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Genuine Finance are authorised and regulated by the Financial Conduct Authority. (FRN: 996345)

Genuine Finance Limited Registered office is: 23  Albion Street, Hull. HU1 3TG. (Company No 14588203).

Genuine Finance Limited Business Trading address is 50 Church Road, North Ferriby. HU14 3AA (Company No 14588203)

Our Data Protection Register number (ICO)  is ZB554083.

Genuine Finance Limited will be the data controller for the data that you provide us with or we collect in relation to the provision of our Services to you (as defined in our  terms and conditions).

You can find out more about us by visiting our website on www.genuine-finance.co.uk

We respect your privacy and protecting your data is paramount. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Policy carefully before using our Services. Together with our Terms and Conditions, this Privacy Policy sets-out our views and practices regarding your personal data, how we collect, process and treat it, and the rights you have in relation to the protection of your personal data.

By using our Services you are accepting and consenting to the practices described in this Privacy Policy, which we may update at any time.

The information we collect

Information you give us. You may give us information about you when you use our services and when you communicate with us. This includes information you input during registration by answering specific questions on our site, applying for a loan, receiving advice on ways to repay your debts, providing us with feedback, participating in surveys, and when you report a problem.

Personal data collected, used, stored and transferred by us may include:

  • Your name and identity data, including forenames, last name, maiden name, date of birth, gender, marital status or similar identifier.
  • Contact data including home address, email address, telephone number and your residential status.
  • Employment status.
  • Financial information (including bank statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets)
  • Technical Data including internet protocol (IP) address, browser type and version, and other technology on the devices used to access our website.
  • Your banking provider(s).
  • Monthly expenditure.
  • Insurance products you hold.
  • Family and dependents.
  • Your aspirations (e.g. to buy a car).
  • Personal information or documents required to identify you.
  • Profile and Usage Data including feedback and survey responses, and how you use our website, products and services.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences.
  • Special Category Data such as medical or health conditions may only be collected with your explicit consent.

Special categories of data. Information relevant to your health. i.e. health data and therefore, ‘special category data’ may be collected from you where it is identified or disclosed by you to the company. We will only record any such data where it is relevant and limited to what is necessary to provide you with our services or of any third parties that are able to provide you with services and with your explicit and informed consent.

Information we collect about you. We will collect information during your use of Genuine Finance Services including: (a) the details regarding the communications made between us; (b) technical information including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, operating system and platform;

Recording telephone calls and other communications. We will monitor or record most of our telephone conversations or other communications between you and us of which may be used for staff training and monitoring purposes.

Information collected from cookies. We and our service providers collect information about your use of our app from cookies. For more on how we use cookies and how to decline them or turn them off please read our cookie policy.

How do we collect your personal data?

Genuine Finance collect personal data using the following methods:

  • Direct contact with our staff by phone, email, post or otherwise for example; for the purpose of applying for & processing loans, confirming identity, handling complaints etc.
  • Automated technologies or interactions with our website, by using the web enquiry form or the start now function for the purpose of; processing identity, loan application etc.
  • Third parties or publicly available sources such as credit reference agencies, Lenders, couriers, third party & partner websites.

 

Lawful basis for how we use your personal date we collect from you

We will collect information from you in relation to mortgage services and rely on the following lawful basis for processing:

Consent – We will always seek your consent to process certain types of information where we are legally required to do so. We use consent to initially engage with you and may communication through phone, email SMS to discuss your requirements. We request consent to provide you with an ongoing service and to contact you in the future to keep you informed of other products and service from us that may be of interest to you

Legitimate interest: To process your application we will supply your personal information to credit reference agencies (CRA’s), who will give us information about you, such as your financial history. We do this to assess creditworthiness and product suitability, check your identity and prevent criminal activity. CRA’s will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.  We collect information from you about from the Credit Refence Agencies to assess your eligibility for the products you requested

Legal obligation: We collect proof of your identity and proof of address to verify your identity and complete anti-money laundering checks.

Contract and legitimate interest : To manage our relationship with you and inform you of changes to our products and services and re-engage with you to review your existing mortgage or protection needs.

Legal obligation and legitimate interest: To handle case enquiries, complaints and your requests to exercise your rights.

Legitimate interests: We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases on which we collect and use your personal data, you can contact our Head of Risk & Compliance.

Our lawful bases may include consent (where you have given consent), performance of a contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you), compliance with our legal obligations and our own legitimate interests. Examples of this are:

    • Develop and improve our products and services, including for the purpose of quality control and analysis.
    • Deliver relevant website and advertisement content to you.
    • Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
    • Measure or understand the effectiveness of the advertising we serve to you.
    • Use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

You may advise at any time should you no longer wish us to use your data

Third Parties who we collect information from or share information with:

Lenders on our Panel (a list is available on request).

Third Parties: who we believe will be able to assist us with your enquiry or application such as trusted partners.

Providers of legal services: such as conveyancing, surveyors as part of the application process.

Introducers: if you have been introduced to us from an Introducer, we may share limited information to inform them on the progress of the application.

Credit Reference Agency Bureau’s: The identities of the CRA’s and the ways in which they uses and share personal information are explained in more detail at;

Equifax (CRA) https://www.equifax.co.uk/crain

Experian (CRA) https://www.experian.co.uk/crain

Call Credit (TransUnion) https://www.callcredit.co.uk/crain

External Suppliers: Specialist IT system providers such as www.nivohub.com

Our Regulators: to fulfil our legal obligations with the Financial Conduct Authority (FCA) or the Information Commissioner’s Office (ICO). Sharing of information to verify your identity and comply with Anti Money Laundering legislation and co-operate with law enforcement, legal proceedings or regulatory authorities.

Change of Ownership: If we sell, transfer or merge parts of our business or our assets, any personal data supplied by you where relevant to that part of the business will be transferred to the new owner or controlling party and will continue to be used under the terms of this policy for the purposes that the personal data was originally supplied to us.

Software systems – we use third party systems including cloud based storage, to help us manage mortgage applications. Collect credit or debit card payments for our services and to process and verify the personal information you supply to us. All software suppliers store any data in the UK and are subject to US regulations including the UK Data Protection Regulations (DPA) and are obliged to keep your details securely and use them only to fulfil the contracted service.

Please note that the 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. We recommend you also read their Privacy Notice in conjunction with ours which can be found on their own websites.

How long is personal data retained?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Unless we explain otherwise to you, we’ll hold your personal data from the end of your relationship with us for up to 6 years to enable us to respond to any queries or complaints

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

You can exercise specific rights with regards to the data that we hold about you.

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

  • Request access to your personal data.This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You have the right to request copies of all records we hold about you.
  • Request correction of the personal data.This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data.This enables you to ask us to delete personal data where there is no reason for us continuing to process it or where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to delete the data for specific legal reasons, if applicable we will notify you, at the time of your request.
  • Object to processing of your personal datawhere we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms..
  • Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal datato you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Right to complain to the Information Commissioners OfficeIf you are not satisfied with how we respond to your enquiry, you have the right to complain to the ICO, who is the regulator for data protection in the UK. https://ico.org.uk/make-a-complaint/
  • Right to complain to FOS You may also have the right to refer any complaint you make to the Financial Ombudsman Service, which is an independent arbitration service and helps settle disputes between customers and businesses.

For the exercise of any of your rights, you can also contact us at: contactus@genuine-finance.co.uk

Data Security

Your privacy is important to us. We store this on secure servers so that it can only be viewed by authorised personnel. We do our best to protect your personal data, but we cannot guarantee the security of your data you transmit to us, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss, or damage. We only process your information within the UK. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services. Both we and other carefully selected organisations or alternative credit and insurance providers may contact you by telephone, letter, e-mail, SMS or other social media to offer other credit or insurance products which may be of interest to you. We may also send you information about money saving tips and guides. You can opt-out of receiving these types of communications at any time by contacting us at contactus@genuine-finance.co.uk or by clicking on the relevant link in email communications you receive from us.

Website links

We use services such as Google Analytics to track how visitors use our website, to understand trends and how the business works and so that we can improve the user experience. The reports we produce do not identify individuals.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you follow a link to or from our app to a third-party website, please be aware that these websites have their own privacy policies.

Our Service may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Please also refer to our Terms and Conditions for more information.

Contact us

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, you may request this by writing to the Compliance Department Genuine Finance Ltd, 50 Church Road, North Ferriby, HU14 3AA.

We shall respond to your request as soon as possible, depending on the complexity of the request but no later than one month from receiving it. If we need additional time, we will tell you and give you the reasons why.

If you are not satisfied with how we respond to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

You may also have the right to refer any complaint you make to the Financial Ombudsman Service (FOS), which is an independent arbitration service and helps settle disputes between customers and businesses.