Privacy Policy
For websites and services of Cleardown Solutions (including Reclaim Portal)

1. This notice tells you what to expect when we collect information about individuals. When we use personal data we are required to do so in accordance with the UK GDPR. We are responsible as a ‘controller’ of personal data for the purposes of the UK GDPR. If you need further information or have any questions or complaints about our privacy notice or privacy practices please contact our Data Protection Officer using the details below:

Data Protection Officer, Cleardown Solutions Limited, Bartle House, Oxford Court, Manchester, M2 3WQ.
Email: DPO@cleardown.co.uk

2. This notice describes:

The personal information that we collect
How we use personal information
The basis upon which we use personal information
How long we keep personal information
Who we share personal information with
Which countries we transfer personal information to
How we protect personal information
The legal rights of individuals whose personal information we process

The personal information that we collect

3. Personal information (personal data) means any information relating to an identified or identifiable natural person.

4. Because of the wide ranging nature of our work, and the different reasons why we need to use personal information, what we collect is very varied and includes:

(a) Information provided to us by the financial services firm that holds an inactive account

Identity and contact data – including name, date of birth, email address, postal address, telephone numbers, passport, national insurance details or equivalent identifiers for non-UK residents. These details represent the most current contact details held by the financial services firm for the underlying consumer. We require these basic details in order to conduct our trace and communication services.

(b) Information provided to us by third parties

Identity and contact data – such as full name, date of birth, email address, postal address, and telephone numbers, are collected. We verify and cross-reference this information provided by financial services firms with various external datasets, including (but not limited to) the edited electoral roll, credit reference agencies, databases of deceased individuals, Royal Mail datasets, and the Department of Work and Pensions. These inquiries may yield additional contact details that are more likely to be actively used by the consumer. In such cases, the updated contact details are added to the consumer's record.
In the course of providing our services we may be informed by a third party of special category data and personal data relating to criminal convictions and offences. This information is collected for the purposes of assisting decisioning of matters related to anti-money laundering and other financial crime.

Identity and contact data – when you choose to donate funds to charity you voluntarily provide information such as full name, date of birth, email address, postal address, and telephone numbers. This is required in order for validation of your request to take place, and provide assurance that the instruction is being place by an authorised individual.

(d) Correspondence

If you contact us, we will keep a record of that correspondence including any contact details.

(e) Website and communication usage

Technical and usage data – including information about how individuals use our website. When you visit our websites, we will collect information about your visit through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources you access.

How we obtain personal information

5. We obtain personal information in different ways, including through:

Direct contact – individuals may give us their personal information by corresponding with us on the website or by post, email or telephone or otherwise.
Clients (financial services firms) – our clients may give us personal information of individuals (for example a client’s employees or underlying consumers) to enable us to provide our services
Third parties or publicly available sources – we may receive personal information of individuals from third parties in connection with the provision of services by us to our clients or from business contact databases or enrichment services. We may also receive information from publicly available sources such as Companies House and HM Land Registry and social media sites.
Our website – we use cookies to help us to provide users with a good experience when browsing the website and allow us to improve the site. Details of the cookies we use, the information we gather and how cookies can be blocked can be found in our Cookie Policy on our website and in our Legal Notices.

How we use personal information

6. We use personal information in a variety of ways including:

To provide our services to our clients and consumers
To recruit employees and subscribers to Cleardown Solutions Limited
To manage and supervise our employees and subscribers
To promote our services and to manage our relationships with clients, prospective clients and business contacts
To meet our legal and regulatory obligations
To meet our audit and insurance obligations

The basis upon which we use personal information

7. We will only use personal information (including special category data and data relating to criminal convictions and offences) when the law allows us to. Most commonly, we will use personal data in the following circumstances:

Where we need to do so to perform a contract we are about to enter into or have entered into – for example a contract of employment
Where it is necessary for our legitimate interests (or those of a third party such as one of our clients) and the interests and fundamental rights of the individual whose personal information we are using do not override those interests – for example where we attempt to return funds to unresponsive clients
Where it is necessary to comply with a legal or regulatory obligation

8. When we use special category data and data relating to criminal convictions and offences it will normally be when this is necessary for the establishment, exercise or defence of legal claims or where we need to do so as an employer, or in the process of establishing communications with a client’s underlying consumer.

9. Generally we do not rely on consent as a legal basis for processing personal information other than in relation to sending direct marketing communications. Consent to receiving direct marketing communications can be withdrawn at any time by contacting us.

How long we keep personal information

10. We will keep personal information in accordance with our data retention practices, which apply appropriate retention periods for each category of personal information. In setting retention periods we take account of the purposes for which the personal information was collected, legal and regulatory obligations on us to retain information, limitation periods for legal action and our business purposes.

Who we share personal information with

11. We may share personal information with third parties including:

In the course of providing services to our clients – for example when seeking to trace a client that resides in a non-UK jurisdiction
When we outsource certain support services – for example IT services and customer relationship management services
Our professional advisers – for example our auditors, bankers and insurers
To regulatory authorities, courts, tribunals and law enforcement agencies – for example the Financial Conduct Authority (FCA)

12. Third parties to whom we transfer personal information are required to respect the security of the information and treat it in accordance with the law. We do not sell personal data to third parties.

Which countries we transfer personal information to

13. In the course of providing services to our clients we may need to transfer personal information outside the UK.

14. Whenever we transfer personal information outside the UK, we implement at least one of these safeguards or ensure that at least one of these conditions applies:

By transferring to a country in relation to which there are UK ‘adequacy regulations’
If we put in place one of the ‘appropriate safeguards’ referred to in the UK GDPR
If one of the exceptions in the UK GDPR applies

How we protect personal information

15. We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate measures to inform our staff about how we collect, handle and keep information secure.

16. We have put in place measures to deal with any suspected personal information breach and will notify relevant individuals and the Information Commissioner of a breach when we are legally required to do so.

The legal rights of individuals whose personal information we process

17. Individuals have the rights set out below. If you wish to exercise any of these rights please contact our Data Protection Officer using the contact details given above.

Request access to their personal information (commonly known as a "data subject access request"). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
Request correction of the personal information that we hold about them. This enables individuals to have any incomplete or inaccurate information we hold, though we will need to verify the accuracy of the new information provided to us.
Request erasure of their personal information. This enables individuals to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their personal information where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal information to comply with local law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to the individual, if applicable, at the time of their request.
Object to processing of personal information where we are relying on a legitimate interest (or that of a third party) and there is something about the individual’s particular situation which makes her/him want to object to processing on this ground as she/he feels it impacts on her/his fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process the information which overrides those rights and freedoms. Individuals also have the right to object where we are processing their personal information for direct marketing purposes.
Request restriction of processing of their personal information. This enables individuals to ask us to suspend the processing of their personal information in the following scenarios: (a) if the individual wants us to establish the information's accuracy; (b) where our use of the information is unlawful but an individual does not want us to erase it; (c) where the individual needs us to hold the information even if we no longer require it as she/he needs it to establish, exercise or defend legal claims; or (d) the individual has objected to our use of their information but we need to verify whether we have overriding legitimate grounds to use it
Withdraw consent at any time where we are relying on consent to process the personal information. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn.

Complaints

18. Individuals have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.co.uk). We would, however, appreciate the chance to deal with any concerns before the ICO is approached so please contact our Data Protection Officer, using the contact details given above, in the first instance.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 09 January 2024.

Privacy Policy For websites and services of Cleardown Solutions (including Reclaim Portal)

Privacy Policy
For websites and services of Cleardown Solutions (including Reclaim Portal)