1st UK Customer Privacy Notice

Why should you read this document?

While dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, 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 describing or relating to your circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, and national insurance number.

Your Personal Data may also identify you indirectly, such as your employment situation, physical and mental health history, or any other information associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Mortgage/Finance requirements, Your Personal Data may include the following:

Title, name, 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 about the processing we may undertake in relation to this type of information)
Any pre-existing mortgage/finance products and the terms and conditions relating to these

The basis upon which our website will deal with Your Personal Data

When we speak with you about your mortgage/finance, we do so because both parties are entering into a contract for the supply of services.

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, during initial discussions with you or when the contract between us has ended 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 or to contact you to seek feedback on the service you received.

Occasionally, 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 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 Personal Data

Suppose you have parental responsibility for children under the age of 13. In that case, it is also very likely that we will record information on our systems relating to those children and, potentially, their Special Data.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from various sources, mainly directly from you. You will usually provide information during our initial meetings or conversations with you to establish your circumstances, needs, and preferences in relation to mortgages/finance. 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 electoral register, also known as the voters roll.

Suppose we use technology solutions to collect Your Personal Data, for example, software that can verify your credit status. In that case, we will only do so if we have consent from you or our nominated processor to access your information in this manner.

Regarding electronic ID checks, we would not require your consent but will 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, computer systems, email, hard drives, and cloud facilities. Employees and consultants within our firm can only access this information when it is necessary to provide our service to you and perform any administration tasks associated with or incidental to that service.
Submit Your Personal Data to Mortgage Lenders in paper form and online via a secure portal. Providing 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 to respond to any queries you may have concerning any mortgage/finance product you may take out or to inform you of any developments in relation to those products and/or policies of which we might become aware.

Sharing Your Personal Data

From time to time, Your Personal Data will be shared with the following:

Mortgage lenders / Finance lenders
Third parties who we believe will be able to assist us with your enquiry or application or who can support your needs as identified. These third parties will include, but may not be limited to, our compliance advisers, product specialists, providers of legal services and valuers (in each case where we believe this to be required due to your circumstances).
This will include an introduction to affinity partners such as Fluent Money and Key Partnerships.

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/finance 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.

We do not envisage that the performance of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and Retention of Your Personal Data

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 being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your 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 postage methods when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us. However, your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

You can:

Request copies of Your Personal Data that is under our control
Ask us to explain further 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 contact 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 to exercise any of your rights set out within it, please contact Tony Ulph at Enquiries@alchemymoney.co.uk

If we feel we have a legal right not to deal with your request or to action it in a different way than how you have requested, we will inform you of this at the time.

You should also contact us as soon as possible if you become aware of any unauthorised disclosure of Your Personal Data so that we may investigate and fulfil our own regulatory obligations.

Suppose you have any concerns or complaints about how we handled Your Personal Data. In that case, 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 The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Data Subject Consent Form

I hereby grant Alchemy Money Limited permission to process my personal data as stated in the Customer Privacy Notice above.

Signed: Signed:

Print Name: Print Name:

Date: Date: