Customer Privacy Notice

In this Customer Privacy Notice the terms, 'we', 'us' and 'our' are references to Embrace Financial Services which is a trading name of Embrace Financial Services Ltd. Embrace Financial Services Ltd  is part of the Pivotal Growth group of companies of which the ultimate parent company is Pivotal Growth Limited (Pivotal Growth). Embrace Financial Services Ltd is also an Appointed Representative of PRIMIS Mortgage Network which is a trading name of First Complete Limited (Our Network). From time to time we authorise advisers to provide our services independently or under a separate trading name but within Embrace Financial Services. Where this is the case the brand names are listed below.  

Why are we asking you to read this document?

During the course of dealing with us we will collect or 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) via all the methods we communicate with you including our website www.embracefs.co.uk (Our Site). We would like to explain to you what we will need to do with Your Information, and the various rights you have including:

• What do we mean by “Your Information”?
• The basis upon which we will deal with Your Information
• The basis upon which we will process certain parts of Your Information
• How do we collect Your Information?
• What happens to Your Information when it is disclosed to us?
• Sharing and transferring Your Information
• The basis upon which our Network will deal with Your Information, Your Special Category Data and Criminal Disclosures
• Security and retention of Your Information
• Your rights in relation to Your Information
• How to make contact with Our Firm in relation to the use of Your Information
• 3rd Party Trading Names

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 lifestyle history, details of treatment and prognosis, medical reports, whether or not you smoke (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
• details of the type of mortgage and/or protection you require where you are receiving mortgage and/or protection advice from us;
• details provided to us by the underwriter of your protection policy relating to any claims made by you once your policy is live. This allows us to monitor claims handling processes and ensure we have the information we need to assist you with the renewal of your policy; and
• responses and feedback which you provide to us in customer surveys, in order that we can monitor the quality of the service we provide and make improvements.
• your name, postal address, phone number and email address when you submit a request to be contacted through our Contact Us page;
• cookie data which relates to your use of Our Site and;
• data sent from your browser to our server which may include:
  • the time, date and duration of your visit to Our Site;
  • the site from which you have come (the referral URL);
  • the pages visited on Our Site; and
  • your IP address.

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The basis upon which we will deal with Your Information

When we speak with you about your mortgage and/or insurance requirements we will 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. If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.

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, fraud prevention or other regulatory obligation to which we are subject.

When needed we may also we may also seek your consent to process your Information by passing it to a partner organisation to provide you with additional advice or service not currently provided by Us. The organisation we pass your Information to will provide you with their own Privacy Notice and you can withdraw or amend that consent at any time.

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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 for information which is of a sensitive nature such as your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category 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 Category Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to current (including charged but not tried yet) or historic criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

Your Special Category 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 but it will be processed with the standards of security required by relevant Data Protection laws.

When we process Your Special Category 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, support any claims and to prevent fraud.

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How do we collect Your Information?

We will collect and record Your Information from a variety of sources, including our introducer organisations and partners, 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 by email and via video or conference calling technology (that we provide).

Unless already provided by an introducer organisation or partner 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.

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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 us, 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 arranging an appointment and 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
• to provide you with future updates in relation to the mortgage and or protection market by post, phone and email, in accordance with your preferences and to provide you with information which we reasonably believe may be relevant to you based on the services we are providing to you including for example information on property insurance

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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 via our service.

Where we transfer Your Information to a third party, this will include but may not be limited to, product specialists (including those within our Network and other Appointed Representatives of the Network such as First2Protect), specialist mortgage lenders, estate agents, providers of legal services such as conveyancing, Surveyors and Valuers.

Outside of our network, we may share your information with certain selected third party companies to perform functions to support our marketing activities.  These include The Marketing Lounge Partnership Limited (MLP) with whom we will share your data to administer specific marketing campaigns and fulfilment that you have opted in to receive. Here is a link to the MLP privacy policy https://mlp.agency/privacy/. 

Your Information is only transferred where we believe this to be required due to your particular circumstances and/or 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 UK.

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The basis upon which Our Network will deal with Your Information, Your Special Category 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 Category Data and Criminal Disclosures.

In the course of handling Your Information (including Your Special Category Data/Criminal Disclosures) Our Network will:

• record and store this data on Network systems run on secure servers. It 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, this data 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; and
• need to access and process this data 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.
• retain the data 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.

Please note that the above information is a summary of the Network Privacy Policy for customers. If, you wish to understand in more detail what the Network will do with Your Information and Special Category Data / Criminal Disclosures then please visit the Network Privacy Policy for customers located at http://www.primis.co.uk/privacy-policy-and-tcs.

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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.

The personal information that you provide will be retained by us in accordance with applicable laws and our internal retention policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our retention policy is available on request.

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Your rights in relation to Your Information

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive and we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.

You can:

• 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)
• obtain a copy of personal information safeguards used for transfers outside the EEA
• lodge a complaint with the Information Commissioner's Office (ICO)

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How to make contact with our Firm in relation to the use of Your Information

If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned:

Email: operations@embracefs.co.uk  

Post: Data Protection Officer, Embrace Financial Services Ltd, Floor 4, 11 Leadenhall Street, London, EC3V 1LP

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 Category 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.

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3rd Party Trading Names

From time to time we authorise advisers to provide our services, independently or under a separate trading name within Embrace Financial Services but we ensure that Your Information is processed in the same way as outlined in this Privacy Notice.

My @ Mortgages

E-Woke Financial Services

Woodhead Mortgage Services

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