Privacy & Security
Please read the following terms carefully to understand how we will manage your Personal Information. By using the Athena Collections website (“Website”), you agree to the processing of information about you as detailed in this policy.
Athena is a debt collection agency and is authorised and regulated by the Financial Conduct Authority (FCA) in respect of accounts formed under the Consumer Credit Act 1974 (amended 2006), authorisation number 791206. Athena is also registered with the Information Commissioner’s Office (ICO) and the Credit Services Association (CSA).
If we have contacted you then we have either been instructed by the original creditor to recover an outstanding debt on their behalf or we have a legitimate interest or gained your consent. Athena is the data controller and the data processor.
We may have obtained your data for marketing our services to you and may contact you from time to time if we believe we have a legitimate interest to do so. You may at any time advise us that you do not wish to be contacted for marketing purposes and we will immediately update your preferences and or delete your personal data.
Using Our Services
It is your choice whether to provide Personal Information to use our services, but if you choose not to provide this information when requested, you may be unable to use our services.
If you use our services, we may record your details in order that we can:
- comply with legal and contractual requirements, or
- be able to contact you, or
- resolve any queries
We will only use your Personal Information as is required to provide, sell or supply our services (“Services”) that may be reflected in the Website, or as permitted by data protection law, or for any other purposes as requested by or agreed with you.
Services will include providing emails which you have chosen to receive following access of our Services, informing you by email of any services similar to those subscribed by you, emails inviting you to complete a review of our service, and any such complying with our legal requirements.
Following our instruction, the original creditor transferred your personal data to us. The data originates from your contractual relationship with the original creditor and includes data collected by them during the life of your account, such as name, address, statement of account, copy invoices, telephone number, email address etc.
Debt collection is of public interest and we have a legitimate interest to process your personal data as we have been formally instructed by the original creditor in respect of recovering an outstanding debt. Processing your personal data is necessary to collect the debt and is allowed even if you do not consent to the processing.
In accordance with our legitimate interest we may also undertake the following activities, but not limited to:
Tracing, which may include improvement of the data we already hold on you from Credit Reference Agencies.;
Search public registers and domains;
Linking historical accounts we may hold on you (from previous cases serviced by us);
Obtaining data from suppliers where permitted to do so;
Where necessary, we will verify the data we control is correct and we may share your information in accordance with our legitimate interest with;
The original creditor,
Other debt collection agencies,
Solicitors, Insolvency practitioners and the courts in the event legal action is required to pursue or defend our or our client’s interests,
Credit Reference Agencies,
High Court Enforcement Officers,
Organisations you have authorised to act on your behalf,
Ombudsmen, regulators and other authorities. This may include law enforcement agencies and other local and government agencies,
Fraud prevention agencies,
Independent financial and professional advisors,
Executors of an Estate,
Her Majesty’s Land Registry,
Approved subcontractors who provide goods and services to us. We will take all appropriate steps to ensure that your data and relevant rights and freedom are safeguarded in accordance with the General Data Protection Regulation (GDPR).
In order to evaluate your ability to repay we may request that you complete a financial affordability assessment and we will process this financial information to agree repayment plans and assess affordability. To allow us to make an informed decision, we may also process your reasons for non-payment subject to information you provide to us.
Unless otherwise agreed with you or there is a legal requirement or we believe it is in your ‘vital interests’, we will not process special categories of personal information (otherwise known as ‘sensitive personal data’).
The data we process and hold on you comes from the original creditor, CRA’s and other approved data suppliers. You may decide to provide us with additional information which may help us to manage your account more appropriately.
Where a debt is due and payable, the data will be retained until such time the debt is either paid or closed and subject to the period of time we are legally obliged to retain.
General Data Processing
In many circumstances, it will be required for Athena to continue processing your data, to protect the rights of another natural or legal person, or because it is an important public interest of the union or member state. It may be appropriate to continue processing data whilst a request for restriction is being investigated.
Your data will be held securely in compliance with data protection legislation.
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 our Group happens, then other parties may use your data in the same way as set out in this notice.
We have a legal obligation to provide your personal data when we are audited by regulatory authorities to prevent, monitor and evidence any fraud, money laundering and other criminal activities.
You have the right to withdraw your consent where we are processing your data using consent as the legal basis. In the context of administering your account, this legal basis is only likely to apply, where you have disclosed ‘special categories’ of personal data to Athena. We will (where our legitimate interest does not override this right) consequently stop processing the data.
We reserve the right to continue processing the data, where we believe that it would not be in your ‘vital interests’, for example, where we believe that to stop processing the data may result in significant harm to your well-being.
Generally, your personal data will not be transferred outside of the United Kingdom or European Economic Area (EEA) however we may decide to do so in accordance with our legitimate interests (for example international debt collection). If we do so, then we will ensure there are suitable safeguards in place to comply with GDPR.
We also use third party service providers to store or who may access your data, which may be located outside of the EEA, including, but not limited to the United States. We will never transfer your personal data outside of the EEA without ensuring the safety and protection of your personal data. In relation to transfers to the United States, we will rely on the Privacy Shield, which is an international data transfer agreement where US companies commit to a higher level of privacy protection than is required by US law.
We will retain your data for as long as required for the lawful purpose for which it was obtained providing that we have a legitimate interest to keep the data. We are also legally required to retain the data for a period of time to prevent, detect and evidence fraud, money laundering and financial auditing.
Personal data will be retained for a period of six years following the closure of the account to allow for the defence of legal claims.
Where calls are recorded, these will be retained for a period of six months from the date of the call however this may be longer if deemed necessary where a complaint arises or legal action is being considered.
You may request information on how we process your personal data, including information on:
- Why we process your personal data.
- What categories of personal data we process.
- Who we share your personal data with.
- How long we store your personal data or the criteria for determining this period.
- What rights you have.
- From where we have received your personal data (if we have not received it from you).
- If your personal data has been transferred to a country outside of the EEA, how we ensure the protection of your personal data.
You may also request a copy of the personal data we process about you. This is known as your Right to Access. Additional copies where considered manifestly unfounded may be combined with a fee or rejected where deemed appropriate.
It is very important that we have the correct information about you and we encourage you to let us know if any of your personal data is incorrect, e.g. if you have changed your name or moved address. Upon being notified we will ensure your data is updated accordingly.
If we process your personal data in an unlawful manner, you may ask us to delete this information. It is however unlikely that we will delete your data unless you have settled the debt or it is closed.
If you have requested we correct your personal data or object to the processing, you may be entitled to the restriction of processing until we have been able to investigate the issue or confirm the accuracy of your personal data (or changed it in accordance with your instructions). This means that we (except for storing the personal data) may process your personal data only in accordance with your consent, or if necessary with reference to legal claims, to protect someone else's rights or if there is an important public interest in the processing.
Please note that once we believe that we have resolved the dispute or validated the accuracy of the data we hold, we will continue to process your data in accordance with our overriding legitimate interest.
If you believe that we do not have the right to process your personal data, you may object to our processing. In such cases, we may continue processing only if we can show our overriding legal grounds for processing out-weigh your rights and freedoms under the GDPR. However, we will process your personal data if it is required for the determination, exercise or defence of legal claims (note that this right only provides you with the ability to raise your objections, not a blanket right to have any and all processing ceased).
If you wish to make a complaint about how we handle your personal data, including in relation to any of the rights outlined above, you can contact our Data Protection Officer at firstname.lastname@example.org or write to Data Protection Officer, Athena Collections, Bourne House, 475 Godstone Road, Whyteleafe, Surrey, CR3 0BL and we will investigate your complaint.
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further information about the ICO and their complaints procedure here.
We are committed to ensuring that your information is secure and to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Information We May Collect Whilst Using our Website
You agree that the Website’s web servers may automatically track the internet domain address from which you visit us and analyse this data for trends and statistics.
If you contact us by any means, you agree that we may keep a record of that correspondence.
Athena Collections or our third-party providers of marketing and content may collect certain information relating to computer location, URL and IP address and domains, browser type, country and telephone area code where your computer is located, the pages of the Website that were viewed during your visit, any advertisements you clicked on and any searches conducted on the Website. Please be aware that this information may be collected even if you do not use our Services.
We may also collect the following information:
- name and job title
- contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers
What we do with the information we gather
We require this information to understand your needs and provide you with a better service and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
Statistical Data and Cookies
We collect statistical data about your user browsing actions, for example but not limited to your IP address, operating system and browser type. This data is collected for system administration and to report aggregate information. This information does not identify an individual.
- obtain statistical data regarding audience size and usage pattern;
- store information about your preferences, allowing us to customise the Website to your interests;
- improve your user experience; and
- to allow the Website to recognise you when you return.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Although we will do our best to protect your Personal Information, we cannot guarantee the security of your information transmitted over the internet to our Website; any transmission is at your own risk. Once we are in receipt of your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access.
What happens if I disable cookies?
You may decide to disable cookies on our site. This depends on which cookies you disable, but in general the site may not operate properly if cookies are switched off. If you only disable 3rd party cookies you will not be prevented from properly using this site. If you disable all cookies you will be unable to use dynamic areas of this site.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
You may request details of personal information which we hold about you under the General Data Protection Regulation. Whilst we will not charge you to access the information you have requested, we reserve the right, where additional copies are requested and are considered manifestly unfounded, to charge a fee or reject the request where deemed appropriate. You can make your request by writing to us at the address specified above.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com
- We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
We may change this policy from time to time by updating this page. You should check this page to ensure that you are happy with any changes. This policy is effective from 25/05/2018.