Privacy Policy

1. Who we are

Prophoenix Solutions Tech (“we”, “us”, “our”) operates update.prophoenixsolutions.com. We are the data controller for personal data collected through this website and in the course of handling claims.

Registered office: 27 Old Gloucester Street, London, England, WC1N 3AX. Registered in England and Wales, company number XXXXXX. Registered with the Information Commissioner’s Office under number XXXXXX. You can reach our data protection contact at [email protected].

2. What personal data we collect

• Identity and contact data. Name, date of birth, current and previous addresses, postcode, email address and mobile number.
• Claim data. The finance provider, approximate year of the agreement, vehicle registration, agreement numbers, the amounts involved and correspondence with your lender.
• Consent records. The exact wording you agreed to, and the date and time you agreed to it. We keep this so we can show what you consented to.
• Technical data. IP address, browser type and version, device type, operating system, referring URL, pages viewed and timestamps.
• Communications. Emails, letters and notes of telephone calls. Calls may be recorded for training and to keep an accurate record of what was agreed. Where calls are recorded we tell you at the start of the call.

We do not ask for special category data. Occasionally a claim involves health or financial hardship information that you choose to give us, for example to explain a period of difficulty. Where that happens we rely on the fact that the data is necessary for a legal claim.

3. Why we use it and our lawful basis

4. Who we share it with

• Your lender or finance provider. We have to identify you to them in order to trace your agreement and make the complaint.
• The Financial Ombudsman Service, where a complaint is referred.
• Our service providers, including email delivery, hosting, telephony and case management. They act on our instructions and cannot use your data for their own purposes.
• Regulators and law enforcement, where we are required to disclose.

We do not sell your data, and we do not pass it to other claims companies or to lead buyers.

5. Where your data is held

Your data is stored on servers in the United Kingdom and the European Economic Area. Where a provider processes data outside the UK, we rely on UK adequacy regulations or on the International Data Transfer Agreement, and we check that appropriate safeguards are in place.

6. How long we keep it

7. Your rights

Under UK GDPR you have the right to:

• Ask for a copy of the personal data we hold about you.
• Have inaccurate data corrected.
• Ask us to delete data where we no longer need it.
• Ask us to restrict how we use it while a dispute is resolved.
• Object to processing we carry out under legitimate interests.
• Ask us to send certain data to you or another provider in a portable format.
• Withdraw consent at any time, including consent to be contacted.

Email [email protected] to exercise any of these. We reply within one month. There is no charge unless a request is clearly excessive.

Note that where we are keeping data to meet a regulatory obligation, we may not be able to delete it on request, and we will explain why if that applies.

8. Marketing

We contact you about your own enquiry or claim because you asked us to. We do not sell your details to third parties for marketing. You can opt out of non-essential messages at any time by replying STOP to an SMS, using the unsubscribe link in an email, or emailing us. Opting out of marketing does not stop messages about a live claim.

9. Cookies

See our Cookie Policy for what we set and how to change your choice. Analytics cookies are not set until you accept them.

10. Security

Data is encrypted in transit, access is limited to staff who need it, and access is logged. No system is completely secure, but if a breach were likely to put your rights at risk we would tell you and the Information Commissioner’s Office without undue delay.

11. Children

This service is for adults. We do not knowingly collect data from anyone under 18. If you believe we hold data about a child, tell us and we will delete it.

12. Complaints

If you are unhappy with how we handle your data, please tell us first using our complaints procedure. You can also complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

13. Changes to this policy

We update this policy when our practices change. The date at the top shows when it was last revised. If a change materially affects you, we will contact you directly.