We collect or use the following information to provide services and goods, including delivery:
Names and contact details
Addresses
Date of birth
Payment details (including card or bank information for transfers and direct debits)
Credit reference information
Account information
Identification documents
We also collect or use the following information to provide services and goods, including delivery:
Racial or ethnic origin
Health information
We collect or use the following information for the operation of customer accounts and guarantees:
Names and contact details
Addresses
Payment details (including card or bank information for transfers and direct debits)
Information used for security purposes
Marketing preferences
We collect or use the following information for service updates or marketing purposes:
Names and contact details
Addresses
Marketing preferences
Location data
We collect or use the following information to comply with legal requirements:
Name
Contact information
Identification documents
Financial transaction information
We also collect or use the following information to comply with legal requirements:
Health information
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Address
Payment details
Account information
Purchase or service history
Witness statements and contact details
Relevant information from previous investigations
Customer or client accounts and records
Financial transaction information
Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have theright to ask us for copies of your personal information. You can request otherinformation such as details about where we get personal information from andwho we share personal information with. There are some exemptions which meansyou may not receive all the information you ask for. You can read more about this right here.
Your right to rectification - You have theright to ask us to correct or delete personal information you think isinaccurate or incomplete. You can read more about this right here.
Your right to restriction of processing - You have theright to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to data portability - You have theright to ask that we transfer the personal information you gave us to anotherorganisation, or to you. You can read more about this right here.
Your right to withdraw consent - When we useconsent as our lawful basis you have the right to withdraw your consent at anytime. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Improving Customer Experience: We process personal data to enhance the quality of our services by analyzing customer feedback and service usage. This helps us tailor our offerings to better meet customer needs while ensuring their privacy is respected.
Fraud Prevention and Risk Management: We collect and use personal data to protect our customers and business from fraud and other security risks. This processing is necessary to ensure the integrity and security of our services and aligns with legal and industry requirements.
Direct Marketing and CommunicationWe use personal information to provide customers with relevant updates about our services, promotions, and offers. Customers can opt out of receiving marketing communications at any time.
Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Efficient Account Management You process personal data to ensure customer accounts are up-to-date, accurate, and managed efficiently. This allows you to provide a seamless service experience without unnecessary delays or disruptions.
Fraud Prevention and Security Personal data is processed to protect both the customer and your organisation against fraudulent activities, ensuring the security of customer accounts and maintaining trust in your services.
Improving Service Delivery You may use customer data to identify ways to enhance your service offerings and tailor them to customer needs. This benefits the customer by improving the quality and relevance of your services.
Resolving Queries and Complaints Personal data is processed to handle and resolve customer queries or complaints related to their accounts or guarantees. This ensures customers receive timely and accurate support.
Personal data is used to communicate important updates related to customer accounts or guarantees, such as changes in terms, reminders, or service interruptions.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
We process personal information to send service updates and marketing communications that we believe are relevant and beneficial to our customers. This includes notifying customers about updates to existing services, promotions, or new products that align with their interests or previous interactions with us. We have carefully assessed the impact of this processing and determined that it does not override the privacy rights of individuals. Customers can opt out of receiving marketing communications at any time by contacting us or using the unsubscribe link provided in our emails.
Our lawful bases for collecting or using personal information for legal requirements are:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
We process personal information to ensure compliance with regulatory obligations and internal governance processes. While most compliance activities fall under legal obligation, we also have a legitimate interest in maintaining accurate records and demonstrating compliance with applicable laws and standards to regulatory authorities. This processing supports our business operations, protects our reputation, and ensures that we can operate lawfully while safeguarding the rights and freedoms of individuals.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
We process personal information to effectively handle and resolve customer queries, complaints, or claims. This helps us improve customer satisfaction and ensure the proper operation of our services. It also allows us to identify and address any recurring issues to improve our processes. We balance this interest with the rights of individuals by ensuring that only the relevant data is used and that the processing is proportionate to the purpose.
Where we get personal information from
Directly from you
Insurance companies
Supplies and service providers
Thirt parties
Other Brokers or Financial Advisors We may receive your personal information from other brokers or financial advisors you have engaged with. This helps us facilitate mortgage or insurance applications, manage claims, or provide financial advice effectively.
Marketing Companies We may obtain your personal information from marketing companies where you have provided consent for your details to be shared with us. This information allows us to send you relevant offers, updates, or promotions regarding our services.
How long we keep information
Data Retention
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, tax, accounting, or reporting requirements. We also retain personal information to resolve disputes and enforce our agreements.
Retention periods may vary depending on the type of data and the legal or business purposes for which it is used. Examples include:
Customer Contracts Retained for 6 years after the contract ends to comply with legal obligations.
Marketing DataCustomer Contracts Retained for up to 2 years after your last interaction with us, unless you opt out earlier.
Complaints or Claims Retained for 6 years after resolution for legal or regulatory purposes.
Once the retention period expires, personal data will either be securely deleted, anonymised, or archived for research or statistical purposes.
Who we share information with
Others we share personal information with
Insurance companies
Professional or legal advisors
Financial or fraud investigation authorities
Relevant regulatory authorities
Organisations we're legally obliged to share personal information with
Suppliers and service providers
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’saddress:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
