Last updated: 22/05/2018
Customer Privacy Notice
2020 Financial Solutions (our Firm, we, our, us) an Appointed Representative of PRIMIS Mortgage Network a trading name of First Complete Limited (Our Network)
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, for example your name, address, date or birth, National Insurance number and the like. Your Information may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or 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 documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing mortgage and/or insurance products and the terms and conditions relating to these
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. In order to perform that contract, and to arrange the products you require, we have the right to use Your Information for the purposes we set out below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, 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. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Network relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Information to enable us to meet any contractual responsibilities we may owe our Network, or for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Information
Where you ask us to assist you with your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently our Network) will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as set out in this Customer Privacy Notice.
When we process your Special Data and any Criminal Disclosures we do so on the basis that it is in the substantial public interest to be able to provide vital insurance products and as permitted by UK data protection related laws and regulations from time to time. Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Information?
We will collect and record Your Information from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to mortgages and insurance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Information, such as software that is able to verify your identity on-line or to access your credit status and/or bank account entries, then you will be required to provide your consent for us or our nominated processor to access your information in this manner, and details of how such software operates will be provided to you prior to the activation of the service.
What happens to Your Information when it is disclosed to us?
In the course of handling Your Information we will:
• record and store Your Information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by our Firm as necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
• submit Your Information to mortgage lenders and/or insurance product providers, both in paper form and on-line via mortgage lender/insurance provider systems, in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that mortgage lenders and insurance providers may raise
• input Your Information, along with full details of the mortgage and/or insurance, discussed with you or which you have taken out, to the computer systems of our Network
• use Your Information for the purposes of responding to any queries you may have in relation to any mortgage product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware
Sharing and transferring Your Information
From time to time Your Information will be shared with or transferred to:
• our Network
• to mortgage lenders and insurance providers
• third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified, such third parties will include but may not be limited to, product specialists (including those within our Network and other Appointed Representatives of the Network), estate agents, providers of legal services such as conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances). in each case for the purposes set out in this customer privacy notice, i.e. to progress your mortgage and/or insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Information being transferred outside of the European Economic Area.
The basis upon which our Network will deal with Your Information, Your Special Data and Criminal Disclosures
Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you in relation to your mortgage and/or insurance products, where those products are regulated by the FCA. In the course of doing so, our Network will also process Your Information generally, including Your Special Data and Criminal Disclosures.
In the course of handling Your Information and Your Special Data/Criminal Disclosures our Network will:
• record and store Your Information and Your Special Data/Criminal Disclosures on Network systems run on secure servers. Your Information and Your Special Data/Criminal Disclosures will be accessed by authorised employees and consultants within, or engaged, by the Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation the Network may have
• use, and where appropriate transmit, Your Information and Your Special Data/Criminal Disclosures to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the Office of the Information Commissioner or any other regulatory, law enforcement or governmental body
• need to access and process Your Information and Your Special Data/Criminal Disclosures to deal with enquiries received from mortgage lenders and insurance providers that relate to the service this Firm has provided to you, including the payment of any commission or fees to us that may be linked to the product you have taken out. Your Information and Your Special Data/Criminal Disclosures will be retained by our Network either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable the Network to fulfil its legal and regulatory obligations.
Security and retention of Your Information
Your privacy is important to us and we will keep Your Information secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.
Your Information will be retained by us either electronically or in paper format for a minimum of six years, or if longer than six years, the duration of this Firm’s relationship with you.
Your rights in relation to Your Information
THE RIGHTS MARKED WITH A * ARE EFFECTIVE FROM 25 MAY 2018
• request copies of Your Information that is under our control
• ask us to further explain how we use Your Information
• ask us to correct, delete* or require us to restrict or stop using Your Information (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Information to another organisation should you wish*
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Information
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact: Mr Naveed Muzaffar Data protection officer for 2020 Financial solutions on 07968 852 758 or Naveed.muzaffar@ 2020financialsolutions.co.uk
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time. You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Information, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Information or Your Special Data/Criminal Disclosures you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
2020 Financial Solutions Ltd ("us", "we", or "our") operates https://2020financialsolutions.com (the "Site"). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.
We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.
Information Collection And Use
While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name ("Personal Information").
Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data").
This Log Data may include information such as your internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.
We collect analytics information when you use the Websites to help us improve them. We may also share anonymous data about your actions on our Websites with third-party service providers of analytics services.
Information Collected From Other Sources
Social Media Widgets:
The Websites include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.
Information From Third Party Services:
We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services. For example, you can log in to the Services using sign-in services such as Facebook Connect or an Open ID provider, as further described below.
You can log into certain Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.
How We Use Information That We Collect
We use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at firstname.lastname@example.org or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.
Sharing Of Information Collected
Third-Party Service Providers:
We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.
From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at email@example.com.
We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to firstname.lastname@example.org.
Correcting, Updating and Removing Your Information
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com. Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting firstname.lastname@example.org for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email email@example.com. Requests to access, change, or remove your information will be handled within 30 days.
An individual who seeks access to, or who seeks to correct, amend, or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Websites or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.
Children’s Personal Information
We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at email@example.com, and we will use commercially reasonable efforts to delete that information.
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.
Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.