Privacy Policy

RecoverX Commercial A trading style of Found First Digital Limited

Effective Date: 27th February 2026

1. Who We Are

RecoverX Commercial is a trading style of Found First Digital Limited, registered in England and Wales.

Company Number: 14675908 Registered Office: 4 Bark Street East, Bolton, BL1 2BQ Email: info@foundfirstrecruitment.co.uk

Found First Digital Limited is the Data Controller for the purposes of UK GDPR.

We are registered with the Information Commissioner’s Office (ICO), Registration Number: [Insert].

2. The Types of Personal Data We Process

Because we provide commercial debt recovery services, we may process the following categories of data:

A. Client Data

Business contact details
Directors’ or sole traders’ names
Contact numbers and email addresses
Financial information relating to debts

B. Debtor Data

We may process personal data relating to:

Sole traders
Company directors
Business partners
Individuals connected with a commercial debtor

This may include:

Name
Business address
Contact details
Financial details relating to outstanding debts
Correspondence history
Publicly available company information

We do not intentionally process special category data unless required by law.

3. How We Collect Personal Data

We collect data:

Directly from clients
From public records (e.g. Companies House)
From correspondence
Through our website contact forms
From credit reference or tracing services where lawful

4. Our Lawful Basis for Processing

Under UK GDPR, we rely on:

Legitimate Interests

We process personal data where necessary for our legitimate interests, including:

Recovering unpaid commercial debts
Enforcing contractual rights
Protecting business interests

We conduct internal balancing assessments to ensure our processing does not override individual rights.

Contractual Necessity

Where you instruct us to act on your behalf.

Legal Obligation

Where we are required to comply with court orders, regulatory requirements, or lawful requests.

5. Why We Process Debtor Data

We process debtor data strictly for the purpose of:

Contacting debtors regarding outstanding commercial debts
Negotiating payment
Assessing recoverability
Referring matters to solicitors where appropriate
Supporting potential legal proceedings

We do not process debtor data for marketing purposes.

6. Sharing of Personal Data

We may share data with:

Independent regulated debt recovery solicitors
Enforcement professionals
Tracing agents
IT hosting providers
Professional advisers
Courts or regulatory bodies where required

We do not sell personal data to third parties.

Where we use service providers, we ensure appropriate data protection agreements are in place.

7. International Transfers

We do not routinely transfer personal data outside the UK.

If third-party IT providers operate outside the UK, we ensure appropriate safeguards are in place.

8. Data Retention

We retain personal data only as long as necessary.

Typical retention periods:

Debt recovery case files: up to 6 years after closure
Enquiries without instruction: up to 12 months
Financial records: as required by law

We may retain data longer where required for legal defence purposes.

9. Data Security

We implement appropriate technical and organisational measures including:

Encrypted website (HTTPS)
Access controls
Secure email systems
Restricted internal access
Password-protected systems

10. Your Rights

Individuals have the right to:

Access personal data
Rectify inaccurate data
Request erasure (where applicable)
Restrict processing
Object to processing based on legitimate interests

Requests should be made to: [Insert Email]

We may request proof of identity.

11. Right to Complain

If you believe your data has been processed unlawfully, you may complain to:

Information Commissioner’s Office www.ico.org.uk

12. Changes to This Policy

We may update this policy from time to time. The latest version will always appear on our website.