Our privacy policy
Your information will be held by Tower Consulting Services Ltd and Andriy Smolenko.
In this privacy notice, “We” “Our”, “Us” and “They” is Tower Consulting Services Ltd and Andriy Smolenko.
How we use your personal information
This privacy notice is to let you know how we promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a client, and the choices you give us about what marketing you want us to send you.
This notice explains how we do this and tells you about your privacy rights and how the law protects you, in accordance with the General Data Protection Regulation (GDPR).
Our Privacy Promise
We promise:
- To keep your data safe and private.
- Not to sell your data.
- To give you ways to manage and review your marketing choices at any time.
Who we are
Tower Consulting Services Ltd is a Debt Counselling Company who provides debt counselling to consumers.
Andriy Smolenko is a director of Tower Consulting Services Ltd.
If you have any questions or want more details about how we use your personal information, you can call us on 01614252190.
Who collects your data
Tower Consulting Services Ltd and Andriy Smolenko are “data controllers”. This means they are responsible for how they hold and use personal information about you.
How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we can use personal information only if we have a proper reason to do so. This includes sharing it outside our company. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
We are obliged to process personal data to comply with the law and therefore have a legal duty to use your personal information.
For what purpose do we use your personal information
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.
| What we use your personal information for | Our reasons | Our legitimate interests |
| To provide debt counselling services to youTo assist you with completing your bankruptcy applicationTo manage our relationship with youTo develop new ways to meet our customers’ needs and to grow our businessTo develop and carry out marketing activitiesTo study how our customers use our products and servicesTo provide advice or guidance about our products and services. | Fulfilling contractsOur legal dutyOur legitimate interestsYour consent | Keeping our records up to date, working out which of our products and services may interest you and telling you about themTo provide debt counselling services to youTo assist you with completing your bankruptcy applicationDeveloping products and services, and what we charge for themSeeking your consent when we need it to contact youBeing efficient about how we fulfil our legal duties. |
| To develop and manage our brand, products and services.To manage how we work with other companies that provide services to us and our customers. | Fulfilling contracts.Our legal duty.Our legitimate interests. | Developing products and services, and what we charge for themBeing efficient about how we fulfil our legal and contractual duties. |
| To deliver our products and services.To manage fees and charges.To exercise our rights set out in agreements or contracts. | Fulfilling contracts.Our legal duty.Our legitimate interests. | Being efficient about how we fulfil our legal and contractual duties.Complying with regulations that apply to us. |
| To detect, investigate, report, and seek to prevent financial crime.To manage risk for us and our customers.To obey laws and regulations that apply to us.To respond to complaints and seek to resolve them. | Fulfilling contracts.Our legal duty.Our legitimate interests. | Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.Complying with regulations that apply to us.Being efficient about how we fulfil our legal and contractual duties. |
| To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit. | Our legal duty.Our legitimate interests. | Complying with regulations that apply to us.Being efficient about how we fulfil our legal and contractual duties. |
Groups of Personal Information
To provide our services, we collect ‘Personal Information (data)’ that uniquely identifies you. The following table explains the different kinds of personal information we collect and why.
| Type of personal information | Description, including examples: | Why we want the data, and what we will do with it: |
| Personal descriptors | Your name, age, date of birth, passport or driving licence. We require this to identify you and communicate with you. | We require this to identify you and communicate with you.You cannot opt out of providing this information. |
| Contact | Where you live and how to contact you. | We require this to identify you and communicate with you.You cannot opt out of providing this information. |
| Financial | This includes your income, expenditure, assets, benefits details, wage slips, tax returns, default history, legal action, county court judgements, previous credit history, credit reference information, bank account and debit card details. | We require this to provide certain services, such as to assess your eligibility for debt solutions or to establish your creditor information on your behalf. It is a contractual requirement for insolvency services.You cannot opt out of providing this information. |
| Employment information | This includes your employment status, occupation, pay date, salary amount, professional occupational status (e.g. Company Director, Police Officer). | We require this to assess your eligibility for debt solutions. It is a contractual requirement for insolvency services.You cannot opt out of providing this information. |
| Life information | This includes your marital status, number of children and/or dependents, general household details. | We require this to assess your eligibility for debt solutions. It is a contractual requirement for insolvency services.You cannot opt out of providing this information. |
| Health information | This includes physical or mental disabilities. For example, if you complete the Debt and Mental Health Evidence Form. | We may collect certain special category data to identify if you are potentially vulnerable or require further support.You can opt out of providing this information. |
| Contractual | Details about the products or services we provide to you. | It is a contractual requirement for insolvency services.You cannot opt out of providing this information. |
| Behavioural | Details about how you use our products and services. | Marketing may record the details and Management Information may be generated using this information.You can opt out of providing this information. |
| Technical | Details on the devices and technology you use. | Marketing may record the details and Management Information may be generated using this information.You can opt out of providing this information. |
| Communications | What we learn about you from letters, emails, and conversations between us. | These are essential communications, deemed necessary to fulfil our contractual and legal obligations.You cannot opt out of providing this information. |
| Electronic signature | We can send documents to you by email which you will need to review, consider and where you decide to proceed, sign using an electronic signature. You may be required to provide personal information to electronically sign the document.We will also collect information such as your name, the date and time of the event, the IP address and other information about the browser or device used to send, sign, approve or take other actions with respect to the document. | All this information is recorded as part of an audit trail that is linked to the electronically signed document.You cannot opt out of providing this information, however, you can opt out of using the electronic signature service and receive a hard copy of the documents by post. |
| Open Data and Public Records | Details about you that are in public records such as the Electoral Register or Insolvency Register and information about you that is openly available on the internet. | We may require this to assess your eligibility for debt solutions. Checking you are not listed on the Insolvency Register is a contractual requirement for insolvency services.You cannot opt out of providing this information. |
| Documentary Data | Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or birth certificate. | We require this to provide certain services, such as to assess your eligibility for debt solutions. We require this to identify you.You cannot opt out of providing this information. |
| Consents | Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you. | We require your consent to act on your behalf. This is deemed necessary to fulfil our contractual and legal obligations.You cannot opt out of providing this information. |
| National Identifier | A number or code given to you by a government to identify who you are, such as a National Insurance number. | We require this to provide certain services, such as to assess your eligibility for debt solutions.You can opt out of providing this information. |
| Consumer feedback | This includes information that you voluntarily share with us about your experience in using our products and services, such as personal stories or complaints. | We use this information for marketing purposes and may collect and publish consumer-generated content.This information is used to evaluate and develop our products and services. It may be shared with regulators and auditors. You can opt out of providing this information. |
Where we collect personal information from
We may collect personal information about you from data you give to us, data we collect when you use our services and from third parties we work with.
Data you give to us:
- When you apply for our products and services
- When you talk to us on the phone
- When you use our websites or mobile device apps
- In emails and letters
- In customer surveys
Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:
- Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.
Data from third parties we work with:
- Companies that introduce you to us
- Financial advisers
- Creditors
- Credit reference agencies
- Social networks
- Fraud prevention agencies
- Payroll service providers
- Public information sources such as Companies House
- Agents working on our behalf
- Market researchers
- Medical practitioners*
- Government and law enforcement agencies.
*If the Debt and Mental Health Evidence Form is appropriate to your circumstances and you request your doctor to complete this form and return it to us, we may hold special category data on you.
Transferring and sharing your information
We may share your information with other parties as without doing this we (or they) cannot carry out our legal duty.
In addition, from time to time, we use the services of external consultants, legal specialists, or outsource certain aspect of our processes to other organisations, some of whom may be located outside of the European Economic Area. We keep outsourcing activity to a minimum however on occasion these organisations may assist us with quality monitoring, marketing, identity verification, audits, record keeping or printing. All outsourced service providers are carefully vetted and monitored to ensure the safeguarding of your information.
We use the services of credit reference agencies for verifying your identity this usually will leave a ‘soft search’ on your credit file. We will share your personal information with credit reference agency and they will give us information about you. The data we exchange can include:
- Name, address and date of birth
- Details of any shared credit
- Financial situation and history
- Public information, from sources such as the electoral register and Companies House.
In accordance with our legal obligations we may be required to share information with the police, other law enforcement, government agencies or regulatory bodies.
You also have the option to appoint someone else to act on your behalf such as a spouse, family member or carer with whom we can share your information with. You will need to provide separate consent for us to be able to share your information with them, and you can revoke this consent at any time.
Who we share your personal information with
- We may share your personal information with these organisations:
- Agents and advisers who we use to assist you with completing your bankruptcy application and explore new products and services
- Your creditors
- The Insolvency Service
- HM Revenue & Customs, regulators and other authorities
- Credit reference agencies
- Fraud prevention agencies
- Insurers
- Any party linked with your product or service
- Companies we have a joint venture or agreement to co-operate with
- Organisations that introduce you to us
- Companies that we introduce you to
- Market researchers
- Independent Financial Advisors
- Companies you ask us to share your data with.
- We may need to share your personal information with other organisations to provide you with the product or service you have chosen.
We may also share your personal information if the make-up of Tower Consulting Services Ltd changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
- If the change to Aperture happens, then other parties may use your data in the same way as set out in this notice.
Fraud Prevention Agencies
- We will need to confirm your identity before we provide products or services to you. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
- Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
- A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us
- We or a fraud prevention agency may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
- If we, or a fraud prevention agency, decide there is a risk of fraud, we may stop activity on your case and the fraud prevention agency will also keep a record of the risk that you, or your business, may pose.
- Fraud prevention agencies can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
- Fraud prevention agencies may send personal information to countries outside the European Economic Area (EEA). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.
Automated decisions for fraud prevention
- We may use automated decision making in processing your personal information in relation to fraud prevention. If you disagree with the outcome of an automated decision you can request a manual review of the accuracy of an automated decision.
Sending data outside of the EEA
We will only send your data outside of the European Economic Area (EEA) to:
- Follow your instructions
- Comply with a legal duty
- Work with our agents and advisers who we use to propose your IVA
- If we do transfer information to our agents or advisers 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. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.
Websites
- If you use our website we may collect your IP address, cookies, browser information, and use plugins that collect your information (e.g. Google Analytics, WordPress and Yoast SEO). Cookies are text files places on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity.
- For further information visit www.about cookies.org or ICO.org.uk/concerns/cookies/
- You can set your browser not to accept cookies and can find out more information in the links above, however in some cases our website features may not function as a result.
- Our website and communications contain links to other organisations and websites. This privacy notice only applies to our company.
Marketing
- We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
- The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
- We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
- We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
- You can ask us to stop sending you marketing messages by contacting us at any time.
- Whatever you choose, you’ll still receive other important, and legally required, information and documents.
- We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
- If you change your mind you can update your choices at any time by contacting us.
Security
- We will use all reasonable efforts to safeguard the information we collect about you by having security and organisational procedures in place.
- All personal information we hold is securely stored, and we conduct regular testing or our cyber and physical security procedures to ensure this is maintained. If at any time we believe there has been a breach of your personal data we will notify you immediately.
- You are responsible for keeping any personal passwords or similar security information private, including personal information you disclose on social media.
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services required to submit your bankruptcy petition. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want to restrict the processing of your data
In certain circumstances you may want to restrict the processing of your data, for example, if you contest accuracy of the information, if you object to the processing of the information we hold about you, if you oppose the erasure of the information and instead insist on restricted processing. You should contact us if you want to do this and we will respond within one month.
What if you want us to stop using your personal information
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data but you are waiting for us to tell you if we can keep on using it.
- If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.
How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
How long we keep your personal information
We will keep your personal information for as long as you are a customer of our company. After you stop being a customer, we will keep your data for 6 years for one of these reasons:
- This is a legal requirement.
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
- We may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
Data portability
Data portability means that we can provide you with your personal information in a structured, commonly used and machine-readable form free of charge. This enables other organisations to use your data. If you require, we can supply this information directly to another organisation if technically feasible. You should contact us to exercise this right and we will respond within one month. This may be extended to two months if the request is complex and we will notify you if this is the case.
How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
Tower Consulting Services Limited, 8 Bowness Street, Manchester, M32 0FA.
How to complain
Please let us know if you are unhappy with how we have used your personal information. You can contact us on 01614252190 or write to the above address.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern: www.ico.org.uk.
Changes to our privacy notice
If we change how we plan to use your information in the future, we will give you 14 days’ notice of this. You have the right to refuse any such changes but it may result in the termination of our service if the refusal affects our ability to provide the service to you.
This policy last updated: January 2024