BACKGROUND:

Blackberry Finance Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.changedebtline.com (“Our Site”). Any personal data We do collect will only be used as permitted by law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018 and the EU Regulation 2016/679- which is incorporated into UK law under the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019 (referred to collectively here as the “Data Protection Regulations”); and

“We / Us / Our”

means Blackberry Finance Solutions Limited, a limited company registered in England under company number 06098871, whose registered address is Hampton By Hilton, Suite 615, 6th Floor, 42-50 Kimpton Road, Luton, Bedfordshire, LU2 0FP, and whose main trading address is the same as its registered address.

2. Information About Us

2.1 Our Site is owned and operated by Blackberry Finance Solutions Limited a limited company registered in England under company number 06098871, whose registered and trading address is Hampton By Hilton, Suite 615, 6th Floor, 42-50 Kimpton Road, Luton, Bedfordshire, LU2 0FP. Change Debtline is a trading name of ours.
2.2 We are authorised and regulated by the Financial Conduct Authority for Debt Counselling Services. Our firm reference number is: 669786. You can check these details on the register: https://register.fca.org.uk/.
2.3 We have notified the Information Commissioner of our data processing activities. Our registration number is: ZA189068
2.4 This Site is operating as a Lead Generation site, which means that any enquiry that you make through our online form will be shared with third parties. See section 6 for more details.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the Data Protection Regulations, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data we hold about you (see section 9);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 10);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 10);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 10 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau

5. What Data Do We Collect?

5.1 We do not collect any personal data from you when you visit the Site and. We do not place cookies on your computer or device.
5.2 If you send Us an email, or use the contact us form on the Site, We may collect your name, your email address, and any other information which you choose to give Us.
5.3. If you contact us for advice about your debts we will collect information relating to your debts and financial situation as well your personal circumstances. This is normally carried out over the phone and we will retain a copy of the call recording.
5.4. Where we are acting as a Lead Generator then we will collect and process the details that you enter into our online form (such as your name and contact details as well as some basic details about the level of debts that you have).

6. How Do We Use Your Data?

6.1 When we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulations at all times. For more details on security see section 8, below.
6.2 As noted above, We do not generally collect any personal data when you visit our Site. If you contact Us via the Site and We obtain your personal details this way, and We may use them as follows:
6.2.1 To reply to your email;
6.2.2 To keep a record if we have referred you to another provider;
6.2.3 to send you details of our service(s) that we think you may be interested in.
6.3 Where we have given you advice we will share your data with your consent or where it is Our and your legitimate interest to the following types of third parties :
a) Other debt counselling/advice providers;
b) Debt solution providers (such as Insolvency Practitioners, Debt Management companies and Breathing Space);
c) Our regulator (such as the FCA or the ICO), including the Financial Ombudsman service where you have made a complaint;
d) Our compliance consultants .
6.4.Where we act as a Lead Generator then we will share your details with: Other Debt Counselling providers,
Debt Advice providers,
Debt or advice Charities,
Insolvency Practitioners,
Solicitors,
Accountants; and
other Lead Generators
6.5 save for in specific circumstances (for example where you have made a complaint) you have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

7. Legitimate Interest

Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.
You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 10. Our legitimate interests include:
• putting you in contact with a debt counselling/debt advice provider;
• the maintenance of our IT/Data Security systems and processes;
• putting in place fraud prevention mechanisms;
• keeping our records up to date;
• working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
• developing products and services;
• being efficient about how we fulfil our legal duties;
• maintaining a marketing suppression list; and
• complying with laws/regulations that apply to us.

8. How and Where Do We Store Your Data?

8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. Where we have given you advice we will keep your data for 5 years following the end of our relationship with you (call recording may however be kept for a shorter period).
8.2 Your data will only be stored in the UK.
8.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure any data We hold about you (even if it is only your email address).
8.4 Steps We take to secure and protect your data include:
8.4.1 Having in place access controls, limiting who can access what data
8.4.2 Anti-virus and firewalls
8.4.3 Data security policies and process
8.4.4 Training of staff, workers and contractors
8.4.5 Ensuring any third-party service providers are bound to confidentiality and the obligations to keep personal data secure.

9. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulations, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at enquiries@blackberryfs.com , or using the contact details below in section 10

10. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at enquiries@blackberryfs.com, or by post at Hampton By Hilton, Suite 615, 6th Floor, 42-50 Kimpton Road, Luton, Bedfordshire, LU2 0FP. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

11. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes or our data processing changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date

Updated – May 2023