Privacy Policy

Last updated: June 2025

Our commitment:

At Manx Collections Limited, we are aware of the trust you place in us and our responsibility to keep your personal data secure in accordance with the Isle of Man Data Protection Act 2018 and UK Data Protection Act 2018 (hereinafter referred to as data protection legislation).

This privacy notice covers:

How and why we process your personal information;
The sources of information about you;
The parties we may disclose it to;
How long we will retain your information;
What rights you have in respect of your personal data; and
How you can contact us with any further queries or concerns.

The Data Controller:

Manx Collections Limited is the Data Controller for the purposes of data protection legislation and in relation to all the personal data provided to us.

The legal basis for processing your data:

The Data Controller may process personal data when any of the following apply:

For the performance of contracts we enter (or may enter) into with you for our goods, services or finance products, or with third parties or employment contracts;
For compliance with legal and regulatory obligations to which the Data Controller is subject;
Where it is necessary for the performance of a task carried out in the public interest; and
Where it is necessary for the purpose of the legitimate interests pursued by the Data Controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

Why do we collect personal information?

We collect your personal information for the following purposes:

To consider proposals from you for our goods, products and services, or for considering third party service agreements, in preparation for the entering into contracts;
To manage accounts where we are the owner, or on behalf of the owner;
For arrears management;
For tracing and debt recovery, where people are not responding using known contact details;
To assess your creditworthiness, and that what you have told us is true and correct;
To ensure the information we hold is accurate;
To carry out database activities, including, data loading, data matching, data linking and system and product testing;
To provide existing customers with our goods, products and services; to perform obligations under agreements for goods, products and services; and maintain our ongoing relationships with you;
To understand how our customers use our goods, products and services to enable us to improve our services to you;
To manage any third-party arrangements in order to run our business and provide you with goods, products and services;
To consider any applications for employment or sponsorship;
To help detect and prevent fraud;
To develop and carry out marketing activities, send marketing communications and to make sure any offers are relevant for you; and
To comply with our legal and regulatory obligations as a regulated financial services provider.

Your personal information is only collected and used for the purpose(s) it was provided for, and of which you were aware at the time your information was supplied to us. We may process your information if it reasonably considers that processing is necessary for another reason and that reason is compatible with the original purpose. We will limit the collection of your personal information to only that which is needed in order to satisfy the intended purpose.

It is ultimately your decision as to whether to provide us with any of your personal information, however, please note that if you fail to provide information we have requested, or you fail to provide accurate information, we may not be able to engage with you further.

What information do we collect and how do we collect it?

In order to fulfil the purposes above, we will need to collect your personal information. We collect it from you when you, or our clients and agents, initially provide it to us, every time you contact us during the administration of your relationship with us, and from additional sources such as background checks and/or references. Information is collected when you meet with us, complete forms, correspond with us, telephone us, or send us an email. We may also get your personal information from an intermediary.

This information can include all, or a combination of any of the items listed below:

General personal details including your title, full name, date of birth, place of birth, nationality, gender, marital status;
Your contact details (current address, previous addresses, telephone numbers, e-mail);
If you’re applying for a job with us, employment details such as employment status, employer contact details, benefits and salary information; and character references;
Information about previous loans or accounts you may have had relevant to your current requirements;
Financial details such as bank account details;
Publicly available information (generally obtained through internet searches) such as news articles or public register information which is obtained from background searches or reference checks;
Customer circumstances, directly through interactions with Manx Collections Limited; through a 3rd party authorised to work on a customer’s behalf; or through an agency working on our behalf;
Court judgments, decrees and administration orders;
Bankruptcies, Individual Voluntary Arrangements (IVAs), debt relief orders and similar events;
From screening companies, credit reference agencies and fraud prevention agencies.

Sensitive Information:

Certain types of personal information are classed as “sensitive” under the data protection legislation, or otherwise referred to as “special categories” of data. This includes information about your health, race, ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.

We do not need to collect your sensitive personal data during the normal course of our business. However, sometimes we may indirectly come across sensitive information such as your health data. For example, if we are made aware of a customer who is subject to a court registered Enduring Power of Attorney, we will be aware of the fact that a data subject may have mental health issues requiring the use of the Power of Attorney, and thus we have indirect information relating to a customer’s health. In order to be able to process any sensitive personal data, we will need your consent. In the event we are likely to (or do) come into possession of your sensitive personal data, we will contact you separately to seek your consent for its processing. In rare instances where consent for processing cannot be given or cannot reasonably be expected to be given by the customer; we may process this data only where processing will be necessary for the performance of a task carried out in the public interest to safeguard the economic wellbeing of certain individuals.

How do we use your personal information?

We store and process the personal information that you (or third parties) have provided to us in any or all of the following ways:

Administrative in order to allow us to perform our obligations under any agreement or account terms and conditions, or employment contract you have entered into with us;
To consider any application for employment or sponsorship you may have submitted;
To supply you with information about goods, products and services that either you have requested from us, or wish to provide to us;
To manage our relationship with you;
To investigate complaints;
For general business purposes and to prepare management and accounting information necessary for the conduct of our business, including audit and security requirements;
For the prevention and detection of crime, including AML purposes, fraud detection and debt collection;
Responding to regulatory requirements;
Passing information to the regulator or Financial Ombudsman as needed to allow investigation into whether we have acted in the right way;
Defend legal claims; and
To comply with our legal, regulatory and statutory responsibilities.

Information you submit through our website may be held and processed by our Internet Service Provider, but it is only held and processed on our behalf and under our strict instruction.

Disclosure of Personal Information:

During the term of your relationship with us we may disclose your personal information to any of the following parties to allow us to properly manage our relationship with you:

Manx Financial Group PLC or its subsidiaries where those companies may provide shared services to assist with Manx Collections Limited processing of your agreement; or where they may provide complimentary services that you may require. Except where such interests are overridden by your interests or fundamental rights and freedoms;
To screening companies to enable us to conduct background checks to comply with our legal obligations;
Your Official Receiver or appointed insolvency practitioner if we receive notice of your insolvency, bankruptcy or insolvency proceedings / arrangement;
Debt collecting, debt chasing or another agent for enforcing payment of monies owed to us;
Tracing companies to assist in our efforts to trace customers if we lose contact with them;
Our insurers and insurance brokers where required for underwriting our risks and as part of ongoing risk assessments; and acquiring appropriate insurance cover in relation to specific goods, products and/or services that we offer;
Court Services if we issue any proceedings against customers or as a result of any other regulatory instruction;
Payment processors, if you have chosen to make payments via debit or credit card;
Debt purchasers/sellers who may hold a legal or beneficial interest in the debt;
To your credit intermediary (if you used one) for the duration of your agreement(s) with us, and/or to our Isle of Man and UK based finance partners (for further information about this please contact us using the contact details at the end of this document);
To persons acting as our agents or on our behalf under a strict code of confidentiality where we outsource functions relating to our goods, products and services (for example, loan administration and management, our IT system providers, document storage and archiving companies etc.);
To anyone we transfer or may transfer our rights and duties under your agreement(s) with us;
Back to you during the course of your relationship with us;
To other parties legally connected with your agreement (e.g. guarantor and other people named on the agreement;
If you are a current or former employee, to future employers who seek references about you (who will require your consent to do this);
To relevant Financial Services Ombudsman Services;
To law enforcement and fraud prevention agencies; or
To legal, regulatory or statutory bodies (such as the Financial Conduct Authority) as required by law or regulation.

Otherwise, we will keep all of your personal information confidential unless you give us consent to transfer it to a third party.

It is not normally necessary during the usual course of business to transfer your personal data outside of the Isle of Man or the UK, however, in the event it is necessary, it will be done so in accordance with the requirements of data protection legislation. These requirements include the provision that the recipient of your personal data must have the same level of protection in place as you are entitled to on the Isle of Man or in the UK. We will advise you in the event that your personal data is to be transferred in this manner.

The exception to this is, if you as a customer live outside the Isle of Man, UK or the EEA and we are sending your personal information back to you, this will be necessary in order to communicate with you and for providing you with our goods and services. Our e-mails to you are subject to encryption and any sensitive documentation will be sent via registered mail.

Credit Reference Agencies:

We will be collecting payment data on behalf of ourselves and lenders we work with which will then be sent to the credit agencies to update your credit file. Your credit file will be updated detailing any payment you make under it and/or any default or failure to keep to its terms.

This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.

Manx Collections Ltd currently use the following 3 credit reference agencies. For further information regarding how they will process your information, please refer to the links provided:

TransUnion - https://www.transunion.co.uk/legal/privacy-centre?
Equifax - www.equifax.co.uk/crain
Experian - www.experian.co.uk/crain

Fraud Prevention Agencies:

We have a legal obligation and legitimate interest to report suspected fraud to law enforcement and fraud prevention agencies, and we are not permitted to share the detail of any disclosure with you.

We may share your personal information with fraud prevention agencies if we feel fraud has been or might be committed. We will use the information to confirm identities, help prevent fraud and/or money laundering or fulfil any contracts you or your business has with us.

These agencies collect, maintain and share data on known and suspected fraudulent activity for the purposes of fraud prevention. These records may be searched and shared with other organisations by the fraud prevention agencies. This is to support their duty to prevent, detect, investigate and prosecute crime.

If fraud is detected, you could be refused certain services, finance or employment.

The fraud prevention and law enforcement agencies we may share data with are:

CIFAS
Dun & Bradstreet
Equifax
Experian
TransUnion
Law enforcement agencies
Regulatory bodies

Please telephone or write to us at the address stated below if you would like further details of the fraud prevention agencies.

How long do we retain your personal information?

We are permitted by law to retain your information in a form which permits identification of data subjects that is no longer than is necessary for the purposes for which the personal data are processed. This includes our legal requirement to hold some information for at least six years following the termination of a customer relationship or transaction.

We will hold the personal information of our customers, their accounting records, client due diligence (CDD) and transaction records for a minimum of six years, except where records are required for investigation by law enforcement, where they will be retained for as long as required by the competent authority.

If you have been unsuccessful in applying for a job with us, we will retain your information for a maximum of 6 months unless you give us permission to retain it for longer.

Once your information is no longer necessary in accordance with the above, it shall be destroyed in line with data protection legislation.

Your Rights:

Under data protection legislation you have the following rights free of charge:

1. Access to Personal Data

Subject to exceptions detailed in data protection legislation, you have a right of access to all personal data we hold about you. If you wish to exercise this right, or you have any questions regarding your personal data, please write to the Data Protection Officer at the address below. We will respond within one month from receipt of a valid request, and in any event, without undue delay.

2. Automated Decision Making:

If automated decision-making technology is used, you have the right not to be subject to a decision based solely on automated processing and request human intervention.

Manx Collections Limited does not use any kind of automated decision-making technology.

3. Rectification

You have the right to the rectification of inaccurate data, and to obtain completion of incomplete personal data. To correct or amend your personal data, please contact the Data Protection Officer at the address below with the details. We may need to verify the accuracy of the new data before changes will be made.

4. Erasure

In certain situations, you have the right to request that your personal data is erased, however, there are limitations to this right.

Examples of grounds for exercising your right to erasure include:

Personal data is no longer necessary for the purpose of the performance of a contract between us and you;
Where data has been unlawfully processed;
Where data has to be erased to comply with a legal obligation;
Where a right to object to direct marketing or the right to object to processing has been exercised.
Examples of limitations to your right of erasure include:
It is necessary for the performance of a contract between us and you;
Our compliance with legal obligations to retain client records for certain periods of time (as detailed above); and
Establishment, defence or exercise of legal claims.

5. Restriction of Processing

You have the right to restrict our processing of your personal data in the following circumstances:

If you contest the accuracy of personal data processed by us, (we may restrict processing for a limited period to enable us to verify the accuracy and amend the data as necessary);
We no longer require your information for the purposes we originally obtained it;
We have no legitimate grounds for processing your information or your information has been processed unlawfully.

If you wish to exercise this right, please contact the Data Protection Officer at the address below with the full details.

6. Data Portability

You have a right to receive your personal information that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to have this personal data transmitted to another data controller (i.e. another business), where technically feasible to do so. This right only applies to automated information that was initially provided to us, or where we used the information to perform our obligations of a contract.

7. Right to Withdraw Consent

You have the right to withdraw consent at any time, where consent is used as the legal basis for processing.

8. Right to Object

You have the right to object to us processing your personal data in the following circumstances:

For direct marketing purposes;
Profiling in relation to direct marketing.

9. Right to Lodge a Complaint

If you have a complaint regarding the way we are processing your personal data, please address it with us in the first instance in the hopes that we will be able to resolve the matter with you. However, if you do not want to address your concerns to us, or we have failed to satisfactorily respond to your data protection complaint, you have the right to complain to the Data Protection Supervisor. The contact details are below:

Isle of Man: United Kingdom:

Information Commissioner Information Commissioners Office

First Floor Wycliffe House

Prospect House Water Lane

Prospect Hill Wilmslow, Cheshire

Douglas SK9 5AF

Isle of Man Tel: +44(0) 303 123 1113

IM1 1ET

Tel: +44(0) 1624 693260

Marketing:

Manx Collections Limited will not directly market goods, products or services to you.

Cookies:

Our website uses a number of cookies to store data on our visitor's computers. For further information, please refer to our Cookie Policy on our website, or by contacting us (contact details below).

What is aggregate information?

Aggregate information is used to show us the total number of visits to our website and which parts of the site are used and most. Aggregate information does not identify individuals, as it does not contain any personal data. This information helps us in developing our website and improving the service we offer you.

Changes to our privacy notice:

We keep our privacy notice under regular review, and we may change it to reflect any changes in the law or our privacy practices. We will place any updates on the web page and encourage you to check is regularly. We will indicate at the top of this privacy notice when it was last updated. Where you have provided us with your email address, we may also contact you to let you know that we have updated the notice. We may also take that opportunity to ask you if you would like to update your marketing preferences.

The Data Protection Officer and Contact Details:

If you have any questions or concerns regarding this notice or you wish to exercise your rights, please contact us, addressing your query to the Head of Compliance:

Writing: Manx Collections Limited, Fourth Floor East, Matrix House, Basing View, Basingstoke, RG21 4FF

Telephone: +44 (0)161 464 4400

Email: info@manxcollections.co.uk

Manx Collections Limited. Registered in England: No 2615535. Registered Office: Attwood House, Unit 10B, Mansfield Business Park, Lymington Bottom Road, Medstead, Alton, Hampshire, GU34 5PZ. Authorised and regulated by the Financial Conduct Authority, firm registration number 619113.