Kiss My Debt

This Privacy Notice

This is privacy notice of https://kissmydebt.com

We respect your privacy and are determined to protect your personal data.

The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

Who Are We?

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up as a subscriber to our service.

This website is not intended for children and we do not knowingly collect data relating to children. You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices in connection to this service and is not intended to override or to be superseded by them.
Data controller(s)

The AI Desk Ltd is the controller and responsible for your personal data. Our company shall be referred to as, Kiss My Debt, or https://kissmydebt.com, “we”, “us” or “our” in this privacy notice). Our contact details are The AI Desk Ltd, who are registered in England and Wales (Company number 07812164), Registered Office; Unit 19, 1-13 Adler Street, London, E11EG. Licensed by the Information Commissioners Office, (registration number ZA228693).

The AI Desk Ltd is the controller and responsible for this website.

Kissmydebt.com are aware how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulations (GDPR).

Contained within this statement and set out below are details of the type of information that we at kissmydebt.com may hold about “you” our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to Kissmydebt.com and personal information which may be collected and obtained by us. Kissmydebt.com may choose to amend the content of this privacy policy on occasion. If this occurs, then we will update the policy and the revised policy will be posted on this website.

How We Process Your Personal Data In Relation To Your Data Submission

We, and our panel of Debt Service Finders (DSF’s) and Debt Service Providers (DSP’s), will keep you informed with the progress of your application. Unless you state otherwise you may be contacted via telephone, email, post, whatsapp, SMS and automated message. (see further section on ‘How we keep you informed’)

Lawful basis for collecting your personal data

We rely upon a different lawful basis to process your personal data according to the reason for which you have provided your data to us.

Our use of your personal data will always have a lawful basis.

Consent:

When you submit your online debt help request (Contact Request) with kissmydebt.com, we process your personal data on the basis that you have provided your consent to be contacted by kissmydebt.com, our panel of Debt Service Finders (DSF) /Debt Service Providers (DSP) in relation to your Contact Request.

We will also rely on your consent to share your personal data with our Debt Service Finders who may offer similar debt help services. These third parties will contact you by the communication channel or channels which you have agreed to, offering products and services that maybe of interest.

Performance Of Contract:

Your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by providing you with a introduction to a Debt Service Finders or Debt Service Providers. Kissmydebt.com, our panel of Debt Service Finders / Debt Service Providers will contact you regarding your contact request.

This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such contract.

Legitimate Interest:

We have a legitimate interest in processing your data (i.e. to share your application with our panel of Debt Service Finders / Debt Service Providers and Credit Reference Agencies) to obtain the service you have applied for.

It also includes processing your data for ID protection and tracing purposes such as Credit Reference and Fraud Prevention. This is in relation to appropriate agencies which are listed within section 9.

You can object to us processing your data in this way by contacting us at info@theaidesk.com.

Our Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us depending on your profile and where we think you will be interested in certain type of products.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside The AI Desk Ltd for marketing purposes.

Opting out

You can withdraw your consent to receive marketing offers we, or any associated third party, send to you any time.

Email:

To unsubscribe by email, please send an email to info@theaidesk.com

SMS:

To unsubscribe by SMS, click the “mobile number” at the bottom of the SMS and reply with “Stop” or “Unsubscribe” in your SMS response.

Our opt-out system will recognise your opt-out request, and your details will be stored in a suppression list so that you do not receive future contact.

If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

3. How You May Contact Us

You may contact us to request information we hold about you by emailing or writing to:

E-mail: info@theaidesk.com

Post:

The AI Desk Ltd
Unit 19, 1-13 Adler Street, London, E1 1EG

How We Keep You Informed

We may want to make contact with you with your consent at some point in order to keep you informed regarding offers on products or services which we think you may find of interest, this contact will be made via SMS, email or telephone. Third parties may also wish to contact you from the information we have shared with them, any information that is shared to third parties is trusted to be used for the purpose it is specified for in ‘Who Do We Share Your Personal Information With?’. Third parties may also use the same means of contact stated above.

As part of the application process, if our Debt Solutions Providers are unable to help you with a debt solution you are looking for, we may pass your details onto another company listed within our privacy policy, who may be able to help you. Please note, third parties will have their own privacy policy, and it is recommended you refer to their policy to understand how they may process your data.

Obtaining Your Personal Data/Information

We use different methods to collect data from and about you including through:

Directly. You may give us your personal contact information and financially related information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Subscribe to our service or publications;
- Request marketing to be sent to you.
The personal information/data that we would normally collect from you is as follows:
- Name
- Country
- Value of debt
- Date of birth
- Number of Creditors
- Employment Status
- How much you could roughly afford to pay your creditors
- Mobile number
- Email address
- IP Address

If you apply with us and have a question about our services, or alternatively choose to send an email to info@theaidesk.com we may also collect the above personal information/data in this instance in order for us to respond to your enquiry.

6. Customer Communication

Upon becoming a subscriber to our service and unless you state otherwise we will contact you with consent via telephone, SMS, whatsapp and email to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regards to accuracy and we will endeavour to check your information with you on occasion.

Ensuring your personal details & or preferences are kept up to date.

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact us as soon as possible (details set out below within ‘Contact’ page).

What Personal Information Do We Collect?

We collect personal information about you when you give this to us when submitting your contact request. This would be, for example, a request to receive information about debt relief or professional guidance surrounding financial help from a service provider. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, personal details, together with details of your financial information, for example, bank account or employer details.

In order to provide you with a introduction to a Debt Service Provider or Debt Service Finder we will need to collect personal information. By proceeding with submitting to us your personal detail so that we may introduce you to either a Debt Service Provider or Debt Service Finder, you give your explicit consent to such information being processed by us and our third-party providers such as Debt Service Providers and Debt Service Finders for the purposes stated in this Privacy Policy.

We may monitor or record your Calls, Emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

How Do We Use Your Personal Information?

We may use your personal information:

to enable you to access and use the Services;
to personalise and improve aspects of our Services;
for research, such as analysing market trends and customer demographics;
to communicate with you, including some or all of the following:
1. sending you information about products and services which we think may be of interest to you – this may include new product launches such as debt solutions, services that offer money saving offers, cheaper tariff services, credit reporting services, newsletters and opportunities to participate in market research;
2. b. introducing you to Debt Service Provider or Debt Service Finder – in order to provide this service to you, we may also send that information to our partners such as our panel of Debt Service Providers and, or Debt Service Finders so that they can help find a solution that you may see fit to proceed with. When they do this, some of our partners may carry out credit checks on you to help you locate and realise any debts that may be present on your credit profile (see section 9 Who do we share your information with? below for further information on the type of checks that may be undertaken);
3. c. sending you a confirmation email of your contact request – when you submit an application with us, you may automatically be sent confirmation of your application by email or SMS so that you have a record of it;
to process an application between you and a third party such as a Debt Solutions Provider or Debt Solutions Finder;
to match our data with data from other sources – we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible. As well as ensuring that any marketing material that we send you is appropriate to your needs, this process also ensures that our Services continue to be as personalised and focused as possible;
to circulate our customer survey review which are available to customers once an application has been completed;
to enable you to share our content with others, e.g. by using any ‘Email a friend’ or ‘Share this’ functionality on our Sites.
to potentially pass on your data to third parties for marketing purposes as per section 9 where you have consented to do so.

Keeping you informed about the Services: You agree that we and, with your consent, other Debt Service Finders will be entitled to contact you (depending on your contact preferences) via email, post, telephone, SMS, or by other electronic means such as via social and digital media, in relation to products, services and other offers that may interest you.

Whenever you provide us with personal information, where necessary we will seek your consent and/or we will give you an opportunity to tell us you do not consent to the use and sharing of your information for marketing purposes. Unless you tell us otherwise, you are consenting to such use.

Who Do We Share Your Personal Information With?

When you complete an application, you consent to us disclosing your personal information to the following parties:

‘kissmydebt.com” Kiss My Debt:: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.
Debt Service Providers and Debt Service Finders as detailed below. You can view details to how they will process your personal data within their privacy polices below.
Debt Service Finders but only where you have opted in to allow us to do so and they are detailed below. They will contact you with regards to Mobile Phone Tariff Saving Offers, Credit Score Reporting and Improvement Products, Energy Switching For Cheaper Tariffs, Discount Coupons, personal claims. You can opt out at any time from receiving these communications.
Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:
if required or permitted to do so by law;
if required to do so by any court, the Information Commissioners Office, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
if necessary in connection with legal proceedings or potential legal proceedings; and/or
in connection with the sale or potential sale of all or part of our business.
The AI Desk Ltd Limited collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation’s own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.

FRAUD PREVENTION AGENCIES (FPA’S)

If we reasonably believe false or inaccurate information has been provided, including in relation to a person’s identity, and fraud is suspected, details, including personal data may be passed to fraud prevention agencies to prevent fraud and money laundering.

Your details may be passed to statutory bodies, regulators, legal bodies, credit reference agencies, fraud prevention entities and identity and address verification agencies who may record and use your details.

Who Might Our Panel Of Debt Service Providers and Debt Service Finders Share Your Personal Information with?

Some of our providers will use your personal information to assess your circumstances (including information about any third party who is named on the application) and verify the information that you have provided before providing a quote to you. Some providers may carry out checks with fraud prevention and credit reference agencies. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way. Some providers may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them.

This information exchange allows providers to verify the information that is provided during the solutions and quote process (including information about any third party who is named on the policy), and also helps to detect fraudulent applications. These checks are not unique to users of our Services – they may also be carried out if you obtain solutions and quotes from other sources.

If you decide to enter into a debt solution offered to you by the Provider, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third party provider, will be held by the provider for the purposes set out in that provider’s privacy policy or terms and conditions. Therefore, you are strongly advised to read your chosen provider’s privacy policy or terms and conditions and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the prescribed debt solution. We have no responsibility for the uses to which a provider puts your personal information.

What Cookies Do We Use?

Cookies and Web Beacons

This section sets out our use of Cookies when you use our sites. Please read it carefully as it explains how we and third parties may make use of your data collected by such Cookies. If you wish to understand how we make use of your data, more generally please refer to section 8.

To find out more about accepting or refusing cookies please visit www.allaboutcookies.org.

Our company uses non-invasive:

– session cookies

– statistic cookies

A cookie is a very small text file placed on your computer or device. Cookies help us to:

understand browsing habits on the Sites;

understand the number of visitors to the Sites and the pages visited.

Most cookies are deleted as soon as you close your browser or mobile application – these are known as session cookies. Others, known as persistent cookies, are stored on your computer or device either until you delete them or they expire.

The cookies we use, are ones that do not identify any personal information about you, and they are essential to the operations of this site and our company.

FACEBOOK (VISITOR ACTION PIXEL)

We use the “visitor action pixels” from Facebook Inc (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.

This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

On our websites functions of the service Instagram are embedded. These functions are offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link contents of our websites to your Instagram profile by clicking the Instagram button.

For further information, please review the Privacy Policy of Instagram: http://instagram.com/about/legal/privacy/

TWITTER CONVERSION TRACKING

On our website, we use the Conversion Tracking Service of Twitter Inc. (1355 Market Street #900, San Francisco, California 94103, “Twitter”). Twitter stores a cookie on the user’s computer to enable an analysis of the use of our online products and services. Twitter Conversion Tracking tracks the actions of users after they have viewed ads or interacted with ads on Twitter. Twitter’s Conversion Tracking allows you to assign conversions such as link clicks, retweets or “like” data.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to tracking, you can do so using the Digital Advertising Alliance tool at optout.aboutads.info.

Twitter is certified under the Privacy Shield Agreement and thus guarantees its compliance with European data protection legislation: (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active)

Cookie settings

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that by disallowing cookies some functionality on the site may be restricted.

Do We Take To Keep Your Personal Information Safe?

Keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

Where will your personal data be held?

Your personal data may be held within the European Economic Area (EEA) or outside the EEA. If any personal data is transferred or stored outside of the EEA, we check whether the EU Commission has determined that it will afforded the same level of protection as it would within the EEA (this is called an adequacy decision). If it will not, we will ensure any such transfer is subject to appropriate safeguards (for example by putting appropriate contractual provisions in place with relevant third parties to provide us with reassurance about the security of your personal data) or is otherwise permitted (for example with your express consent to transfer) in accordance with the provisions of the GDPR.

Rights of Access To Your Personal Information

You have certain rights under the General Data Protection Regulations . For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.

Right to be informed when we collect your data we have to tell you what we are going to do with it primarily though this Privacy Policy and within the opt in /consent statement.
Right to Object– because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to a service available amongst our panel of Debt Service Providers and Debt Service Finders. You can object to this processing at any time by sending us an email at info@kissmydebt.com, or by writing to the Customer Services Team at The AI Desk Ltd, Unit 19, 1-13 Adler Street, London, E1 1EG. We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
Right of Access – you can ask us at any time to confirm whether we hold your personal information, and if so, you can access it by emailing us at: info@kissmydebt.com
Right to rectification – if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
Right to erasure – if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
Right to restrict our use of your information – you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
Right to data portability – this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies and utility companies.
Right to complain to the Information Commissioner’s Office (ICO) – we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Please refer to our Complaints section How To Make a Complaint below for further information.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at info@kissmydebt.com

How Long Will We Retain Your Personal Information For?

The amount of time we retain your information for will depend on the reason it was provided:

If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.
Your information/data will not be used for marketing purposes once 24 months has passed following your application.

If you require further information on our data retention policies please email: info@theaidesk.com

Your Right To Opt Out of Future Contact From Us Or Any Listed Third Party

You can opt out of future contact from kissmydebt.com at any time. All of our marketing messages provide an opt out link as stated in Section 2 Consent – please allow up to 48 hours for us to process your opt out request. Alternatively you can email info@kissmydebt.com where your details will be removed from any future marketing campaigns.

If you are receiving contact from third parties you will need to contact them directly and request them to remove your details.

Your Right to be Forgotten / Erasure Of Your Personal Information

Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
When the individual withdraws consent.
When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
The personal data has to be erased in order to comply with a legal obligation.
The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right “to be forgotten” does not apply i.e. where we need to comply with a legal obligation.

If you wish to request your “right to be forgotten” please email: info@kissmydebt.com

Our marketing partners will also be informed of your request where you have stipulated to do so.

How to make a complaint

https://www.kissmydebt.com (The AI Desk Ltd) always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we’re keen to resolve it as quickly as possible. You can contact us is any of the following ways:

By Post:
Complaints Department, The AI Desk Ltd, Unit 19, 1-13 Adler Street, London, E1 1EG

By Email: info@theaidesk.com

We will acknowledge receipt of the complaint within 5 working days and we hope to provide a final response within 4 weeks. We will write to you again within 4 weeks if we are unable to provide a final response within that time period. In any event we will respond to your complaint in full within 8 weeks.

If you are not satisfied with our response, or if a complaint is not resolved after eight weeks, you may refer the complaint to –

Information Commissioner’s OfficeWycliffe House, Water Lane, Wilmslow, CheshireSK9 5AF

Tel:0303 123 1113(local rate) or01625 545 745

Kiss My Debt

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This Privacy Notice