Who are we?
EquityReleaseScotland.org (ERS) who operates this website is a trading style of Lifemortgage UK Ltd a limited company registered in Scotland No. SC 570501 with its head office at 29-31 Burrell Street, Crieff, Perhshire, PH7 4DT. Lifemortgage UK Ltd is an Appointed Representative of Britannia Financial (UK) Ltd a limited company registered in Scotland No. SC 431527 with its head office at 23 Brighouse Park Cross, Edinburgh, EH4 6GZ which is authorised and regulated by the Financial Conduct Authority and are entered in the Financial Services Register (htpps://register.fca.org.uk/). The Financial Services No. of Lifemortgage UK Ltd is 784210 and the Financial Services No. of Britannia Financial (UK) Ltd is 776344. ICO Registration Number ZA264399
What Information do we collect?
When clients (i)register on our website, (ii)complete any of our enquiry forms (iii)respond to any survey we may launch (iv)agree to a face to face meeting (v)discuss their requirements remotely by telephone (vi)provide initial information for another party on e.g. a joint application, the information we gather may include:
i) Your name, ii) Your postal address, iii) Your e-mail address iv) Your contact telephone number, v) The value of your residential property vi) The value of any outstanding secured debt on your property, vi) Your age, vii) Your contact preferences viii)sensitive personal data, such as medical conditions, (ix)income and outgoings, (x)criminal convictions, (xi)credit status, (xii)Solicitors/Accountants details, (xiii)Bank/building society details (xiv)Your IP address; All to help us accurately advise and arrange a suitable product on your behalf for your own unique and individual circumstances.
Please note: There is no obligation or requirement for any of our clients to enter any personal information whatsoever, as they have the right to remain anonymous while visiting our website. However, any information provided will be deemed offered voluntarily by clients and treated in the strictest confidence by us.
What we do with your information:
We will use your data for advising and arranging equity release products for you, this may involve providing quotes and illustrations, responding to enquiries, completing and submitting paperwork and handling complaints.
We may also use your data to prevent and detect fraud and other crimes, to verify identity using various credit reference agencies, establish your financial history and confirm you are not on the HM Treasury Financial Sanctions List and to prevent money laundering.
We may also use your data to fulfil our legal and regulatory obligations, such as sharing personal data with authorities such as the FCA, HM Revenue & Customs, The Information Commissioners Office, the Police and other Government agencies if requested to do so.
To initially process your enquiry which may include sending out a brochure highlighting our services.
Calling, writing, e mailing and texting you, if requested by you, and arranging an appointment with you and one of our Advisers at a suitable time convenient to you.
To ultimately process any of our services or products requested by you which may include the sharing with you of information relevant to your order and keeping you appraised of developments throughout the order process.We may use your e mail address to send you information periodically about our products and services which we feel may be of interest to you. You will always have the option to opt-out from all and any future correspondence as per the terms of our ‘Opt-out’ Policy below.
To improve the functionality of our Website using any feedback received from you.
To enhance and improve our customer service using any feedback from you.
To carry out market research from time to time.
To service and administer any promotions and prize draws we may run from time to time.
Using your personal information and Our Advice Process:
- We will use the personal information provided by you to research the Equity Release market to find an appropriate and suitable product based on your needs and individual and unique circumstances.
- You will be provided with an illustration(s) highlighting and detailing the relevant information discussed with you and clarify and queries or questions you may have thereafter.
- You will also be provided with a Keyfacts about our services document, a copy of our Vulnerable Customers Policy and the Equity Release Council Code of Conduct document.
- Should you accept our advice, we will then use your personal information to complete the application form for the recommended lender contained within our illustration.
- Throughout the entire process we will liaise with you, the lender and your chosen Solicitor to a satisfactory completion.
- In the event of a complaint from you about our service provided to you, we will also use your personal information to assist us in this purpose.
- The data provided will be held on internal systems and our software providers until they are removed as per our retention policy.
Legal Basis for Processing your Data:
We will process your personal information only when we have a legal basis for doing so. It is your right as the subject of this Data to be informed what the legal basis is.
Contractual Performance or activities prior to entering into a contract:
We will process your Data using this basis for the purposes of providing a quotation, advising upon and arranging your mortgage products, responding to complaints and for mortgage/policy enquiries. Some personal Data are classified as ‘special categories’ of Data for example, Medical Conditions or Criminal Records Data-information relating to unspent criminal convictions. These categories of Data will be processed in accordance with the Law on the legal basis that it is necessary for the performance of a contract. Other Legitimate interests include for Marketing purposes, by keeping you informed when you may need to review a product or when you may require to complete a new or vary your existing Will or complete your Power of Attorney application and lodgement with the Office of the Public Guardian in Scotland. Consent by you for such purposes can be withdrawn by you at any time.
Your Legal Rights:
- Right to be informed– You have the right to have a copy of all the personal information we hold on you.
- Right of Access– You have a right to know how this personal information is stored by us, used by us in our business and how it may be shared with any third party. This can be requested via a SAR (Subject Access Request) (FREE of CHARGE) sent to: The Data Protection Officer, Equity Release Scotland.Org, 23 Brighouse Park Cross, Edinburgh, EH4 6GZ. By e mail at email@example.com or by telephone on 0333 360 1958. This information will normally be provided to you within 30 days from your initial request.
- Right of Rectification– You have a right to request that we correct or amend the personal information we hold on you, object or restrict the processing of this information and request that it be erased where there is no legitimate reason we should remain holding and processing such information. In the case of a valid request, we will apply this to any third party who we have shared the information with.
- Right of Erasure– Where you have given express consent for us to process your personal information you have the right to withdraw that consent at any time where there is no legitimate reason we should remain holding and processing such information. In the case of a valid request, we will apply this to any third party who we have shared the information with.
- Right to restrict the processing of your information. If it is identified that the information we hold is not accurate, you can request that any processing is restricted until such time as we can verify this and any other errors, and make the appropriate corrections. You are entitled to this Right if you believe the processing of the information is unlawful or if you are awaiting a decision following any objection raised by you regarding any automated decision process.
- Right to Object to your information being processed and can withdraw your consent at any time.
- Right to information Portability. You have the right to request that we provide this information in machine readable format and you have the right to request that we transfer the information to third parties for you to use in a format of your choice.
Our ‘Opt-Out’ Policy
Once you have registered your information with us via our Website you can change your mind about receiving e mail and postal correspondence from us by either writing to us at: Data Protection Officer, Equity Release Scotland.Org, 23 Brighouse Park Cross, Edinburgh, EH4 6GZ. By e mail at firstname.lastname@example.org or by telephone on 0333 360 1958.
Who will we share your personal data with?
We will not sell, share or otherwise convey your ‘personally identifiable information’ to external parties other than to trusted third parties who assist us in:
Providing to you the product or service ordered by you.
Maintaining and operating our Website.
Executing our business.
Processing and monitoring data on how clients use our Website.
Furthermore, these trusted third parties will all agree to keep your ‘personally identifiable information’ strictly private and confidential and held in accordance with the Data Protection Act 1998 and all subsequent amendments and the General Data Protection Regulation (GDPR) 2018.
We may pass your ‘personally identifiable information’ to:
Verify your identity and contact information with external data bureaus.
Law enforcement agencies to comply with the Law.
Protect our legal rights, to promote our safety and to protect our property, intellectual and otherwise and those of our trusted third parties.
Collection agencies in the event of default of any contractual obligations.
‘Non-personally identifiable information’ may however, be used by trusted third parties for marketing, processing and sorting of data and for advertising purposes.
Your personal information may be shared with various credit reference agencies such as Equifax and Experian.
Where you have been introduced by a third party, we may be obliged to inform them that a product has been purchased to fulfil our contractual obligations to them.
The chosen lender may pass your details onto third parties, such as credit reference agencies, anti-fraud agencies, other Government agencies when asked to do so including HMRC.
We may be under a legal obligation to share your personal information with other Government agencies for the purposes of crime prevention.
Your personal information may also be shared with internal and external auditors or professional advisers such as Solicitors and Accountants, as well as the Financial Ombudsman Service in regard to any complaint made or the Financial Services Compensation Scheme in the event that a product provider fails.
We may share your personal information with anyone named on the Mortgage or Equity Release Mortgage or anyone whom they have authorised to discuss the Mortgage or Equity Release Mortgage on their behalf.
In the event we take payment from Credit/Debit card providers we may share your personal information with them to validate card details and obtain payment.
In the event of the business being re-organised or sold to a third party, we may share your personal information with the new entity or third party.
For how long will we hold this personal information:
We will only hold your personal information for as long as required by our Regulator the FCA and in line with the Information Commissioner’s Office rules. In the case of an Equity Release or Mortgage contract we will hold this information for a period not exceeding seven years from when the product recommended ends and the lender is repaid in full. For clients who do not proceed with our recommendations initially, we will hold their information for a period of three years.
‘Third Party’ Linked sites:
We may at our discretion offer on this website ‘third party’ products or services who have, themselves, their own privacy policies. We respectfully request that when using these ‘linked’ sites that users familiarise themselves with the privacy policies of the linked sites. We accordingly, assume no responsibility or liability for their content of these associated or linked sites nor does the appearance of third party linked sites imply endorsement from us to the goods and services of the linked sites.
Equity Release Scotland may collect statistics about the behaviour of visitors to its websites. Equity Release Scotland may display this information publicly or provide it to others. However, Equity Release Scotland does not disclose personally-identifying information other than as described below.
Corrections, Updates & accessing your information:
If at any time, you would like to correct, update or request a copy of all the information we hold on you please send your request in writing to: Data Protection Officer, Equity Release Scotland.Org, 23 Brighouse Park Cross, Edinburgh, EH4 6GZ. By e mail at email@example.com or by telephone on 0333 360 1958.
COPPA (Children’s Online Privacy Protection Act):
We will never collect any information from minors under the age of 13 which is in full compliance of the Children’s Online Privacy Protection Act.
Protecting your information:
All the information we collect via this website is encrypted and delivered to us through a secure environment. We use rigorous methods in doing so to ensure your private information is appropriately protected. E mails sent by us to your e mail address are not secure, accordingly we will never include any of your personal identifying information by e mail without your prior agreement and permission. It is our company policy to respond to your enquiry by telephone in the first instance and thereafter by standard mail. If you have any concerns or reservations in using e mail as a mode of communication with us, you may also elect to use the telephone or standard mail. We can accept no liability for any losses or damages as a result of the loss of confidentiality of the aforementioned information by e mail.
Use of our Website:
By entering your details on our website, you agree that we may call you to discuss a Mortgage, regardless of whether you choose to proceed with it.
Copyright & Trademark:
All pages in this website, all screens displaying content and all information and material contained within this website is wholly owned by Equity Release Scotland.org. Any reproduction, in whole or part, without the prior written consent of Equity Release Scotland.org is strictly prohibited.
We cannot warrant that our website will be free from any viruses or defects and cannot accept responsibility for any technical issues our users may suffer as a result of using our website. In the event of disruption to the use of this website as a result of us carrying out maintenance for any reason or purpose we will keep the said disruption to an absolute minimum.
Your Right to Complain:
Should you have any concerns regarding the way in which we have used or processed your personal information, please call, write, e mail or otherwise notify our Data Protection Officer at Equity Release Scotland.Org, 23 Brighouse Park Cross, Edinburgh, EH4 6GZ. By e mail at firstname.lastname@example.org or by telephone on 0333 360 1958.
You can also raise your concern by contacting the Information Commissioner’s Office (ICO) on 03031231113 or visiting their website at www.ico.org.uk