At Loans Arena we respect your privacy and the confidentiality of your personal information.
Who are we?
Loans Arena is an appointed representative of PRIMIS Mortgage Network who is a trading style of Personal Touch Financial Services Limited which is authorised and regulated by the Financial Conduct Authority.
This Privacy Notice explains:
- Who we are
- What personal information we collect
- How we use your personal information
- Who we share your information with and why?
- How we keep your information secure
- Your rights
- How to contact us
Who we are?
Loans Arena provide financial planning solutions and advice through experienced and qualified advisers based in the UK.
Currently, Loans Arena and PRIMIS Mortgage Network jointly determine the purposes and means of processing personal client data relating to giving advice. This means we are joint data controllers for this core, advice giving, activities and therefore responsible for managing this client data and ensuring compliance.
However, Loans Arena is solely responsible for some activities, for example any direct marketing that we undertake.
What personal information we collect
Personal information includes your name, address, or phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial advisor, visit a website we may have or register to receive one of our newsletters (if applicable).
The type of personal information we collect will depend on the purpose for which it is collected and includes:
Information to verify your identity
Family, lifestyle, health, and financial information
We collect personal information directly from you. For example, we ask for personal information at the start of our relationship and in subsequent communications, in order to check your identity and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.
Special Category Information
In some instances, it is necessary to collect more sensitive information (such as health or lifestyle information) which is called special category data. This is to allow us to provide our financial advice service to you. We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely. You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.
We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements. Personal information will be securely disposed of when it is no longer required, in accordance with our Data Retention and Disposal Schedule. A copy of this is available using the contact details below.
On what basis do we collect data?
The processing of your personal data is allowed under a number of lawful bases. The data required for the provision of products and services is processed on the basis there is a contract with you to do so. Any relevant marketing activity we undertake is done because, as a firm, we have a legitimate interest to do so. However, you have rights, as listed below, which impact how we can use and process your data.
How we use your personal information
During the course of your dealings with Loans Arena you will be asked to provide detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your ethnic origin, your health and family health history.
Your Information means any information describing or relating to you. Your Information may identify you directly, for example your name, address, date of 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 Loans Arena providing you with assistance in relation to your mortgage; insurance; pension; investment and wealth management 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 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; insurance; pension; investment and wealth management products and the terms and conditions relating to these.
Where you ask Loans Arena to assist you with your insurance or pension needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, Loans Arena will ask you information about your ethnic origin, your health and medical history (Your Special Data).
If you have parental responsibility for children under the age of 16 it is also very likely that Loans Arena (and consequently Primis Mortgage Network) 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 Loans Arena of information relating to historic or current criminal convictions or offences. This is relevant to insurance related activities such as underwriting, claims and fraud management.
Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as set out in this Privacy Notice.
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 Data and Criminal Disclosures.
In the course of handling Your Information and Your Special Data/Criminal Disclosures our Network will:
- record and store Your Information and Your Special Data/Criminal Disclosures on Network systems run on secure servers. Your Information and Your Special Data/Criminal Disclosures 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, Your Information and Your Special Data/Criminal Disclosures 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
- need to access and process Your Information and Your Special Data/Criminal Disclosures 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.
Your Information and Your Special Data/Criminal Disclosures will be retained by our Network 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.
Who we share your information with and why?
From time to time Your Information, Your Special Data and/or Criminal Disclosures will be shared with or transferred to:
- Loans Arena
- Mortgage lenders and product providers.
- Contractors or suppliers who we may engage to assist us with any customer feedback exercises.
- Our professional indemnity insurers, brokers, claims handlers and legal advisers and another person who may provide professional services in connection with the handling of a complaint, litigation, or investigation.
- Any person we may engage in connection with any investigation to detect, prevent or investigate financial crime, including those that may be carried out by or in conjunction with mortgage lenders, product providers and regulators.
- LSL Property Services plc, the ultimate parent company of the Network, and any associated company who may provide services to the Network from time to time.
In each case for the purposes set out in this Privacy Notice, i.e. to enable us to comply with our legal obligations to you, to further our legitimate interests, where there is a substantial public interest and to detect or prevent financial crime.
These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.
How we keep your information secure
We’re committed to ensuring the confidentiality of the personal information that we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.
If we work with third parties in countries outside the EU, we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.
In limited circumstances, data may be accessed outside of the EEA i.e. by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.
Loans Arena tries to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below. This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have the right to opt out of receiving marketing information and tell us what your communication preferences are by contacting PRIMIS Mortgage Network using the details provided at the end of this notice or by using the opt out option below or on any email marketing. You may opt out at any time if you do not want to receive any further communications of this nature.
Individual Data Rights and Requests
The right to be informed – You can request that we provide ‘fair processing information’, typically through this privacy notice.
The right of access – You may request a copy of the personal information we hold about you, using the contact details found on the end of this privacy notice.
The right to rectification – The accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information.
The right to erasure – You may request the deletion or removal of personal data where there is no compelling reason for its continued processing.
The right to object – You may object to the processing of your data based on legitimate interests.
The right to restrict processing – You have a right to request we ‘block’ or suppress processing of your personal data.
The right to data portability – You may request to obtain and reuse your data; and
The right not to be subject to automated decision-making including profiling.
If you wish to correct, restrict, delete, or make changes to your personal information, or any of the data subject rights listed above, please contact us at the number/address listed below.
How to contact us
If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences, or correct your personal information, please contact us using the following details.
Primis will liaise with Loans Arena Ltd on your behalf to affect your requests.
Data Protection Officer: Raj Lyall
Address: PRIMIS Mortgage Network, No 2 Methuen Park, Chippenham, Wiltshire, SN14 0GB.
How to complain
If you wish to raise a complaint about how we have handled your personal data, you can contact the Office of Data Protection who will investigate the matter.
If you are not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can complain to our regulator:
Information Governance Department
Information Commissioner’s Office
0303 123 1113