Privacy Notice

This Privacy Notice is issued by ALL Scheme Ltd (SchemeCo) and is addressed to individuals outside our organisation that we interact with regarding the proposed Scheme of Arrangement (the Scheme). For further details on the Scheme, please see the Practice Statement Letter (PSL) available on the Scheme Portal at amigoscheme.co.uk, or contact us at [email protected].

This Privacy Notice may be amended or updated from time to time to reflect changes in our practices, the way we collect and use your information, or changes in the law.

We encourage you to read this Privacy Notice carefully, and to regularly check this page to review any changes we might make to this Privacy Notice.

Our lawful basis to process your information

  • Where you provide personal data in relation to the Scheme, including by creating a profile on the Scheme Portal or by voting on the Scheme, we will use our legitimate interests (in administering the Scheme) to store and process your information.
  • If the Scheme is approved and you subsequently make a claim to SchemeCo, we will use our legitimate interests (in administering the Scheme) to process your information in relation to the claim and to contact you about it.
  • Where you discuss sensitive data with us, we will capture explicit consent from you in order to store and process this information about you.

We will process your information as per our contractual and legal obligations to ensure we're acting safely, responsibly and legally. This includes:

  • Performing adequate checks (including seeking supporting information where required) to confirm your identity and to ensure you are a Redress Creditor (as defined in the PSL).
  • Identifying the claims that will not be dealt with under the Scheme.
  • Assessing, determining and administering any potential claim you make if the Scheme is approved (including via court proceedings).
  • Responding to and complying with any regulatory requirements (i.e. Financial Conduct Authority, Financial Ombudsman Service) and legal obligations (i.e. court judgments).

How we collect your information

We will collect information:

  • That you provide to us through our website, including through creating a profile on the online portal available at amigoscheme.co.uk, and through voting on the Scheme.
  • That you provide in reference to making a claim under the Scheme if it is approved.
  • Where necessary, from third parties (including from other group entities), such as banks, credit reference and fraud prevention or investigation agencies, or any other company that helps us make decisions or assessments under the Scheme.

Information we collect about you will also include information that you, or third parties, have previously provided to us or our affiliates in connection with applying and taking out a loan from Amigo Loans Ltd, in accordance with the relevant privacy policies made available to you when that information was collected.

What information will we collect?

We will collect any information we need from you in order for you to participate in voting on the Scheme and, if approved, making a claim in relation to it, as well as any other information which we reasonably need to make decisions about you or fulfil our obligations under the Scheme.

The information we will collect about you includes:

  • Your name, date of birth, addresses and contact information.
  • Your customer reference number.
  • Your agreement number.
  • Details of how you vote in relation to the Scheme, including any written comments you provide during the voting process.
  • If the Scheme is approved, details of any claim you make to SchemeCo.
  • Card and bank account information. If you provide us with any debit card and bank details, either via a claim under the Scheme or subsequently, we will keep those details and will use the details in line with the consent you provide to us, unless you advise us otherwise.
  • Documents to verify your information (including, without limitation, bank statements or payslips from the time the loan was lent and any evidence of money having been directly paid back by a borrower to a guarantor when you submit your claim).
  • Information we receive when making a decision about you or any claim you make to SchemeCo.
  • Details of the loans you have and have had with us and all previous transactions.
  • Details of when you contact us and when we contact you. We may keep any email address or phone number(s) that you communicate with us on or that you tell us about.
  • Your location.
  • Information about your computer including your IP address, operating system and browser type. For more details please see our Cookie Notice.
  • We may record your customer journey on our website or the Scheme Portal for usability monitoring, testing and improvement. However, we will not record any personal information you input.
  • We will record and/or monitor the calls, texts, emails and letters you send to us or receive from us.

We will also collect information for the purpose of staff training, and system improvement.

How will we use your information

We will use your information to progress all aspects of the procedural running of the Scheme and to review and decide the validity of any claims made under the Scheme if it is approved.

We will use your information:

  • To operate and manage your account on the Scheme Portal and any correspondence you may have with us.
  • To determine whether you are a Redress Creditor and to organise the Creditor Meeting.
  • To administer the voting process in relation to the Scheme.
  • To determine and adjudicate any claim you may make under the Scheme if it is approved.
  • To contact you (using any contact details that you have given to us) via email, SMS, letter, telephone or send you push notifications about the Scheme or in relation to any claim you may make under the Scheme if it is approved.
  • To respond to complaints.
  • To exercise our rights set out in agreements or contracts and to comply with our legal obligations.

How long will we store your information

  • If you have an account on our Scheme Portal, we will store your information for 1 year from the date you vote on the Scheme or, if the Scheme is approved, for such period as is required in connection with the administration and determination of any claims you make under the Scheme.
  • If you have a claim with us, we will keep your information indefinitely until your claim has been administered in full. Once your claim has been administered in full, and providing we have no ongoing relationship with you or any reason to keep your data, we will remove your information after 7 years.

Who we will share your information with

We will share your information with Amigo employees who:

  • Manage your account and details on the Scheme Portal
  • Respond to your queries and complaints
  • Process any claim you may make under the Scheme if it is approved
  • Audit our internal processes
  • Test our systems

We may also share your information with other parties such as:

  • The Scheme Supervisors
  • The Scheme Adjudicator
  • Companies who verify your information for us
  • When we are legally obliged to
  • Third party companies who help us document, record, assess and test our internal processes and systems
  • Any company we use to process your information (i.e., mail and telecom companies to send you communication via text, email and letter)
  • Any company we use to store your information on our behalf
  • Our regulators

Because of the nature of our business and the other organisations we work with, we may transfer your information to other countries. We will only transfer your information so that it may be used as we have described. The other countries may have different laws regarding the use of your information than those that apply in the UK.

If we transfer your information from the UK to organisations located outside of the UK, we will do so in compliance with the law in the UK.

Your rights

  • You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or remove your information, as long as we are not legally required to hold it or we hold it to meet a legitimate expectation or for you or us to meet a legal obligation.
  • If we are using your data because we deem it necessary to do so, and you do not agree, you have the right to ask to remove your information, or ask us to stop processing your information. If you would like to do so, you can contact us at [email protected]. In cases where you ask us not to contact you, we may still hold your information so that we know not to use it. If you request us to remove your information, we will only refuse your request if we are of the view that it is necessary to keep your information and we are legally permitted to do so, or we have the legal right to process the information for another specific reason. For example, if you have an ongoing relationship with us, or we have a legal reason to keep it.
  • Where we have obtained your consent to process your personal data for certain activities, you may withdraw your consent at any time. You can do so by contacting us at [email protected].
  • You may also have the right to instruct us to transfer the data we hold about you. We will help with this - either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format. To do this just contact us by phone, in writing, or by using the email address above.
  • Your rights regarding our use of your information are not absolute. If we decide not to act on a request that we receive from you, we will inform you of our legal reason(s) for not acting on your request.

How to complain

If you are unhappy with how we have used your data, you can tell us about it by contacting us on [email protected]. You can also contact the Information Commissioner's Office (ICO) which is the authority responsible for data protection in the UK.

You can contact the ICO at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

You also have the right to object to the way we use your information in certain circumstances. To exercise your right to object please contact us at [email protected].

Generally, you are not required to pay any charge to us for exercising your rights. If you make a request to us about your data, we have one month to respond to you.

Controller

The controller of your information is:

  • ALL Scheme Ltd, Nova Building, 118-128 Commercial Road, Bournemouth, BH2 5LT.

The Data Protection Officer is Richard Dickinson.

We are registered with the Information Commissioner's Office in the UK with registration number A8798008.

You can contact us at [email protected] or by writing to us at the above address.

Security

We recognise how important it is to protect and manage the information you share with us. We use computer safeguards such as firewalls and data encryption to keep your details safe. Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required.

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