How we use your personal information
Your information will be held by Mind Money Limited. This privacy notice is to let you know how we promise to look after your personal information.
Mind Money Limited is registered in England and Wales under company number 16571028.
Our Information Commissioners Office registration number is ZC253834 which can be viewed on the register at www.ico.org.uk/register or by contacting the ICO.
You can contact us by writing to:
Mind Money Limited, 167-169 Great Portland Street, London, England, W1W 5PF or emailing us at info@mindmoney.co.uk
This privacy notice applies to all individuals or users (“data subjects”) whose Personal Data is processed by Mind Money Limited (“us”, “we”, “our”).
Why should you read this document?
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.
This may also refer to similar information about any related third parties, such as family members, who are not a client of Pure Wealth Management.
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 Investment/Mortgage/Finance and/or Insurance requirements 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 Investment, Mortgage, Finance and/or Insurance products and the terms and conditions relating to these.
The basis upon which our Firm will deal with Your Personal Data
Data Protection law says that we are allowed to use your Personal Data only if we have a proper reason to do so. This includes sharing it outside our Group. The law says we must have one or more of these reasons:
To fulfil a contract we have with you, or
When it is our legal duty, or
When it is in our legitimate interest, or
When you consent to it.
When we speak with you about your Investment, Mortgage, Finance and/or 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 discussion 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.
A legitimate interest is when we have a business or commercial reason to use your Personal Data. But even then, it must not unfairly go against what is right and best for you. We may use your Personal Data for our legitimate interest in order to:
manage our relationship with you or your business;
keep our records up to date, working out which of our products and services may interest you and telling you about them;
develop and carry out our marketing strategy;
develop new ways to meet our customers’ needs and to grow our business;
develop services and defining what we charge for them;
manage risk for us and our clients;
support, develop and manage our staff members;
develop and improve how we deal with financial crime, as well as doing our legal duties in this respect; and
be efficient about how we fulfil our legal and contractual duties.
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/Ethical Investments, 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 Category Data).
We will record and use Your Special Category Data in order to make enquiries of Insurance/Investment providers in relation to insurance product that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.
We will need what is called explicit consent to process this type of personal 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 to insurance related activities such as underwriting, claims and fraud management.
We will use Special Category 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.
Children’s data
Where the firm processes personal data relating to children, the firm must apply particular care and ensure the processing is fair, transparent and limited to what is necessary.
Where consent is required for processing relating to a child under 16, consent must be obtained and recorded from the holder of parental responsibility.
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 to establish your circumstances and needs and preferences in relation to Mortgage, Finance, Investment and/or Insurance. 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 voters roll. If we use technology solutions 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.
How we check your identity/ Fraud Prevention Agencies (FPAs)
We may ask you to provide physical forms of identity verification when you make an application through us. Alternatively, we may share your personal information with credit reference and fraud prevention agencies, as needed to help detect fraud and money laundering risks.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.
With regards to electronic ID checks, we may supply some of your personal information to Equifax Limited and SmartCredit Limited (SmartSearch), who provide services such as credit risk and affordability checking, fraud prevention, anti-money laundering, identity verification and tracing.
Equifax and SmartSearch will use your personal information to provide services to us. We use their services in order to help prevent fraud and money laundering. More information about Equifax and SmartSearch and the ways in which they use and share personal information can be found in their privacy notices at https://www.equifax.co.uk/privacy-hub/privacy-notice and https://www.smartsearch.com/privacy-policy
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.
We will use the information to:
Confirm identities.
Help prevent fraud and money-laundering.
Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime. FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
Telephone calls
Calls may be monitored, recorded and transcribed (including through the use of automated or AI enabled tools) for training, compliance, quality assurance and evidential purposes.
Where we use automated or AI enabled tools to record, transcribe, summarise or review calls, meeting notes or correspondence, we use these tools to support administration, training, compliance monitoring, quality assurance and evidential review.
We do not use call transcripts alone to make solely automated decisions with legal or similarly significant effects about you unless this is explained to you and appropriate safeguards are in place.
Transcripts are subject to the same retention, access controls and security measures as call recordings.
Automated decision making and profiling
Data Protection law has provisions on:
Automated decision-making (making a decision solely by automated means without any human intervention.
Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
Where we use automated processing, including profiling, to make a decision that produces legal or similarly significant effects for an individual, we will ensure that an appropriate lawful basis is identified and recorded before processing begins.
We will provide meaningful information about the use of automated decision making, including the purpose of the processing and the safeguards available to the individual.
Where applicable, individuals will be able to obtain human intervention, make representations and contest the decision.
Solely automated decision making involving special category data will not be used unless a valid condition for processing that data applies and appropriate safeguards are in place.
Any new or materially changed automated decision making, AI enabled processing, profiling, transcription, analysis or monitoring activity will be reviewed and reflected in this privacy notice before use.
What happens to Your Personal Data when it is disclosed to you?
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 system (websites, email, hard drives, and cloud facilities). This information 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 and/or Insurance Product Providers, both in paper form and online 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, Finance, Investment and/or Insurance Policy 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.
Joint Applicants
If you give Personal Data about someone else (such as a joint applicant) then you should not do so without their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice.
Sometimes, when you make a joint application, your personal data may be shared with the other applicant. For example, details of the application will be shared with your joint applicant and vice versa.
Electronic Marketing
We, or companies within our Group (including Pure Structured Finance Limited , Pure Buy to Let Limited, Pure Wealth Management Limited, Browne & Brown IFA Ltd and Pure Structured Finance Limited) would like to keep you updated about relevant products and services through a variety of electronic means, including potentially by telephone, email, SMS and instant messaging services (such as WhatsApp). If you do not want to receive such messages, you can ask us to stop sending these at any time by clicking on the ‘unsubscribe’ button in our emails or by replying to our emails with the word “unsubscribe” as the subject.
Cookies and similar technology
Where websites use cookies or similar technologies, the relevant cookie notice or website privacy wording must explain the categories of cookies used, the purpose of each category, whether consent is required and how users can manage their choices.
Where the firm relies on a consent exemption for cookies or similar technologies, such as where permitted for statistical purposes or to improve website functionality, this is documented and kept under review.
If you choose not to give us your Personal Data
We may need to collect Personal Data by law, or under the terms of a contract we have with you.
If you choose not to give us this Personal Data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide our Services to you in an efficient manner. It could mean that we cancel a service you have with us.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
Mortgage Lenders/Finance Lenders/Investment Providers 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, Providers of legal services such as Estate Planners, conveyancing, surveyors and valuers (in each case where we believed this to be required due to your particular circumstances).
Comparison service providers, product providers and other third-party partners where this is necessary to obtain quotations, compare products, progress an application or switch, or otherwise provide a service you have requested. Depending on the product or service, these may include providers of insurance, energy, broadband, mobile and other household financial products. Where appropriate, we will tell you which provider or comparison partner will receive your information before it is shared.
HM Revenue & Customs, regulators and other authorities
UK Financial Services Compensation Scheme
Credit reference agencies
Fraud prevention agencies
Organisations that introduce you to us, or Companies that we introduce you to
Companies you ask us to share your data with.
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, Investment and/or Insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your Mortgage, Finance, Investment and/or 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.
Sharing your Personal Data outside of the EEA
In order to provide our Services, it may be necessary for us to transfer or store your Personal Data outside of the EEA. If we do transfer your Personal Data outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
Where it is necessary to transfer or store your personal information outside the UK or EEA, we will ensure that an appropriate transfer safeguard is in place, such as adequate regulation or another recognised transfer mechanism, unless an exception applies. We will provide further information about the relevant safeguard where required.
You can find out more about data protection on the Information Commissioner’s Office website.
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 it being accessed unlawfully or maliciously by a third party.
Your Personal Data will be retained either electronically or in paper form for a minimum period of six years following the advice or service you receive from us, and for longer where this is necessary to meet legal, regulatory, contractual, evidential or legitimate business requirements.
Where records are no longer required, they will be securely deleted or destroyed in line with our retention and secure disposal procedures.
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).
Object to Your Personal Data being used to make a decision solely by automated means without any human involvement
Object to the automated processing of Your Personal Data to evaluate certain things about you (profiling)
How to make contact with our Firm in relation to the use of Your Personal Data
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested; we will inform you of this at the time.
You should also make contact with 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 your complaint relates to how we use your personal information, please contact us first using the contact details provided in this notice. We will acknowledge your data protection complaint within 30 calendar days, investigate it without undue delay and provide you with the outcome once our review is complete.
If you remain dissatisfied after receiving our response, you may complain to the Information Commissioner’s Office. The ICO can be contacted through its website or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF