Privacy Policy | Neotiqa Recovery

Version 1.0 · Effective 19 June 2026

Neotiqa Limited · Company No. 16718145

PRIVACY OVERVIEW

Neotiqa Limited generally acts as an independent controller when reviewing and pursuing commercial recovery Cases.

This Policy covers Client representatives, Debtor representatives, Website users, suppliers and other individuals whose information appears in Case records.

The Policy should be linked from the Website footer, Case Submission form and the first substantive communication sent to a Debtor or Debtor representative.

1. Who we are

1.1 Neotiqa Limited, trading as Neotiqa Recovery, provides business-to-business commercial invoice recovery services.

1.2 Neotiqa Limited is registered in England and Wales under company number 16718145. Its registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

1.3 For the personal data described in this Privacy Policy, Neotiqa Limited is generally the data controller.

1.4 Contact details:

(a) email: hello@neotiqa.com;
(b) telephone: +44 20 8191 3412; and
(c) post: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

2. Scope of this Policy

2.1 This Privacy Policy explains how Neotiqa collects, uses, discloses and retains personal data relating to:

(a) current and prospective Clients;
(b) directors, employees and representatives of Clients;
(c) Debtor companies and individuals connected with them;
(d) directors, officers, employees, representatives, advisers and agents of Debtors;
(e) people who contact Neotiqa about an invoice or payment arrangement;
(f) suppliers, contractors and professional advisers;
(g) Website visitors; and
(h) other people whose information is included in recovery documents or correspondence.

2.2 The Services are directed at businesses. Business records and communications may nevertheless contain personal data identifying directors, employees, representatives and other individuals.

3. Our data protection role

3.1 Unless expressly agreed otherwise, Neotiqa and the Client each act as separate independent controllers.

3.2 The Client is responsible for its original collection and use of personal data and for lawfully disclosing information to Neotiqa.

3.3 Neotiqa is responsible for the processing decisions it makes when reviewing, administering and pursuing a Case, complying with legal obligations, protecting its rights and operating its business.

3.4 This Policy does not govern the Client's own processing. Individuals should also review the Client's privacy information where relevant.

4. Personal data we collect

4.1 Client and prospective-Client information

4.1.1 Neotiqa may collect:

(a) name;
(b) business email address;
(c) telephone number;
(d) job title;
(e) employer or company name;
(f) Companies House and corporate information;
(g) evidence of authority to instruct Neotiqa;
(h) correspondence and call notes;
(i) Case Submission information;
(j) invoice, account and payment information;
(k) bank details used for direct payment;
(l) complaints and dispute records; and
(m) information required for identity, fraud, sanctions or compliance checks.

4.2 Debtor and recovery information

4.2.1 Neotiqa may collect:

(a) Debtor company name, registration number and registered office;
(b) trading and contact addresses;
(c) names and roles of directors, officers, employees and representatives;
(d) business email addresses and telephone numbers;
(e) invoices, statements and account balances;
(f) contracts, purchase orders and delivery information;
(g) payment history;
(h) correspondence concerning the Debt;
(i) details of disputes, complaints, defences and counterclaims;
(j) settlement proposals and payment plans;
(k) information concerning insolvency, dissolution or restructuring;
(l) public Companies House and registry information;
(m) verification or tracing information obtained lawfully from third parties; and
(n) notes and records generated while managing the Case.

4.3 Settlement and payment enquiries

4.3.1 Where someone contacts Neotiqa to settle, query or discuss an invoice, Neotiqa may collect:

(a) name and company;
(b) contact details;
(c) Neotiqa and invoice references;
(d) proposed payment amount;
(e) payment-plan information;
(f) information concerning a dispute or query; and
(g) related correspondence.

4.4 Website and technical information

4.4.1 Neotiqa and its infrastructure or security providers may collect:

(a) IP address;
(b) browser and device details;
(c) approximate location derived from an IP address;
(d) pages viewed and actions taken;
(e) form-submission timestamps;
(f) server, security and error logs;
(g) cookie or local-storage identifiers;
(h) referral information; and
(i) Website interaction information.

4.5 Call recordings

4.5.1 Where Neotiqa records a telephone call, it will normally tell participants at the beginning of the call or through another appropriate notice.

4.5.2 Recordings may be used for record-keeping, quality assurance, evidence, training, complaint handling and the establishment, exercise or defence of legal claims.

5. Sources of personal data

5.1 Neotiqa may obtain personal data from:

(a) the Client;
(b) the individual concerned;
(c) the Debtor and its representatives;
(d) invoices, contracts, statements and correspondence;
(e) Companies House and other public registers;
(f) company websites and publicly available professional sources;
(g) lawful business-information, verification or tracing providers;
(h) solicitors, accountants, insolvency practitioners and other advisers;
(i) courts, tribunals and public authorities;
(j) banks or payment providers where relevant to a payment;
(k) the Website and Neotiqa's technology systems; and
(l) service providers and subcontractors.

5.2 Where Neotiqa obtains personal data from someone other than the individual, it will provide or make available appropriate privacy information in accordance with applicable law, normally through its first substantive communication or within the legally required period.

6. How we use personal data

6.1 Neotiqa may use personal data to:

(a) review and assess a proposed Case;
(b) verify the Client, Debtor and Debt;
(c) enter into and administer an Agreement;
(d) contact the Debtor and relevant representatives;
(e) seek payment of an unpaid commercial invoice;
(f) discuss payment dates, payment plans and settlement proposals;
(g) calculate contractual or statutory additions;
(h) maintain Case files and communications;
(i) report material progress to the Client;
(j) identify payments and reconcile accounts;
(k) calculate, invoice and verify Commission;
(l) deal with disputes, counterclaims and complaints;
(m) establish, exercise or defend legal claims;
(n) prevent fraud, misuse, unlawful submissions and security incidents;
(o) perform sanctions, identity and compliance checks;
(p) maintain the Website and information security;
(q) comply with legal, regulatory, tax, insurance and accounting obligations;
(r) obtain professional advice;
(s) manage suppliers and contractors;
(t) improve services and internal processes using aggregated or anonymised information; and
(u) communicate with business contacts about relevant Neotiqa services where lawful.

7. Lawful bases

7.1 Legitimate interests

7.1.1 Neotiqa may process personal data where necessary for its legitimate interests or those of the Client or another party, including:

(a) recovering commercial debts;
(b) administering business contracts;
(c) contacting business representatives about unpaid invoices;
(d) verifying the identity and status of companies and their representatives;
(e) preventing fraud and misuse;
(f) protecting systems and information;
(g) maintaining accurate records;
(h) pursuing or defending legal claims;
(i) collecting Commission and other sums due;
(j) improving and managing Neotiqa's business; and
(k) communicating with existing or prospective business Clients.

7.1.2 Neotiqa considers whether these interests are overridden by the rights and freedoms of the individuals concerned.

7.2 Contract

7.2.1 Neotiqa may process personal data where necessary to take steps requested before entering into a contract with an individual or to perform a contract to which that individual is personally a party.

7.2.2 Where the Client is a company, Neotiqa's principal basis for processing information about its employees and representatives will normally be legitimate interests rather than contractual necessity.

7.3 Legal obligations

7.3.1 Neotiqa may process personal data where required to comply with legal, tax, accounting, court, regulatory, sanctions or law-enforcement obligations.

7.4 Legal claims

7.4.1 Neotiqa may process information where necessary to establish, exercise or defend legal claims.

7.5 Consent

7.5.1 Neotiqa relies on consent only where consent is appropriate and legally required, such as for certain optional cookies or communications.

7.5.2 Consent may be withdrawn at any time without affecting processing already carried out lawfully.

8. Special-category and criminal-offence data

8.1 Neotiqa does not normally need special-category or criminal-offence information to recover a commercial invoice.

8.2 Clients and Website users must not provide such information unless it is necessary, relevant and lawfully disclosable.

8.3 Where such information is received, Neotiqa will process it only where an additional legal condition applies, including where necessary for legal claims or another lawful substantial-public-interest condition.

8.4 Neotiqa may delete, redact or restrict unnecessary sensitive information.

9. Who we share personal data with

9.1 Neotiqa may share personal data where reasonably necessary with:

(a) the Client;
(b) the Debtor and its directors, employees and representatives;
(c) Neotiqa's employees and contractors;
(d) hosting, email, telephone, CRM, document-storage and IT providers;
(e) business-information, verification and tracing providers;
(f) payment providers and banks;
(g) solicitors, accountants, auditors, insurers and other professional advisers;
(h) courts, tribunals, process servers, insolvency practitioners and enforcement professionals;
(i) regulators, tax authorities, government bodies and law-enforcement agencies;
(j) prospective purchasers, investors, lenders or successors to Neotiqa's business, subject to appropriate confidentiality protections; and
(k) other parties where the person concerned has authorised disclosure or disclosure is required or permitted by law.

9.2 Neotiqa does not sell personal data.

10. Service providers

10.1 Neotiqa uses third parties to support the Website, communications, Case administration, security and business operations.

10.2 Where a provider acts as Neotiqa's processor, Neotiqa requires it to process personal data only for authorised purposes and to apply appropriate data protection and security obligations.

10.3 Some providers may act as independent controllers for their own legal or operational purposes. Their own privacy notices apply to that processing.

11. International transfers

11.1 Some providers may process personal data outside the United Kingdom.

11.2 Where personal data is transferred to a country not covered by a UK adequacy decision, Neotiqa uses an appropriate safeguard where required, such as the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, another approved transfer mechanism or a permitted statutory exception.

11.3 Individuals may contact Neotiqa for further information about relevant safeguards.

12. Data retention

12.1 Neotiqa retains personal data only for as long as reasonably necessary for the relevant purpose.

12.2 Normal retention periods are:

(a) submitted and accepted Case records, communications and recovery documents: for the duration of the Case and generally six years after closure;
(b) contracts, Commission records, invoices and accounting records: generally six years after the relevant financial period or transaction;
(c) rejected or unaccepted Case Submissions: generally up to 24 months after the last meaningful contact;
(d) settlement enquiries that do not progress: generally up to 24 months after the last meaningful contact;
(e) call recordings: generally up to 12 months unless required longer for a dispute, complaint or legal claim;
(f) Website security and server logs: generally up to 12 months;
(g) marketing records: until an individual opts out or the information is no longer useful; and
(h) suppression records: for as long as reasonably necessary to ensure an opt-out or objection is respected.

12.3 Neotiqa may retain information longer where a legal claim is ongoing or reasonably anticipated, Commission remains payable or requires verification, law requires a longer period, an insurer, regulator or court requires preservation, fraud, sanctions or security concerns exist, or the information is needed to establish, exercise or defend legal rights.

12.4 Neotiqa may retain anonymised information indefinitely where it can no longer identify an individual.

13. Security

13.1 Neotiqa uses reasonable technical and organisational measures designed to protect personal data, including access control, authentication, encryption in transit where supported, secure hosting and storage, backups, security monitoring, access restrictions, incident management and supplier management.

13.2 No internet transmission, email service, Website, storage system or security measure is completely secure. Neotiqa cannot guarantee absolute security.

14. Accuracy

14.1 Neotiqa takes reasonable steps to maintain accurate personal data.

14.2 Clients and Debtors should tell Neotiqa promptly where information is inaccurate or has changed.

14.3 Neotiqa may retain a record of a correction, dispute or previous information where required for evidential, accounting or legal purposes.

15. Individual rights

15.1 Depending on the circumstances, individuals may have the right to:

(a) request access to their personal data;
(b) request correction of inaccurate or incomplete data;
(c) request deletion;
(d) request restriction of processing;
(e) object to processing based on legitimate interests;
(f) request portability of information they provided where the legal conditions apply;
(g) withdraw consent where consent is the lawful basis; and
(h) complain about Neotiqa's processing.

15.2 These rights are not absolute. Neotiqa may refuse or restrict a request where permitted by law, including where information is required to recover or verify a Debt, protect another person's rights, comply with a legal obligation, establish, exercise or defend legal claims, prevent fraud, or preserve confidential or legally privileged information.

15.3 Neotiqa may request information to verify identity and authority before responding.

16. Objections to legitimate-interest processing

16.1 An individual may object to processing based on legitimate interests.

16.2 Neotiqa will consider the objection and the circumstances of the processing.

16.3 Neotiqa may continue processing where it has compelling legitimate grounds that override the individual's interests, rights and freedoms, or where processing is required for the establishment, exercise or defence of legal claims.

16.4 An objection does not itself extinguish, waive or determine the validity of a commercial Debt.

17. Automated decision-making

17.1 Neotiqa may use software to organise information, calculate amounts, identify Cases requiring attention and support administrative decisions.

17.2 Neotiqa does not currently make solely automated decisions about individuals that produce legal or similarly significant effects without appropriate human involvement.

17.3 Neotiqa will update this Policy and provide any additional required information if this changes.

18. Cookies and local storage

18.1 The Website may use essential cookies or browser storage to operate forms, maintain security, remember display preferences, prevent misuse and maintain Website functionality.

18.2 Where non-essential analytics, advertising or similar technologies are used, Neotiqa will request consent where required and provide appropriate controls.

18.3 Users can manage cookies through browser settings. Blocking essential storage may prevent parts of the Website from working correctly.

19. Business marketing

19.1 Neotiqa may contact business Clients and prospective Clients about relevant Neotiqa services where permitted by law.

19.2 Individuals can opt out at any time by using an unsubscribe option where provided or emailing hello@neotiqa.com.

19.3 Opting out of marketing will not prevent service, recovery, payment, legal or administrative communications.

20. Third-party websites

20.1 The Website may contain links to external websites or services.

20.2 Neotiqa does not control those organisations and is not responsible for their privacy practices. Their own privacy notices apply.

21. Children

21.1 The Services are not directed at children.

21.2 Neotiqa does not knowingly seek to collect children's personal data through the Website or recovery service.

22. Data protection complaints

22.1 A data protection complaint may be sent to hello@neotiqa.com.

22.2 The complaint should include the complainant's name and contact information, the processing concerned, why they believe there is a problem, the outcome sought, and any relevant reference or evidence.

22.3 Neotiqa will acknowledge, investigate and respond in accordance with applicable data protection law and may request further information or proof of identity.

22.4 Individuals also have the right to complain to the Information Commissioner's Office.

22.5 Further information about complaints is available at ico.org.uk/make-a-complaint.

23. Changes to this Policy

23.1 Neotiqa may update this Privacy Policy to reflect changes in its Services, systems, providers, processing activities, legal requirements or regulatory guidance.

23.2 The current version will be published on the Website with a revised version number and effective date.

23.3 Material changes may also be communicated directly where appropriate.

24. Contact us

24.1 Questions, rights requests and complaints should be sent to:

Company

Neotiqa Limited

Address

71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

hello@neotiqa.com

Telephone

+44 20 8191 3412

We recover unpaid B2B invoices, professionally.

London