• Turnaround & Restructuring Specialists

RE10 RESTRUCTURING AND ADVISORY LIMITED (Re10)

PRIVACY POLICY


1. Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we as data controllers collect from you ("you/your") through the use of our services ("Services") and website, how that information may be used or disclosed by us and the safeguards we use to protect it.

Re10 is not responsible for the privacy policies of third party sites to which links are provided. The privacy policies on such sites should be checked before providing them with any personal information. Our website does not collect or compile personally identifying information for sale to any party for consumer marketing purposes. Some pages on the website may permit you to send emails or other messages to us. Emails and messages sent to us will contain your name and email address, as well as any information you may wish to include in the message.

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

2. The data controllers:

Re10 Restructuring & Advisory Limited (registered company number 03564276; England & Wales).

Currently the insolvency practitioner associated with this practice is Mr N C Patel. He is also the director of Re10 Restructuring & Advisory Limited responsible for personal data security.

Address: 58 Hugh Street, London, England, SW1V 4ER
Tel: 020 7355 6161 Email: datacontroller@re10.co.uk

3. What we may collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Insolvency Assignments
  • Marketing / Business Clients
  • Human Resources

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.1 Insolvency Assignments

We will hold information and data about data subjects in order to properly administer formal assignments subject to insolvency legislation in the UK and abroad. As this type of assignment is subject to law e.g., the Insolvency Act 1986 (as amended) and Insolvency Rules 2016, we consider that such data is held for legal and legitimate interest purposes, specifically to allow us to properly administer such assignments.

Personal data held is general employee information to enable us to calculate redundancy entitlements and claims, creditor and shareholder information to enable creditors to claim in the respective estates, to receive information regarding the progress of an assignment and to receive dividends, and customer information to ensure that any debts due to the insolvent entity can be collected.

In addition, data is held in relation to individuals subject to an insolvency process, to include directors/partners of registered companies or limited partnerships. Such information is held in our general assignment files, retained in paper form and/or electronically.

3.2 Marketing & General Business Database

Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.

Where we hold information collected from Entities or Debtors in the course of an insolvency assignment, this information will only be used to communicate with you with regard to the lawful statutory obligations of the insolvency assignment.

We keep the records about you that we need for doing business with you, but no more. We are likely to have:

  • Your names
  • Who you work for, and what you do there.s
  • Your business contact details.s
  • Dates and times when we contacted you.s
  • Preferences in receiving marketing from us and our third parties and your communication preferences.s

We are likely to keep some of any additional written information you give us in (in emails, for example) while we consider you to be an active business contact.

We may also put your name on our marketing database, but:

  • Only if the contact details we have for you include your business email address; and
  • Only if we think you are likely to be interested in receiving marketing information from us.

You will always be able to ask us not to contact you with marketing information.

3.3 Human Resources - Applying for a job with us?

We keep the records about you that we need for considering whether to offer you employment, but no more. That information may come from:

  • Your CV and correspondence.
  • Information in the public domain (available on the internet or in directories, for example). In common with many other employers, we may search social media on the internet for information posted by or about you.

4. Data Retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

Any information about you that we use for marketing purposes will be kept with us for as long as is necessary and relevant, or until consent is withdrawn.

As an insolvency practice, together with other legislation, we are governed by the Insolvency Practitioners Regulations 2005 (as amended). This legislation requires us to preserve records as follows

  • Our case files (all appointment types) - for a period of 6 years following the Insolvency Practitioner’s release or discharge,
  • Company books and records:
    Liquidation and Administration - for a period of approximately 15 months after the closure of the case (12 months after the dissolution of the company by companies house which will follow 3 months after the closure of a liquidation or administration), Bankruptcy – for a period of 12 months after closure subject to there being no other legal requirements.
  • Voluntary Arrangements – where records are held, these will be returned to the Entity or Debtor who provided the information.

Other non insolvency assignments

In relation to this type of information, we may hold personal data to complete our contractual obligations as part of an assignment. The data will be retained for a period of 6 years after the end of the assignment.

5. Special Category Data

This includes data relating to an individual which is more sensitive, for example, health records. Such data is held securely and confidentially and held for general regulatory purposes, preserving client records or business management functions. Such data is held in accordance with the general assignment retention periods detailed above.

We do not collect any Special Categories of Personal Data about you such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

6. Data Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All information you provide to us is stored on our hosted secure servers. Where we have given you a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7. How we use your personal information

We use information about you in the following ways:

  • To contact you to discuss the advice and/or services that you may require
  • To comply with our legal obligations to which we are subject.
  • To comply with money laundering checks, ID checks, validation type services, etc.
  • To notify you about changes to our site or the services that we offer.
  • To inform you of events that may be of interest to you by letter, telephone, email and other electronic methods, provided that we have your permission, where necessary.

In addition to the above, we may use the information in the following ways:

If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please refer to the "How can you opt-out, remove or modify information you have provided to us?" section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and "members-only" content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us. You have the right to withdraw consent to marketing at any time by clicking on the unsubscribe button when receiving any correspondence from us or by simply emailing us on datacontroller@re10.co.uk, and we will either delete your data from our systems or move your data to our "unsubscribe list'.

8. Your Rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
  • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
  • We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
  • If you consider any information that we hold about you to be incorrect or incomplete, or wish us to remove any such data, you should write to us or email us at datacontroller@re10.co.uk with your request.

9. Changes to our Privacy Policy

By using or accessing our website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. We reserve the right to modify or amend this privacy statement at any time and for any reason. Nothing contained herein creates or is intended to create a contract or agreement between us and any user visiting the website or providing identifying information of any kind.

10. Complaints

If you have any concerns over how we have used or are using your data then please datacontroller@re10.co.uk in the first instance.

You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance