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Chatbot Privacy Notice

How we use information you send to our Chatbot
Who are Lowell?

Lowell are a group of companies which includes Lowell Portfolio I Ltd and Lowell Financial Ltd.  We buy customer accounts where there is an outstanding balance from a wide range of organisations. These include banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.

If you are a Lowell customer, this means that Lowell has bought your account. We will work with you to arrange repayment of the outstanding balance.

For more information about Lowell, please see our privacy promise.

 

What is a Chatbot?

Our Chatbot is a computer programme which is here to direct you to the best place to find the information you need.

If our Chatbot sends you a text, you can send us a reply.  It uses the information you text us to decide how best to respond to you.

Why have I received a text message?

Our Chatbot has sent you a text to see if we can help you with a letter that we recently sent to you.

What if I haven’t received a letter?

If you haven’t received the letter, please call us on 0333 556 5550

What if I’m not a Lowell customer?

If you are not a Lowell customer please call us on 0333 556 5550. If you believe we have sent you a text by mistake, please call us on 0333 556 5550.

What information do we collect about you?

We collect any information which you send to us by text.

Our customer privacy notice explains in more detail the information we collect about our customers.

Who do we share your information with?

If our Chatbot isn’t sure how to respond to you, it will share the content of your text with Google. It will not share any other information such as your telephone number with Google.  Google will carry out more analysis of your text to help our Chatbot decide how to help you.

Our customer privacy notice explains in more detail who we share information about our customers with.

Where do we get your information from?

We get your information from your texts to our Chatbot.

We may get your telephone number from:

  • the previous owner of your account
  • one of the credit reference agencies (Experian, Equifax or Transunion) or
  • third party data providers which are not credit reference agencies.

The credit reference agencies have published information notices which explain how they use and share personal information they receive about you. These are available at www.experian.co.uk/crain, www.equifax.co.uk/crain and https://www.transunion.co.uk/crain.

Our customer privacy notice explains in more detail where we get information about our customers from.

Why do we need your information?

We need your information to reply to you.  We have a legitimate interest in responding to your text message.

Our customer privacy notice explains in more detail why we need information about our customers.

Where is your information stored?

Your information is generally stored on servers and filing systems in the UK. From time to time it may be stored in or accessed from countries outside the UK. Where this may happen, we always make sure that there are appropriate safeguards in place to guarantee that your information and your rights are protected to the same high standard as under UK law. These include the model contract clauses, binding corporate rules or the EU-US Privacy Shield.

For more details, please see the 'Where is your information stored?' section of our full customer privacy notice.

How long do we keep your information for?

We only keep your information for as long as we need it. We will keep your information for no more than 7 years from the date you cease to have any active accounts with us.  However, we won’t keep all of your information for so long, and we will delete some information much sooner.

Our customer privacy notice explains more about how long we keep your information.

 

Do we carry out profiling and automated decision-making?

Our Chatbot does not carry out profiling.  It does make automated decisions about how to respond to your text.  However, these decisions do not have a legal or similarly significant effect on you.

Our customer privacy notice explains what profiling and automated decisions we make about customers when managing their accounts.

What rights do you have?

Under the data protection rules, you have a number of rights in respect of your information, which include the right to:

  • access your information
  • ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
  • delete or erase your information (sometimes called the right to be forgotten)
  • stop or restrict our processing of your information
  • object to our processing your information
  • not be subject to automated decision-making and
  • request the transfer of some of the information we hold about you (known as data portability).

 Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use your information, please see the 'What rights do you have?' section of our full customer privacy notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by:

  • email at dpo@lowellgroup.co.uk or
  • letter at Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ.

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, query or request relates to, please contact our Data Protection Officer using these contact details.

 

What if you have a complaint?

If you have any questions, concerns or complaints about the way we process your personal information, our Data Protection Officer will do their very best to help you.  You can contact our Data Protection Officer by:

  • email at dpo@lowellgroup.co.uk or
  • letter at Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ.

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, concern or complaint relates to, please contact our Data Protection Officer using these contact details.

If you are not happy with the way we have handled your complaint or are still concerned about our handing of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

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