Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service
users.
1.2 This Policy applies where we are acting as a data controller with respect to the
personal data of our website visitors and service users. In other words, where we
determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of our website and services, we will ask you to consent to our use of
cookies when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can specify whether you would like to
receive direct marketing communications and limit the publication of your information.
You can access the privacy controls via the relevant website.
1.5 In this Policy, “we”, “us” and “our” refer to Civil Enforcement Advisers Limited.
For more information about us, see Section 13.
How we use your personal data
2.1 In this section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source
and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“).
The usage data may include your IP address, geographical location, browser type and
version, operating system, referral source, length of visit, page views and website
navigation paths, as well as information about the timing, frequency and pattern of your
service use. The source of the usage data is our analytics tracking system. This usage
data may be processed for the purposes of analysing the use of the website and
services. The legal basis for this processing is consent or our legitimate interests,
namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may
include your name and email address. The source of the account data is you. The
account data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is consent or
our legitimate interests, namely the proper administration of our website and business or
the performance of a contract between you and us and/or taking steps, at your request,
to enter into such a contract.
2.4 We may process your information included in your personal profile on our website
(“profile data“). The profile data may include your name, address, telephone number,
email address and date of birth. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis for this
processing is consent or our legitimate interests, namely the proper administration of our
website and business or the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.5 We may process your personal data which is provided in the course of the use of
our services (“service data“). The service data will include all data contained within your
credit report. The source of the service data is Equifax, Call Credit Ltd and Experian plc.
The service data will also include any information provided by you in relation to your
case and any information obtained from any third party in relation to your case. The
service data may be processed for the purposes of providing our services. The legal
basis for this processing is consent.
2.6 We may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters (“notification data“). The notification data
may be processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent or the performance of a
contract between you and us and/or taking steps, at your request, to enter into such a
contract.
2.7 We may process information contained in or relating to any communication that
you send to us (“correspondence data“). The correspondence data may include the
communication content and metadata associated with the communication. Our website
will generate the metadata associated with communications made using the website
contact forms. The correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website and business and
communications with users.
2.8 We may process any of your personal data identified where necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks or obtaining
professional advice. The legal basis for this processing is our legitimate interests,
namely the proper protection of our business against risks.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies
(this means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set out in this
Policy. Civil Enforcement Advisers Limited currently has no subsidiaries or holding
company. Should this legal structure change in the future, we will notify you within the
confines dictated by GDPR.
3.2 We may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice or the establishment, exercise
or defence of legal claims, whether in court proceedings or in an administrative or out-of-
court procedure.
3.3 We may disclose your information to a partner law firm for the purposes of
resolving your claim. We will notify you of our intention to do this.
3.4 In addition to the specific disclosures of personal data set out in this section 3, we
may disclose your personal data where such disclosure is necessary for compliance with
a legal obligation to which we are subject or in order to protect your vital interests or the
vital interests of another natural person. We may also disclose your personal data where
such disclosure is necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
4.1 In this section 4, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic Area
(EEA).
4.2 The hosting facilities for our website are situated in the United Kingdom. The
European Commission has made an “adequacy decision” with respect to the data
protection laws of each of these countries. Transfers to each of these countries will be
protected by appropriate safeguards, namely the use of standard data protection clauses
adopted or approved by the European Commission.
4.3 You acknowledge that personal data that you submit for publication through our
website or services (for example, a testimonial) may be available, via the internet, around
the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
5.1 This section 5 sets out our Data Retention Policies and Procedure, which are
designed to help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for
longer than is necessary for that purpose or those purposes.
5.3 Personal data will be retained for a minimum period of 1 day following submission
date and for a maximum period of 6 years following service or product close date.
5.4 Notwithstanding the other provisions of this section 5, we may retain your
personal data where such retention is necessary for compliance with a legal obligation to
which we are subject or in order to protect your vital interests or the vital interests of
another natural person.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Amendments
6.1 We may update this Policy from time to time by publishing a new version on our
website.
6.2 You should check this page occasionally to ensure you are happy with any
changes to this Policy.
6.3 We may notify you of changes to this Policy by email or through the private
messaging system on our website.
Your rights
7.1 In this section 7, we have summarised the rights that you have under data
protection law. Some of the rights are complex and not all of the details have been
included in our summaries. Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of the
processing, the categories of personal data concerned and the recipients of the personal
data. Providing the rights and freedoms of others are not affected, we will supply to you a
copy of your personal data. The first copy will be provided free of charge but additional
copies may be subject to a reasonable fee. You can access your personal data by visiting
the relevant website when logged into our website.
7.4 You have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete personal
data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data is no longer
necessary in relation to the purposes for which it was collected or otherwise processed;
you withdraw consent to consent-based processing; you object to the processing under
certain rules of applicable data protection law; the processing is for direct marketing
purposes; and the personal data has been unlawfully processed. However, there are
exclusions of the right to erasure. The general exclusions include where processing is
necessary; for exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, exercise or defence of legal
claims.
7.6 In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure; we no longer need the personal data for
the purposes of our processing but you require personal data for the establishment,
exercise or defence of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this basis, we may
continue to store your personal data. However, we will only otherwise process it: with
your consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of important
public interest.
7.7 You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a task carried out
in the public interest or in the exercise of any official authority vested in us; or the
purposes of the legitimate interests pursued by us or by a third party. If you make such
an objection, we will cease to process the personal information unless we can
demonstrate compelling legitimate grounds for the processing which override your
interests, rights and freedoms or the processing is for the establishment, exercise or
defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you make such
an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to your
particular situation, unless the processing is necessary for the performance of a task
carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you
are party; or
(c) in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive
your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the rights and
freedoms of others.
7.11 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not
affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by sending an
email to: claims@civilenforcement.co.uk
7.14 Should you wish to report a complaint or if you feel that we have not addressed
your concern in a satisfactory manner, you may contact the Information Commissioner’s
Office. You can visit them at ico.org.uk or call them on 0303 123 1113. Our company ICO
reference number is ?????
About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is
sent by a web server to a web browser and is stored by the browser. The identifier is then
sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set expiry date,
unless deleted by the user before the expiry date. A session cookie, on the other hand,
will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user
but personal information that we store about you may be linked to the information stored
in and obtained from cookies.
Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as
you navigate our website;
(b) status – we use cookies to help us to determine if you are logged into our website;
(c) personalisation – we use cookies to store information about your preferences and
to personalise the website for you
(d) security – we use cookies as an element of the security measures used to protect
user accounts, including preventing fraudulent use of login credentials and to protect our
website and services generally;
(e) advertising – we use cookies to help us to display advertisements that will be
relevant to you;
(f) analysis – we use cookies to help us to analyse the use and performance of our
website and services; and
(g) cookie consent – we use cookies to store your preferences in relation to the use of
cookies more generally.
Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.
10.2 We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information gathered
relating to our website is used to create reports about the use of our website. Google’s
privacy policy is available at:
https://www.google.com/policies/privacy/.
Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via these
links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-
preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-
manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many
websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
Our details
12.1 This website is owned and operated by Civil Enforcement Advisers Limited.
12.2 We are registered in England and Wales under registration number 15993612 and
our registered office is at 36 Albemarle Street, Mayfair, London, W1S 4JE
12.3 You can contact us:
(a) by email: claims@Civilenforcement.uk
(b) by writing to us @ Civil Enforcement Advisers Limited. 36 Albemarle Street,
Mayfair, London, W1S 4JE