Our privacy policy

The purpose of this Notice

When we provide our services to you, we will collect personal information about you and others and we want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.

The data controller of your personal information is Simply Investment Limited. Registered Office: 7a Radford Crescent, Billericay, England, CM12 0DU. Registered Company Number: 06528590 Registered in England & Wales (“we”, or “us”, or “our”).

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the ‘How to contact us’ section.

What type of personal information will be processed and why?

We may ask you to provide personal information by filling in forms and documents or by corresponding with us by phone, e-mail, letter or otherwise or during the course of our meetings with you. The legal basis for processing your personal information is to provide our services to you.

Depending upon the types of products and services you require, we may also need to collect information from and about you which the law considers to be sensitive, such as data about your physical or mental health, which we refer to as “special category personal data”. The special category personal data that we may ask you to provide, and the reasons why we ask you to provide it, are as follows:

We will only process the special category personal data listed above with your explicit consent. You may choose not to provide us with this consent. However, please note that if you do not provide us with your consent to collect and process the information listed in the table above:

• we may not be able to advise you fully in respect of certain products and services which require this information (in particular those relating to health or life insurance).;
• your application may be rejected by the providers of products and services which require this information; or
• the quotes for such products and services may be higher than would be the case if this information were provided.

In some circumstances, we may receive information about you from third parties. In particular, we will receive information about you from Credit Reference Agencies and Fraud Prevention Agencies. This may include details of the products and services you have applied for, those lenders, finance and credit organisations with whom you have (and have had) an agreement with, the amounts advanced, the amount and frequency of repayments and whether you have made your repayments on time and in full. This will help us make the best possible assessment of your financial situation before we decide whether we can provide you with our services and/or recommend any specific products and services. It is in our legitimate interests to process your personal information for this purpose. We may also ask you to provide Letters of Authority to allow us to receive information about you from providers.

When we record communications

We, and persons acting on our behalf, may record and/or monitor communications including telephone conversations over landlines and mobile phones, emails, instant messaging, chat rooms, fax and other electronic communications between our staff and you.

Who might my personal information be shared with?

We may disclose your personal information to the following categories of recipients:

• to providers of financial services, insurance and investment products and services in respect of whom you request us to submit applications on your behalf and to receive updates from such providers in order for us to provide our services to you throughout the lifetime of our relationship with you;
• to our suppliers and partners in order for them to help us provide our services to you, this   includes:

-Within Simply Investment Limited and its affiliated firms. These firms include: Mortgage Thoughts Limited T/A Mortgages by Simply, Simply Lending Solutions, Simply Specialist Lending, Simply Lending Solutions Great Baddow and Insurance by Simply and others.

• our IT systems providers to assist us with providing you with an efficient, modern and professional service;
• our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
• our accountants, solicitors, insurer(s) and insurance broker(s) and any other provider of professional services to us;
• to Credit Reference Agencies in order to find the most suitable product for you we may use the information held at credit reference agencies (CRAs). A CRA is a company that collects personal information from various sources and provides that personal information for variety of uses (including to prospective lenders for the purposes of making credit decisions).

We will search a CRA who will provide us with information about you to assess creditworthiness and product suitability and check your identity. They will provide us with the publicly held data, including the electoral roll and shared credit performance data. If you have a financial associate their data may also be provided.

We will use the information provided to us by a CRA to help decide which products may be best for you.

When the CRA receives a search from us they will place a quotation search footprint on your credit report, whether or not you decide to apply for the product. This search will not affect your ability to gain credit.

The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.

More information about each CRA and what it does with personal data is available at the following locations:

Experian: www.experian.co.uk/crain Call Credit: www.callcredit.co.uk/crain Equifax: www.equifax.co.uk/crain

You can contact any of the CRAs if you wish to obtain a copy of your credit report:

Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk

CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414 Equifax PLC, Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US or call 0844 335 0550 or log on to www.myequifax.co.uk

• to other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
• to Lending Score to check your preapplication mortgage http://www.lendingscore.co.uk/
• to a prospective buyer (and its agents and advisers) in the event we intend to sell any part of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your personal information could form part of one of the assets we sell, provided that we inform the buyer it must use your personal information only for the purposes described in this Notice. We will never rent or sell your personal information other than as part of a sale of our business;
• to any national and/or international regulatory, enforcement body, government agency or court where we are obliged to comply with legal obligations
• as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC)
• to exercise, establish or defend our legal rights, or
• to protect your vital interests or those of any other person; and
• to reviews.co.uk for customer reviews (https://www.reviews.co.uk/front/user-privacy-policy)
• to CasePRO to provide a customer management tool (https://casepro.co.uk/privacy-policy/)
• to Horizon for our phone system
• Amazon to help power provide a cloud platform (https://aws.amazon.com/privacy/)
• to Eversign for our secure document signing (https://eversign.com/legal/privacy)
• to Mortgagebrain to source mortgage products (https://www.mortgagebrain.co.uk/privacy-policy)
• to any other person with your consent to the disclosure or where we are required to do so by law

Open Banking – Consents Online an Equifax company

When you apply for a mortgage, we will use Open Banking technology to help verify your income and outgoings, to assess your eligibility for certain mortgage products and to detect fraud.

We use a tool provided by Consents Online Limited. This allows you to share your bank account and transaction history with us.

To use this service, you will be asked to agree to Consents.Online’s Terms of Service for Open Banking connections, and you will be redirected to your bank by Consents.Online in order to authenticate yourself. Their Terms of Service will set out the terms on which you agree to them accessing information.

Once this verification is complete, your bank/building society will provide Consents.Online with 24 months’ history of your banking transactions. This information will be shared with us and Lending Score (acting as a data processor) and may be updated on a daily basis to ensure we have the most up-to-date information.

Consents.Online Ltd is registered and authorised by the Financial Conduct Authority under Firm Reference Number FRN 792642. You can read their privacy policy here https://consents.online/Privacy

Open Banking Data Processor

We may share your personal data with entities that provide services to us, such as vendors and suppliers that provide technology, services, and/or content for the operation and maintenance. Access to your personal data by these service providers is limited to the information reasonably necessary for them to perform their limited function. We take steps to help ensure that they keep your personal data confidential and comply with our privacy and security requirement. A key provider is Lending Score Limited incorporated in England and Wales, with company number: 11633476 and its registered address at 14 Park Square East, Leeds, LS1 2LF. Lending Score will access your Transaction Data on our behalf for the purposes such as summarising and categorising your Transaction Data, producing pdf statements, and determining your affordability.

International Data Transfers

As a UK based company, all of the personal information we process is protected by European data protection standards. And, if we ever have to send data overseas, we take care that it’s covered by the same high standards.

Certain of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We’ll only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Your data protection rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
• In addition, you can object to processing of your personal information, ask us to

restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at http://ec.europa.eu/justice/data-protection/article- 29/structure/data-protection-authorities/index_en.htm.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please contact the Data Protection Officer on 01245 209853 or by writing to us at Barn 12 Runwell Hall Farm, Hoe Lane, Rettendon, CM3 8DQ. Alternatively, you can email us at [email protected]

Data retention

We retain personal information we collect from you where we have an ongoing legitimate need to do so, for example:

• to provide you with a product or service you have requested us to provide,
• to perform our contractual obligations to you;
• to comply with applicable legal, tax or accounting requirements;
• to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims. This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or ombudsman.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Updates to this Notice

We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

How to contact us

If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please contact the Data Protection Officer on 01245 209853 or by writing to us at Barn 12, Runwell Hall Farm, Hoe Lane, Rettendon, CM3 8D.