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Privacy Policy

Ebenegate is committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use, store and share your personal information, the legal reasons we rely on when processing it, and your rights.

 

1. Information we collect

Depending on your relationship with us, we may collect and process:

  • your name, address, date of birth and contact details;
  • identity verification information;
  • details of your income, expenditure and financial circumstances;
  • information about your debts, creditors and outstanding balances;
  • bank account and payment information;
  • employment and benefit information;
  • details of your property, vehicles or other assets;
  • information relating to your debt or insolvency arrangement;
  • correspondence and communications with you and your creditors;
  • call recordings;
  • information provided through our website or customer portal;
  • complaint and enquiry information; and
  • technical information such as your IP address, device, browser and cookie information.

We may also process sensitive information, such as health information, where this is relevant to your circumstances, vulnerability or the support you require.

Where we process special category data, we will only do so where permitted by data protection law.

3. Where we get your information

We may collect information directly from you when you contact us, use our website or portal, provide documents or information, or make payments.

We may also receive information from:

  • organisations that refer you to us or instruct us to administer your arrangement;
  • insolvency practitioners;
  • debt advice or debt solution providers;
  • your creditors and their representatives;
  • banks and payment providers;
  • credit reference agencies;
  • regulators, government bodies and public authorities;
  • professional advisers and service providers; and
  • publicly available sources where appropriate.

4. How we use your information

We may use your information to:

  • administer your debt or insolvency arrangement;
  • communicate with you and your creditors;
  • process and allocate payments;
  • review your financial circumstances;
  • conduct periodic or annual reviews;
  • manage changes to your arrangement;
  • deal with queries, claims and complaints;
  • provide and operate our customer portal;
  • verify your identity;
  • prevent fraud and financial crime;
  • identify and support vulnerable customers;
  • monitor calls for quality, training and compliance;
  • maintain accurate records;
  • meet legal and regulatory obligations;
  • protect our systems and services; and
  • establish, exercise or defend legal claims.

5. Our lawful bases

We will only process your information where we have a lawful basis to do so.

Depending on the circumstances, this may include:

  • Contract – where processing is necessary to provide services to you.
  • Legal obligation – where we are required to process information by law.
  • Legitimate interests – where processing is necessary for our legitimate business interests and does not override your rights.
  • Consent – where we ask for your permission to use information for a specific purpose.
  • Vital interests or public interest – where these lawful bases apply in limited circumstances.

Where we rely on consent, you can withdraw it at any time.

6. Who we share your information with

Where necessary, we may share personal information with:

  • organisations involved in your debt or insolvency arrangement;
  • insolvency practitioners;
  • your creditors and their representatives;
  • banks and payment providers;
  • professional advisers;
  • IT, hosting and software providers;
  • identity verification and fraud prevention providers;
  • regulators, government bodies and public authorities;
  • courts and law enforcement agencies; and
  • other organisations where required by law or authorised by you.

Where another organisation processes information on our behalf, we require appropriate protections to be in place.

 

7. How long we keep your information

We only keep personal information for as long as necessary for the purposes for which it was collected and to meet legal and regulatory requirements.

Where we administer an arrangement, relevant records will generally be retained for up to six years after our involvement ends, unless a longer period is required.

Once information is no longer required, it will be securely deleted, destroyed or anonymised.

8. Keeping your information secure

We use appropriate technical and organisational measures to protect personal information against loss, misuse, unauthorised access, alteration or disclosure.

Access is restricted to individuals who have an appropriate business need.

10. Cookies and website information

When you use our website or online services, we may collect technical information about your device and how you use our services.

We use cookies and similar technologies to operate and secure our website, remember preferences, understand how the site is used and improve our services.

Where required, we will obtain your consent before using non-essential cookies.

11. Marketing

Where we send direct marketing communications, we will only do so where we have an appropriate lawful basis and in accordance with applicable electronic marketing laws.

You can opt out of marketing at any time.

This will not prevent us from sending service communications that are necessary to administer your arrangement.

12. Automated decision-making

We do not normally make decisions about you solely using automated processing where those decisions would have a legal or similarly significant effect.

If this changes, we will provide appropriate information about the processing and your rights.

13. Your rights

Depending on the circumstances, you may have the right to:

  • request access to your personal information;
  • ask us to correct inaccurate or incomplete information;
  • request deletion of your information;
  • ask us to restrict how your information is used;
  • object to certain types of processing;
  • receive certain information in a portable format;
  • withdraw consent where we rely on consent; and
  • challenge certain decisions made solely by automated means.

You also have an absolute right to object to your personal information being used for direct marketing.

Not all rights apply in every circumstance, particularly where we are required by law to retain or process information.

14. Contacting us about your information

If you have a question about how we use your information or would like to exercise your rights, contact:

Ebenegate
PO Box 27160
Glasgow
G2 9LZ


Email: client@ebenegate.co.uk

We may need to verify your identity before responding to a request.

15. Complaints

If you are unhappy with how we have handled your personal information, please contact us first so we can investigate.

You also have the right to complain to the Information Commissioner’s Office (ICO).

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Further information is available at ico.org.uk.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our services, legal requirements or how we process personal information.

The latest version will always be published on our website.

Last updated: August 2026