Towerhall Solutions Ltd Privacy Notice

Towerhall Solutions Ltd (“we,” “our,” or “us”) provides debt recovery services exclusively to businesses
(“clients”). We act solely as a data processor, handling personal data on behalf of and under the
instruction of our clients, who are the data controllers. This privacy policy explains how we process
personal data in full compliance with UK data protection laws.

What information we collect, use, and why

What We Collect

(From our contact form)

• Your name

• Contact number

• Email address

Any information you include
in the ‘Message’ field

Why We Collect It

To respond to your enquiry and
communicate with you about your
message.

To understand and reply to your
specific request.

Please do not include sensitive
personal information (e.g., health, race,
religion, or financial details) unless
absolutely necessary.

To deliver the agreed service, fulfil our
contract with you, and manage the
relationship (e.g., invoicing, updates,
support).

Lawful Basis

Legitimate interests (Article
6(1)(f)) – it’s necessary to help
you and run our business
effectively.

Legitimate interests (Article
6(1)(f)) – only used to answer
your query.

Performance of a contract
(Article 6(1)(b)) – necessary to
provide the service you’ve
requested.

Your Data Rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal
information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful
bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below.
You can find out more about your data protection rights and the exemptions which may apply on the
ICO’s website:

Your right to be informed – You have the right to be informed about what personal date we collect
and how we use it.

Your right of access - You have the right to ask us for copies of your personal information. You can
request other information such as details about where we get personal information from and who we
share personal information with. There are some exemptions which means you may not receive all the
information you ask for.

Your right to rectification - You have the right to ask us to correct or delete personal information you
think is inaccurate or incomplete.
Your right to erasure - You have the right to ask us to delete your personal information, in certain
circumstances.

Your right to restriction of processing - You have the right to ask us to limit how we can use your
personal information, in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal
data, in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you
gave us to another organisation, or to you.

Your right to not be subject to automated decision making and profiling - You have the right not to be
subject to a decision based solely on automated processing, including profiling, which has legal or
similarly significant effects on you. (We do not use automated decision making.)

If you make a request, we must respond to you without undue delay and in any event within one
calendar month. We will conduct reasonable and proportionate searches to fulfill your request.
You can exercise any of your above rights, including Subject Access Requests, by using the contact
details at the bottom of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and
services for clients are:

 Contract – we have to collect or use the information so we can enter into or carry out a contract
with you. All of your data protection rights may apply except the right to object.

 Legitimate interests – we’re collecting or using your information because it benefits you, our
organisation or someone else, without causing an undue risk of harm to anyone. All of your data
protection rights may apply, except the right to portability.

For more information on our use of legitimate interests as a lawful basis you can contact us using the
contact details set out below.

Our lawful bases for collecting or using personal information for the operation of client or customer
accounts are:

 Contract – we have to collect or use the information so we can enter into or carry out a contract
with you. All of your data protection rights may apply except the right to object.

 Legal obligation – we have to collect or use your information so we can comply with the law. All of
your data protection rights may apply, except the right to erasure, the right to object and the right
to data portability.

 Legitimate interests – we’re collecting or using your information because it benefits you, our
organisation or someone else, without causing an undue risk of harm to anyone. All of your data
protection rights may apply, except the right to portability. For more information on our use of
legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to comply with legal requirements:

 Contract – we have to collect or use the information so we can enter into or carry out a contract
with you. All of your data protection rights may apply except the right to object.

 Legal obligation – we have to collect or use your information so we can comply with the law. All of
your data protection rights may apply, except the right to erasure, the right to object and the right
to data portability.

Where we get personal information from

 Directly from you

 Regulatory authorities

 Legal bodies or professionals (such as courts or solicitors)

 Debt collection agencies

 Credit reference agencies

 Suppliers and service providers

How long we keep information

Personal data is retained only for as long as instructed by the client or as required by law. Upon
completion of our services, data is securely returned or deleted.
In the event of a personal data breach, we will notify the affected data controller(s) without undue delay
and, where feasible, not later than 72 hours after becoming aware of it.
For more information on how long we store your personal information or the criteria we use to determine
this please contact us using the details provided below.

Who we share information with

Other financial or fraud investigation authorities

 Professional or legal advisors

 Regulatory authorities

 Organisations we’re legally obliged to share personal information with

 Suppliers and service providers

 Professional consultants

Contact Details

If you have any questions about this policy or data handling, you can contact us at:

Telephone: 01342 718300

Email: info@towerhallsolutions.com

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the
contact details at the bottom of this privacy notice. We will acknowledge your complaint within 30 days
and respond without undue delay.

You may escalate unresolved complaints to the Information Commissioner's Office (ICO - the UK
supervisory authority for data protection issues) here: https://ico.org.uk/make-a-complaint/

The ICO’s address:           
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113