Step Away Debt — Privacy Policy

We process personal data in accordance with the:

• • UK General Data Protection Regulation (UK GDPR)
  • Data Protection Act 2018
  • Privacy and Electronic Communications Regulations (PECR)
  • ICO guidance for businesses processing customer data

Please read this document carefully.

1. Who We Are

Aritel Limited T/A Step Away Debt

Registered Office: Suite 25, Lavenham Business Centre, Parsons Street, Oldham, OL9 7AH

ICO Registration Number: ZB582496

ICO Registration Status: Data Controller

Customer Support: info@stepawaydebt.com

Phone: 0203 793 4392

Website: stepawaydebt.com

For personal data collected via Step Away Debt, Aritel Limited is the Data Controller.

When we introduce you to an Insolvency Practitioner (“IP”) or FCA-authorised debt-advice organisation, that entity becomes an independent Data Controller responsible for its own processing activities.

2. What Step Away Debt Does

Step Away Debt operates as a debt-advice and referral service, helping individuals understand available debt-solution options and connecting them with authorised debt-solution providers. We:

• Provide initial debt advice.
• Offer general guidance, options, and recommendations based on the information you provide.
• Help you understand statutory and non-statutory debt options.
• Introduce your enquiry to Insolvency Practitioners or FCA-authorised debt solution providers.

You remain in full control of whether you proceed with any suggested option or introduced provider.

3. Personal Data We Collect

We collect only the information necessary to provide advice, manage your enquiry, and introduce you to an appropriate provider.

3.1 Information You Provide Directly

• Full name
• Address and postcode
• Email address
• Telephone number
• Information relating to your financial situation, including debt amounts, creditor types, income, expenditure, assets, or related circumstances
• Preferred contact times
• Any details voluntarily submitted via form fields

3.2 Information Automatically Collected

• IP address
• Location (approximate, based on IP)
• Browser and device type
• Interactions with our site (via cookies and analytics)
• Website usage and behaviour trends

3.3 Special Category Data

If you provide information that indicates financial hardship, health conditions affecting income, or vulnerabilities, this may be considered sensitive information. Such data is processed under:

• Article 9(2)(a) – explicit consent
• Article 6(1)(b) – steps taken at your request
• Article 6(1)(f) – legitimate interest in ensuring appropriate service and safeguarding

We do not request information on criminal convictions and do not store it unless voluntarily disclosed.

4. Where We Obtain Personal Data

We collect data through:

• Our website enquiry forms
• Telephone calls or emails
• Live chat or WhatsApp (if communicated)
• Marketing partners, comparison platforms, or affiliates who have obtained your consent to be contacted (verified for UK GDPR compliance)

All lead sources undergo due diligence, and we only work with partners who meet UK data protection standards.

5. How We Use Your Personal Data

Your information is used only for the following legitimate and transparent purposes:

5.1 To provide initial debt advice and guidance

We use your financial details to explain general solutions such as IVAs, DMPs, DROs, or other debt-management options.

5.2 To make recommendations

Based on the information provided, we may highlight solutions that are likely to be suitable; however, final assessments remain with an authorised IP or an FCA-authorised provider.

5.3 To process and pass your enquiry to authorised partners

This includes Insolvency Practitioners or debt-advice organisations who can formally assess and administer debt solutions.

5.4 To maintain accurate records and fulfil compliance obligations

Including audit trails, safeguarding, identity verification checks, and regulatory reporting.

5.5 To communicate with you

Including contacting you at your preferred time to discuss your enquiry or next steps.

5.6 For internal improvement

Including service monitoring, staff training, fraud prevention, and system performance analysis.

5.7 For marketing

We will only send marketing to those who have opted in. You may withdraw consent at any time.

6. Our Legal Basis for Processing

We rely on the following lawful bases:

• Article 6(1)(b) – processing necessary to take steps at your request (advice + referral)
• Article 6(1)(a) – your consent for marketing or sensitive information
• Article 6(1)(f) – our legitimate interests in security, fraud prevention, and business operations
• Article 9(2)(a) – explicit consent for special category data

We do not use automated decision-making that produces legal or significant effects.

7. Who We Share Your Personal Data With

We share information only when necessary and only with organisations that meet regulatory requirements:

7.1 Insolvency Practitioners (IPs)

Licensed and regulated by the Insolvency Practitioners Association (IPA) or equivalent bodies.

7.2 Debt-advice providers

FCA-authorised firms offering regulated debt counselling or debt adjusting.

7.3 Service providers

Including hosting services, CRM systems, email platforms, security providers, and compliance consultants.

7.4 Regulatory bodies (if legally required)

This may include the ICO, courts, law enforcement, or statutory bodies. We never sell your data.

8. Retention of Personal Data

We retain information as follows:

• Enquiry and advice records: 3 months
• Records passed to providers: retained according to their own legal obligations (typically 6 months)
• Marketing consent: retained until withdrawal
• Website logs/cookies: see Cookie Policy

After retention periods expire, data is securely deleted or anonymised.

9. International Transfers

Where data is stored or processed outside the UK, we ensure:

• Adequacy regulations apply, or
• Standard Contractual Clauses (SCCs), IDTA, or UK Addenda are in place
• Sufficient technical and organisational measures are implemented

We conduct due diligence on all suppliers.

10. Your Data Protection Rights

You have the right to:

• Request access to your data
• Request correction or deletion
• Object to or restrict processing
• Withdraw consent at any time
• Request data portability
• Lodge a complaint

We respond to all valid requests within 24 business hours.

11. How to Withdraw Consent

You may withdraw consent for marketing or special-category data at any time: info@stepawaydebt.com

This will not affect the lawfulness of prior processing.

12. How We Keep Your Data Secure

We use robust security measures, including:

• Encrypted data transfer
• Secure servers
• Multi-layered access controls
• Regular audit trails
• Staff training and verification
• Monitoring and penetration testing
• Secure data-sharing protocols

13. Third-Party Links

Where our website links to external sites, they remain responsible for their own privacy practices.

14. Complaints

If you have a concern about how your data has been handled, please contact us first.

If unresolved, you have the right to complain to:

Information Commissioner’s Office (ICO): www.ico.org.uk

15. How to Contact Us

Data Protection Officer / Compliance Team

Aritel Limited
34-35 Suite 2993, Unit 3a Hatton Garden, London EC1N 8DX
Customer Support:  info@aritel.co.uk | 0133 268 3518

16. Updates to This Privacy Policy

We may update this notice from time to time to reflect:

• Legal changes
• Operational changes
• Service improvements