Privacy & Security

Privacy & Security

This privacy policy sets out how Athena Collections Ltd (“Athena”) uses and protects your personal data.

Please read the following terms carefully to understand how we collect, use, store and protect your personal data when you use the Athena Collections website (“Website”), contact us, use our services, interact with Athena AI, or where we process personal data in connection with debt recovery activity.

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, we have either been instructed by the original creditor to recover an outstanding debt on their behalf, we have a legitimate interest in processing your data, we are taking steps at your request, or we have obtained your consent where consent is required. Athena will usually act as the data controller for the personal data we process, although in some circumstances we may also process personal data on behalf of another organisation.

We may have obtained your data for marketing our services to you and may contact you from time to time where we believe we have a legitimate interest to do so, or where you have consented to receive marketing communications. You may at any time advise us that you do not wish to be contacted for marketing purposes and we will update your preferences and/or delete your personal data where appropriate.

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.

Debt Collection

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 interests, we may also undertake the following activities, including but not limited to:

Tracing, which may include improving the data we already hold about you using information 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 that the data we control is correct and we may share your information, in accordance with our legitimate interests, 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,

Process servers,

Credit Reference Agencies,

Tracing 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 appropriate steps to ensure that your data and relevant rights and freedoms are safeguarded in accordance with UK GDPR and applicable data protection legislation.

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, Athena may be required to continue processing your data to protect the rights of another natural or legal person, for reasons of important public interest, or where processing is required for the establishment, exercise or defence of legal claims. It may be appropriate to continue processing data while a request for restriction is being investigated.

Your data will be held securely in compliance with data protection legislation.

Your data may be shared with third parties to perform services on our behalf. 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 data where we believe that stopping processing would not be in your vital interests, for example where we believe that stopping processing 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 who may store or access your data and who may be located outside of the United Kingdom or EEA, including, but not limited to, the United States. We will not transfer your personal data outside of the United Kingdom or EEA unless appropriate safeguards are in place. In relation to transfers to the United States, we may rely on the UK Extension to the EU-US Data Privacy Framework where the relevant provider is certified, or another lawful transfer mechanism where appropriate.

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 have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR. Athena’s Privacy Policy provides you with information including: our purposes for processing the personal data, retention periods for that personal data, and who it will be shared with.

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.

All the above information is available in this Privacy Policy.

You may also request a copy of the personal data we process about you. This is known as your right of access. Additional copies, or requests which are manifestly unfounded or excessive, may be subject to a reasonable fee or rejected where permitted by law.

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. However, it is unlikely that we will delete your data where we need to retain it for debt recovery, legal, regulatory, complaint handling, fraud prevention or record-keeping purposes.

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 compelling legitimate grounds for processing which outweigh your rights and freedoms under UK GDPR. We may also continue to process your personal data where it is required for the establishment, exercise or defence of legal claims. This right gives you the ability to raise your objections, but it is not a blanket right to have all processing stopped.

Where processing is based on your consent or for the performance of a contract, you have the right to data portability. As outlined within this Privacy Policy, we will in most circumstances process your data under its legitimate interest to do so. Whilst it is unlikely that this right will apply in the context of our processing, we will consider requests where you feel this right applies.

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 co*****@******************co.uk or write to Data Protection Officer, Athena Collections, Lytchett House, 13 Freeland Park, Wareham Road, Poole, BH16 6FA 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

The Website’s web servers may automatically track the internet domain address from which you visit us and analyse this data for trends, statistics, security and website performance purposes.

If you contact us by any means, we may keep a record of that correspondence.

Athena Collections or our third-party providers of marketing, website, analytics, content and chatbot services may collect certain information relating to computer location, URL, 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, any searches conducted on the Website and any interactions with Athena AI. 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.

Athena AI and Website Chatbot

We use an AI-assisted website chatbot, known as Athena AI, to help visitors obtain general information about Athena Collections Ltd, our services, debt collection processes, pricing, frequently asked questions and related topics.

Athena AI is intended to provide general information only. It does not provide legal, financial or professional advice and should not be relied upon as a substitute for speaking directly with Athena Collections Ltd or obtaining independent advice where appropriate.

When you use Athena AI, we may collect and process information you choose to provide during the chat. This may include your name, business name, job title, email address, telephone number, enquiry details, case information, invoice information, debt information, documents or details you provide, and any other information included in your messages.

We may also collect technical and usage information relating to your interaction with Athena AI. This may include session identifiers, user identifiers, timestamps, platform information, browser or device information, IP address, conversation duration, chat transcripts, chatbot responses, logs, metadata, usage information, error or warning information and other technical data generated during the interaction.

Athena AI is provided using technology supplied by an approved third-party chatbot and AI technology provider. Information submitted through Athena AI may be processed by that provider on our behalf for the purpose of operating, supporting, monitoring, securing and improving the chatbot service.

Chatbot conversations may be automatically recorded as transcripts. These transcripts may be reviewed by Athena Collections Ltd and/or our approved service providers for quality monitoring, training, troubleshooting, compliance, security, analytics, performance review and service improvement purposes.

You should not provide unnecessary personal data, special category data, confidential information, bank details, payment card details, passwords, National Insurance numbers, medical information, information relating to children, or any information you do not want processed through Athena AI.

We may use information submitted through Athena AI for the following purposes:

  • • responding to your enquiry;
  • • helping assess whether our services may be suitable;
  • • following up with you where you have asked us to do so or where it is otherwise lawful;
  • • maintaining internal records;
  • • reviewing, testing and improving Athena AI;
  • • monitoring chatbot performance, accuracy and user experience;
  • • detecting and preventing misuse, spam, fraud, abuse or unlawful activity;
  • • complying with legal, regulatory and contractual obligations;
  • • protecting our business, staff, clients, website and systems.
  • Our lawful basis for processing information submitted through Athena AI will usually be one or more of the following:
  • • our legitimate interests in operating, improving and securing our website, responding to enquiries, managing prospective client relationships and providing information about our services;
  • • taking steps at your request before entering into a contract;
  • • compliance with a legal or regulatory obligation;
  • • consent, where we specifically ask for it.

Athena AI may use conversation context, variables, logs and technical data to generate responses, route enquiries and assist users during their interaction with the chatbot.

Athena AI will not make solely automated decisions that produce legal or similarly significant effects about you. Any decision to accept an instruction, pursue a debt, recommend legal action, escalate a matter, issue proceedings, or take further recovery action will involve human review.

We may use chatbot analytics and evaluation tools to assess how Athena AI performs. This may include reviewing whether enquiries were resolved, whether users appeared satisfied, how often the chatbot was used, how many interactions took place, whether issues were escalated and how the chatbot can be improved.

Where information processed through Athena AI is transferred outside the United Kingdom or European Economic Area, we will ensure that appropriate safeguards are in place. This may include an adequacy decision, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

We will retain chatbot data only for as long as reasonably necessary for the purposes set out above. Where a chatbot conversation relates to a client enquiry, prospective instruction, complaint, legal claim, debt collection matter or regulatory issue, we may retain it in line with our usual enquiry, account, complaint, legal or regulatory retention periods. Other chatbot data may be retained for a shorter period for monitoring, security, analytics and service improvement purposes.

You may exercise your data protection rights in relation to personal data submitted through Athena AI by contacting us using the details set out in this Privacy Policy.

Statistical Data and Cookies

We use a consent tool to ask for your permission before setting non-essential cookies (e.g. analytics and advertising). These cookies help us improve our services and deliver relevant content. They will only load if you accept them or enable them in your preferences. You can change or withdraw consent at any time via the ‘Privacy settings’ link in the footer.

Essential cookies (strictly necessary for the website to function) will always remain active. Non-essential cookies, such as those used for Google Analytics and advertising, are disabled by default until you provide consent.

(For more details on the cookies we use, please see the Cookie Table below.)

Security

Where you submit personal data to us, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

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 third-party cookies you should not be prevented from properly using this site. If you disable all cookies you may 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.

Your Rights

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 co*****@******************co.uk
  • 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 was last updated in May 2026 and is reviewed regularly to ensure compliance with UK GDPR and related regulations.