us, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain information. (Art. 15 GDPR: right to access)
- You shall have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. (Art. 16 GDPR: right to rectification)
- You shall have the right to obtain from us the erasure of your personal data without undue delay. (Art. 17 GDPR: right to erasure)
- You shall have the right to obtain from us restriction of processing. (Art. 18 GDPR: right to restriction of processing)
- You shall have the right to receive your personal data, you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided or to have the personal data transmitted directly from one controller to another, where technically feasible. (Art. 20 DS-GVO: right to data portability)
- You shall have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, including profiling based on those provision. (Art. 21 GDPR: right to object)
- You shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. (Art. 77 GDPR: right to lodge a complaint with a supervisory authority).
If you provided us with your informed consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please write to:
The Data Officer
Hotwire Media Ltd.
Office 7, Eastgate
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall- protected) servers.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Internet-specific services
A cookie consists of information, sent by a web server to a web browser, which stores the cookie on the user’s device. The information in the cookie is sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the specific browser.
We may use both “session” cookies and “persistent” cookies on our website. We will use session cookies to keep track of you whilst you navigate the website; we will use persistent cookies to enable our website to recognise your browser if you visit us again;
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until they are deleted or until they reach their expiry date.
You may at any time prevent the setting of cookies by using the corresponding settings in your browser or the respective software on your device and thus permanently deny the setting of cookies. Moreover, you may delete cookies saved on your device at any time. However, if you deactivate the setting of cookies, not all functions of our website may be entirely usable.
b) Google Analytics
We use Google Analytics. Google Analytics is a web analytics service of the Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, United States. Via this technology, we collect and analyse data about our visitor’s behaviour. This data is anonymous and we use it for the optimization of our website. We use the function anonymizeIP, which anonymizes your IP-address before the data is transferred to Google’s servers in the United States of America.
Google Analytics places cookies on your device. By setting the cookie, Google may analyse the use of our website. Therefore, Google gains knowledge of information, such as the access time, the location from which the site was accessed and the frequency of visits to our website by the data subject. With each visit to our website, data will be transmitted to Google in the United States of America. Google may store and pass these personal data collected through the technical procedure on to third parties.
As stated above, you may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of your web browser or respective software used. Additionally, you may download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
We use Leadspedia. Leadspedia is a lead distribution service based in the US. Via this technology, we collect, filter and distribute personally recognisable data between the websites used by Hotwire Media Ltd and the Third Party partners referred to in section 4