Privacy Policy
GentleTech's Privacy Policy is committed to safeguarding your personal data with transparency and trust. Our comprehensive policy outlines how we collect, use, and protect your information, ensuring compliance with data protection regulations.
At GentleTech, we prioritise secure data handling, user privacy, and clear communication about your rights. Whether you're exploring our services or sharing your details, trust GentleTech for a privacy-first approach that ensures your information is safe and managed responsibly.
At GentleTech, we prioritise secure data handling, user privacy, and clear communication about your rights. Whether you're exploring our services or sharing your details, trust GentleTech for a privacy-first approach that ensures your information is safe and managed responsibly.
Introduction
GentleTech Ltd Privacy Notice
About Us
GentleTech Ltd (“we”, “us”, “our”) is registered in England and Wales under Company Registration Number 16170819. Our registered office is at: Office Gold, Building 3, Chiswick Park, 566 Chiswick High Road, London, W4 5YA.
Telephone: 0204 616 0300
Email: hello@gentletech.co.uk
GentleTech Ltd is registered as a Data Controller with the Information Commissioner’s Office (ICO) under registration number ZB847875.
Purpose of This Privacy Notice
We are committed to ensuring the privacy and security of all personal data we process. This Privacy Notice explains how we collect, use, and share your information, as well as your rights in relation to that information. This notice applies to:
Individuals who engage in our services.
Visitors to our website.
Clients and potential clients of our business.
Any other third parties we interact with in the course of providing our services.
Data Minimisation and Purpose Limitation
We are committed to only collecting the personal data necessary for the specific purposes outlined in this privacy notice. Your data will not be processed for unrelated purposes unless we have obtained your consent, or it is required by law.
Data We Process
We may collect, use, store, and transfer different kinds of personal data about you, depending on the nature of your relationship with us. This includes:
| Data Type | Details |
|---|---|
| Identification Data | Full name, title, gender, date of birth, nationality, passport number |
| Contact Data | Home and business addresses, email addresses, phone numbers |
| Vehicle Data | Vehicle registration number, make, model |
| Financial Data | Bank account information, payment history, income, expenditure details |
| Employment Data | Job title, company details, employment history |
Sensitive or Special Category Data
Certain information, such as health data, is classed as special category data under the law. We use this data, provided by you or an authorised third party, to understand your circumstances and ensure fair treatment in line with our legal obligations. We may rely on your explicit consent or specific exemptions under the Data Protection Act 2018 to process this data.
| Data Set | Details | Purpose |
|---|---|---|
| Health Information | Data regarding physical or mental health conditions, medical history, and any health-related disabilities. | Information about anxiety, depression, or other mental or physical health issues may be processed to assess vulnerability. |
| Racial or Ethnic Origin | Information related to racial or ethnic background, national origin, or similar demographic data. | Used to verify nationality for immigration applications or support visa eligibility criteria. |
| Biometric Data | Includes facial images, fingerprints, and other data used for identification purposes. | Required for identity verification during visa applications or to meet regulatory obligations. |
Technical and Usage Data
We collect technical and usage data, such as IP addresses, browser details, time zone settings, and information about your visit, using cookies and similar technologies to:
| Objective | How Data is Used |
|---|---|
| Enhance Website Functionality | To understand how visitors interact with our site and ensure that it is functioning correctly across different browsers and devices. |
| Improve User Experience | Tailor the site’s layout and features based on user preferences and behaviours. |
| Security and Monitoring | Detect and prevent fraudulent activity or misuse of our services. |
| Analytics and Performance | Analyse trends to optimise site performance and gather insights for improving content and services. |
Data Collection
We gather personal data from a range of sources depending on the context of the legal services provided. This list is not exhaustive:
| Source | Details | Why We Collect This Data |
|---|---|---|
| Public Records and Databases | Electoral Register, Companies House, Register of Judgments, Orders, and Fines | To verify identities, confirm addresses, and obtain information necessary for legal proceedings or compliance. |
| Debt Management Companies | StepChange, PayPlan, financial circumstances, income, expenditure, other creditors | To work collaboratively in managing debt solutions and ensuring accurate and relevant financial information. |
| Original Creditors | Credit agreements, payment history | To confirm the details of the debt and establish the contractual relationship between the original parties. |
| Financial Institutions | Banks, payment providers, insolvency, financial settlement scenarios | To facilitate financial transactions, manage insolvency cases, and address any payment disputes. |
| Directly from You | Phone, email, correspondence, forms on our website | To understand your situation, provide advice, and communicate effectively regarding ongoing matters. |
| Nominated Third Parties | Family, legal representatives | To respond to authorised requests on your behalf and ensure that we act in accordance with your instructions. |
| Law Enforcement | Police, other agencies relevant to legal proceedings or compliance | To support investigations, report unlawful activity, or fulfil legal and compliance obligations. |
| Service Providers | Solicitors, legal advisors, case-related information | To collaborate on complex legal cases, obtain specialist advice, or utilise external services for case management. |
| Vehicle Registered Keepers | Driver information for parking disputes | To identify the driver involved in parking disputes and manage enforcement actions where necessary. |
| Email Analytics | Assess the effectiveness of communications, used internally | To evaluate and optimise our communications for better service delivery and client engagement. |
Purpose of Processing
We will only process your personal data where we have a legal basis to do so. The purposes for which we use your personal data include:
| Activity | Objective | Legal Grounds |
|---|---|---|
| Daily Activities | To maintain effective communication with clients | Legitimate interests and the performance of contractual duties |
| Client Relationship Management | To maintain effective communication with clients and relevant stakeholders, ensuring proper documentation of interactions and updates | Legitimate business interests in managing and maintaining client relationships |
| Handling Enquiries, Complaints, and Disputes | To address and resolve any queries, complaints, or disputes raised by individuals/clients | Legitimate interests in maintaining service standards and compliance with legal requirements |
| Improving our Services | We may use aggregated, anonymised data to improve our services and client interactions. This involves analysing trends, monitoring service quality, and implementing new processes | Legitimate interests |
Data Protection Impact Assessments (DPIAs) and Legitimate Interest Assessments
For activities involving high-risk processing, we conduct Data Protection Impact Assessments (DPIAs) to evaluate and mitigate potential risks to your data. When relying on legitimate interests as a basis for processing, we also carry out Legitimate Interest Assessments to ensure that our interests do not override your rights and freedoms.
Data Sharing
Gentle Tech Limited may share your personal data with various third parties as necessary, depending on the circumstances and the nature of our services. When sharing your data, we ensure that third parties comply with data protection laws and use your data only for the specified purpose. We will only share data if we have a data sharing agreement in place. Below is an overview of who we may share your information with and why:
| Category | Details |
|---|---|
| Clients | We act on behalf of clients, sharing updated info to manage matters effectively. |
| Authorised Individuals | With permission, info may be shared with authorised individuals like relatives or legal representatives. |
| Debt Management Agencies | Share info with agencies like Christians Against Poverty, Payplan, StepChange with consent. |
| Third-Party Service Providers | External providers like IT support, print management, and legal services may access data. |
| Others as Agreed by You | Share data with other parties as specified by you with consent. |
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. Generally:
Client Data: Retained for 6 years from the closure of the case or matter.
Non-Client Data: Retained for 6 years following the last interaction or legal obligation.
After the retention period expires, your data will be securely deleted or anonymised.
International Data Transfers
We do not usually transfer personal data outside of the UK. If we do, we will ensure that the transfer is lawful and that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or an adequacy decision.
Your Rights
We are committed to ensuring you understand how we use your personal data. This notice provides you with a comprehensive overview of the data we process and the reasons for doing so. The following is a list of your rights under the Data Protection Act 2018.
| Nature of the Right | Description | Conditions/Exceptions |
|---|---|---|
| Access Your Data | Request a copy of personal information held (Subject Access Request) | Exemptions if legally required to retain data, needed for legal claims, or regulatory obligations |
| Correct Your Data | Inform us if data is inaccurate or incomplete | May request evidence for certain corrections |
| Have Data Erased | Request deletion of data in specific circumstances | Does not apply if needed for legal obligations or claims |
| Restrict Use of Your Data | Request restriction on use of data in certain situations | We may continue processing if essential for legal purposes or with consent |
| Data Portability | Receive data in a structured format for transfer | None specified |
| Object to Processing | Object to use of data in certain circumstances | We may continue processing if strong legal grounds or necessary for legal purposes |
| Automated Decision Making | We do not use automated decision-making or profiling | N/A |
How to Exercise Your Rights
If you wish to exercise any of your rights, please contact us using the contact details listed in this privacy notice. In cases where we process your data on behalf of another party, such as a client, we may refer you directly to them, or to the original creditor or debt owner for specific queries.
For further information, you can visit the Information Commissioner’s Office (ICO) website: https://ico.org.uk
Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed. These include:
Secure servers, encryption, and access controls including IP whitelisting.
Pro-active network monitoring and intrusion detection.
Staff training and confidentiality agreements.
Regular reviews and audits of our security practices.
In the event of a data breach, we will notify you and the ICO where legally required.
Cookies
Cookies and How We Use Them
Cookies are small text files that are stored on your device (computer, tablet, or smartphone) when you visit websites. These files contain data that help the site remember your preferences, improve your browsing experience, and collect analytical information. Cookies are widely used to make websites function efficiently and to provide useful information to website owners.
When you visit our website, various cookies may be placed on your device. Below, we outline the types of cookies we use, their purpose, and how you can manage them:
| Cookie Type | Purpose | Examples |
|---|---|---|
| Essential Cookies | Necessary for basic functioning, enable core features like page navigation, security settings, and accessibility | sessionid: Maintains the user's session on the website, ensuring smooth navigation between pages. XSRF-TOKEN: Provides security by preventing cross-site request forgery attacks. cookieConsent: Stores the user’s cookie preferences and consent settings. ASP.NET_SessionId: Identifies user sessions on sites built using ASP.NET technology. cfduid: Used by content delivery networks (e.g., Cloudflare) to identify trusted web traffic and maintain security settings. |
| Performance and Analytics Cookies | Collect information about user interaction, track user activity, understand user behaviour, identify popular areas, and improve user experience | _ga, _gid, _gat |
| Functional Cookies | Cookies that save your settings for future visits Which remember choices like preferred language or region, provide enhanced features, and services like live chat support | language: Stores the user’s preferred language (e.g., "en" for English). geoLocation: Saves the user’s location to provide region-specific content. chatbox_open: Remembers whether the live chat window is open or closed. theme: Retains the user's theme preference (e.g., dark or light mode). preferences: Keeps track of site settings, such as font size or layout options. |
| Targeting and Advertising Cookies | Cookies by third-party ad networks like Google AdWords, Facebook Pixel. These cookies deliver content relevant to interests, track browsing habits, show tailored ads, limit ad frequency, and measure marketing effectiveness | _fbp (Facebook Pixel): Tracks user interactions for targeted advertising and retargeting on Facebook and Instagram. IDE (Google DoubleClick): Used by Google to provide and track ad performance and target ads based on user interactions. NID (Google Ads): Stores user preferences and personalises Google ads on Google services. _gcl_au (Google AdSense): Used to measure ad conversion rates and performance across websites using Google AdSense. ANID (Google): Identifies and targets users for Google Ads campaigns based on their preferences and browsing patterns. fr (Facebook): Identifies users for targeted advertising and monitors the effectiveness of Facebook ads. |
Third-Party Cookies
In addition to the cookies set by us, some third-party services integrated into our site may place their own cookies on your device. For instance, when we embed content from social media platforms or use analytical tools, these third parties may use cookies to collect data independently. We have no direct control over the data collected by these external services.
How to Manage and Control Cookies
You have the right to decide whether to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your settings to decline them if you prefer. Be aware that disabling certain cookies may impact the functionality and user experience of our website.
To learn more about managing cookies, including how to enable or disable them in your browser, visit www.allaboutcookies.org. This site provides step-by-step guides for different browsers and more detailed information on how cookies work.
Adjusting Your Cookie Settings
On Chrome: Go to “Settings” > “Privacy and Security” > “Cookies and Other Site Data” to manage your cookie preferences.
On Safari: Open “Preferences” > “Privacy” to block or allow cookies.
On Firefox: Navigate to “Options” > “Privacy & Security” > “Cookies and Site Data.”
On Edge: Go to “Settings” > “Cookies and Site Permissions” to choose how cookies are managed.
You can also use browser add-ons or extensions, such as the Google Analytics Opt-out Browser Add-on, which prevents your data from being used by Google Analytics.
More Information
For more comprehensive details on how cookies function, how they are used by websites, and tips on protecting your online privacy, visit the ICO’s Guide to Cookies.
If you have any further questions regarding our use of cookies, feel free to contact us via the details provided in our privacy notice.
Complaints
If you have any concerns about our handling of your personal data, please contact us directly at hello@gentletech.co.uk. You also have the right to lodge a complaint with the ICO:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: www.ico.org.uk
Changes to This Privacy Notice
We may update this Privacy Notice from time to time in response to changes in the law or our business operations. The latest version will always be available on our website.
GentleTech Ltd Privacy Policy
updated November 2024
