Gecko Mortgage Broker Privacy Policy
Introduction
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 Personal Data). This document is important as it allows us to explain to you what we
will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data 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/Loans/Financial and Insurance
Your Personal Data 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/Loans/Financial and Insurance products and the terms and conditions
relating to these.
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Mortgage/Loans/Financial and Insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed 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 Personal Data 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 Compliance Service Provider 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 Personal Data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a
legal, compliance or other regulatory obligation to which we are subject.
How do we receive information about you?
We receive your Personal Information from various sources:
- When you voluntarily provide us your personal details in order to register on our Site;
- When you use or access our Site in connection with your use of our services;
- From third party providers, services and public registers (for example, traffic analytics vendors).
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example 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/guidance regarding the suitability of any product that may be availableto you.
If you have parental responsibility for children under the age of 13, it is also very likely that we 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 toinsurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
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 Personal Data?
We will collect and record Your Personal Data 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 toestablish your circumstances and needs and preferences in relation to Mortgage/Loans/Financial andInsurance. 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 youremployer, and searches of information in the public domain such as the voters roll. If we use technologysolutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent butwill inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This nformation can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
.
• Submit Your Personal Data to Product Providers / Mortgage Lenders / Commercial Lenders / Insurance Product Providers / Conveyancers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made
on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Mortgage/Loans/Financial and Insurance you may take out, or to inform you of any developments inrelation to those products and/or polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
• Mortgage/Loans/Financial/Conveyancing Firms 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. These third parties will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, lead introducers, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
• Data will be passed to Credit Reference Agencies and searches conducted to validate your identity, your credit history and your criminal records. The Credit Reference Agencies/Criminal Records Bureau may check the details supplied against any databases (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. We may also use information gained from conducting the credit search to identify the most suitable lender for your circumstances. A record of the search will be retained, but will not affect future credit. By signing this you are agreeing to a search being undertaken in this way.
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your Mortgage/Loans/Financial/Conveyancing and Insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you
marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to
you, and as otherwise set out in this Customer Privacy Notice.
Security and retention of Your Personal Data
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
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
being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
You can request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data.
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (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 Personal Data 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 Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exerciseany of your rights set out within it please contact:
Charlotte Lowe – Tel:01477 571 355
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 contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, 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 Personal Data 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.
Marketing/E-Marketing Consent
(our Firm), is a Company Registered in England and Wales/Scotland/Northern Ireland whose Company
Registration Number is 10710985
Why are we asking you to read and complete this E-Marketing Customer Consent?
As a valued customer, we would like to provide you with reassurance that we take your right to privacy in an electronic context seriously.
During the course of providing you with our service, this Firm may be in contact with you through a variety of electronic means, including potentially by telephone, email, SMS and instant messaging services (such as WhatsApp). These means are referred to in this document as E-Marketing.
We would like to take particular care to ensure that any marketing or promotional information that we may send to you, is done so with your prior, express permission. We would like to keep you informed about products or services that we, or selected third parties, may have access to that may be of interest to you. In this document, we explain how we would do this, and ask for your consent to receiving such information
from us in the future.
How this E-Marketing Consent relates to our Customer Privacy Notice
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 Personal Data).
During the course of our initial discussions with you, you will have been provided with a copy of, or been provided with access to, our Customer Privacy Notice (contained within this document). We encourage you to read this document, as it sets out in detail the basis upon which this Firm will process and share Your
Personal Data.
Our Customer Privacy Notice does not extend to explaining how we would like to use Your Personal Data for marketing purposes, including to E-Market to you. We are of the view that this is better set out separately, to enable you to be clear and make informed decisions in relation to your right to privacy.
How we will use Your Personal Data in the future
There are a range of reasons why we need to retain Your Personal Data and, when necessary, use it to make
contact with you. These include:
• asking your views on the quality of the service we have provided
• responding to your own questions on the product you have taken out
• informing you with regard to any changes to the terms and conditions of your products proposed or
made by mortgage lenders and insurance providers
Specifically, we would also like to make your aware of products or services that are made available to our firm from time to time that we think may be of interest to you in the future. We propose to do this by any of the E-Marketing means, using contact information you have provided to us.
IMPORTANT NOTES: Marketing by our Firm
If you do not indicate your agreement for us to make contact with you, we may be unable to provide you with details of products and/or services that may suit your needs and circumstanc
We would like to maintain a record of your express consent for us to contact you by post, telephone, SMS, email and instant messaging for marketing our products or services that we think may be of interest to you.
Please indicate your consent to us contacting you by any of the means specified below:
The Credit Reference Agencies may check the details supplied against any databases (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. We may also use information gained from conducting the credit search to identify the most
suitable lender for your circumstances.
A record of the search will be retained but will not affect future credit. By ticking this box are agreeing to a
search being undertaken in this way.