Customer Privacy Notice

Why are we asking you to read this document?

During the course of dealing with us we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Information). We would like to explain to you what we will need to do with Your Information, and the various rights you have in relation to Your Information.

What do we mean by "Your Information"?

Your Information means any information describing or relating to you. Your Information may identify you directly (e.g., your name, address, date of birth, National Insurance number) or indirectly (e.g., your employment situation, physical/mental health history, or cultural/social identity).

In the context of providing you with assistance in relation to your mortgage and/or insurance requirements, Your Information may include:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses, and identity verification documents.
• Employment and remuneration information (salary, bonus schemes, overtime, sick pay, other benefits) and employment history.
• Bank account details, tax information, loans and credit commitments, personal credit history, income and expenditure, family circumstances, and dependents.
• Health status and history, treatment details, prognosis, and medical reports.
• Any pre-existing mortgage and/or insurance products and their terms and conditions.

The basis upon which our Firm will deal with Your Information

When we speak with you about your mortgage and/or insurance requirements, we do so on the basis that a contract for the supply of services is in place between us. To perform that contract and arrange the products you require, we have the right to use Your Information.

Alternatively, if the contract has ended or during initial discussions, we have the right to use Your Information provided it is in our legitimate business interest to do so and your rights are not affected (e.g., seeking feedback or responding to lender requests).

On occasion, we may use Your Information to meet legal or regulatory obligations (e.g., compliance responsibilities to our Network).

Special Data and Criminal Disclosures

We process Your Special Data and Criminal Disclosures on the basis that it is in the substantial public interest to provide vital insurance products, as permitted by UK data protection laws.

How do we collect Your Information?

We collect Your Information mainly directly from you during meetings or conversations, verbally or in writing (including email). We may also obtain information from:

• Third parties (e.g., credit checks, employer information).
• Public domain searches (e.g., voters roll).
• Technology solutions (e.g., online identity verification or banking access software). Note: You will be required to provide consent for such technology before use.

What happens to Your Information?

In the course of handling Your Information we will:

• Record and store it in paper files, mobile devices, and computer systems (websites, email, hard drives, cloud facilities).
• Submit it to mortgage lenders and insurance providers (paper or online) to progress applications.
• Input it into our Network’s computer systems.
• Use it to respond to queries or inform you of product developments.

Sharing and transferring Your Information

From time to time Your Information will be shared with:

• Our Network: PRIMIS Mortgage Network.
• Mortgage lenders and insurance providers.
• Third parties: Product specialists, estate agents, conveyancers, surveyors, and valuers (where required).

Note: Sharing with third parties is for progressing your enquiry, not for them to send you marketing messages.

If we transfer data outside the UK, we ensure adequate protection levels are in place in compliance with privacy laws.

Our Network: PRIMIS Mortgage Network

Our Network is authorised and regulated by the Financial Conduct Authority (FCA). They are responsible for the quality of advice we provide on regulated products. The Network will:

• Store Your Information on secure servers.
• Access data for supervision, training, quality audits, surveys, and complaint handling.
• Share data with regulators (FCA, HMRC, etc.) if required.
• Retain data for a minimum of six years (or longer if required by law).

For more details, view the Network Privacy Policy.

Security and Retention

We take reasonable steps to safeguard Your Information against unlawful access, loss, or damage. We expect you to also take steps to safeguard your privacy (e.g., using secure postage and encrypted emails).

Retention: Your Information will be retained by us for a minimum of six years, or the duration of our relationship with you if longer.

Your Rights

You have the right to:

• Request copies of Your Information under our control.
• Ask us to explain how we use Your Information.
• Ask us to correct, delete, or restrict the use of Your Information (subject to limitations).
• Ask for an electronic copy to be sent to another organisation.
• Change the basis of any consent regarding future marketing.

Contact Us

If you have concerns about how we handle your data, you may lodge a complaint with the ICO (Information Commissioner's Office) at https://ico.org.uk.