Personal Data Management Customer Privacy Policy

Background

1. Who are we

Our site is owned and operated by Personal Data Management Limited, a limited company registered in England under company number 11324154 and ICO number ZA378793.
We help you create a personal budget that you can use for your own records or choose to share with creditors or organisations who may assist you with payment plans or debt support.
We take data protection seriously and want you to understand how and why we use your information.

2. What personal data we collect

Depending on how you use our service, we may collect:

Personal details

  • Your name
  • Address and residency details
  • Date of Birth
  • Contact details (email, phone number)
  • IP address, browser type and version

People you share finances with

  • Their name and date of birth
  • Children’s dates of birth (used to check potential benefit entitlement)

Employment and financial information

  • Employment details
  • Income and expenses
  • Bank details (only where you choose to give these to a creditor to set up a payment
    plan — IE Hub does not store your bank login details)

Health information (special category data)

  • Only the details you choose to provide
  • Only shared with a creditor when you give explicit consent

Information received from others

We may receive:
  • Your name and email address from organisations who invite you to use IE Hub
  • Vulnerability information from the Vulnerability Registration Service (VRS), if you are
    registered with them and the creditor you choose to share with also subscribes
  • Income/expense data through Open Banking (IE Hub does not see or store your bank
    login details)

3. How we collect your information

We collect data in the following ways:
  • Directly from you when you create an account or update your budget
  • From creditors or partners who invite you to use IE Hub
  • From Open Banking, where you choose to use it
  • From the VRS to help creditors understand your circumstances
Most data is provided by you directly.

4. What we use your data for

We use your information to:

Provide our service

  • Create and manage your IE Hub account
  • Allow you to build and update your budget
  • Allow you to choose which creditors or organisations can access it
  • Enable you to share your budget via OTP, Freepost or download
  • Provide information on potential benefits or discount schemes
  • Provide advice from FCA-regulated companies (if applicable)

Communicate with you

  • Respond to your messages
  • Send service updates
  • Contact you (occasionally) to request feedback or a user survey

Optional services (your choice)

  • Send marketing emails (only if you opt in)
  • Share your budget with creditors (only when you choose to share it)

Service improvement and analytics

  • Improve our website and tools
  • Analyse anonymised usage patterns to understand affordability and debt trends
    (Only anonymised, non-identifiable data is used.)

5. Our lawful bases for processing your data

Under the UK GDPR, we rely on the following lawful bases:

Performance of a contract (Article 6(1)(b))

We use your personal, financial and account information so we can provide the budgeting tools and features you signed up to use.
Without this information, we cannot deliver the service.

Consent (Article 6(1)(a))

We rely on your consent when:
  • You choose to share your budget or personal information with a creditor or organisation
  • You provide health information and ask us to share it
  • You opt in to marketing messages
You can withdraw your consent at any time by emailing customer.support@iehub.org.

Legal obligation (Article 6(1)(c))

We may process or retain information where the law requires us to do so, for example for financial reporting, audit, or responding to a lawful request from a regulator.

Legitimate interests (Article 6(1)(f))

We use anonymised data to understand how IE Hub is used, improve our service, and support research on affordability and debt.
This data cannot identify you.

6. Special category data (health information)

If you choose to include information about your health in your budget, we will only share it with a creditor when you give explicit consent, as required under Article 9(2)(a) UK GDPR. We do not ask for medical evidence.
If you do not want a creditor to see this information, please do not include it in comment boxes.

7. Who we share your data with

We share your information only when:
  • You choose to share your budget with a creditor
  • The creditor is part of the Freepost service (where applicable)
  • You provide a One-Time Password (OTP) to a creditor while on a call with them
  • An organisation invites you to use IE Hub and you submit an updated budget back
    to them
  • You use Inbest, who receives anonymised data to calculate benefit and tariff
    entitlements
  • You use Open Banking services, which are handled via third-party providers
If you choose to share your data with an organisation that operates outside the UK (e.g., through a group company or parent company), their overseas staff may access your information.
You remain in control — you can remove a creditor’s access at any time from within your
account.

8. International transfers

If the creditor or organisation you choose to share with has offices outside the UK, your data may be accessed from that location.
Their own privacy policies will apply once data is shared.
IE Hub itself stores and processes your data only within the UK.

9. How long we keep your information

We keep your data for:
  • Six years from the date you last submitted a budget, or
  • Until you ask us to delete it, whichever comes first.
If you request deletion, we will remove your IE Hub data within 72 hours.
If you have shared your budget with a creditor, you must request deletion from them
separately.

10. How we protect your information

We use a range of security measures to protect your data, including:
  • Encryption
  • Intrusion detection and prevention
  • Access controls
  • Secure UK-based hosting
We regularly test and review our security standards.

11. Your data protection rights

You have the following rights under UK GDPR:
  • Access – to request copies of your personal data
  • Rectification – to correct inaccurate or incomplete information
  • Erasure – to ask us to delete your data in certain circumstances
  • Restriction – to limit how your data is used
  • Object – to certain types of processing
  • Data portability – to receive your data in a transferable format
You can exercise these rights by contacting dpo@iehub.co.uk.
We respond within one month.

12. How to contact us

Personal Data Management Ltd (IE Hub)
Tramshed Tech, Pendyris Street, Cardiff, CF11 6BH
Email: customer.support@iehub.co.uk
For rights requests: dpo@iehub.co.uk

How to complain

If you’re unhappy with how we use your data, please contact us at complaints@iehub.org.
You can also complain to the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://ico.org.uk
IE Hub
IE Hub is a trading name of Personal Data Management Ltd. Company number: 11324154. Main trading address: Tramshed Tech, Pendyris Street, Cardiff, CF11 6BH. ISO 27001 and ISO 9001 Certified. ICO registration number: ZA378793.
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