How we use non-borrowers' data

in relation to Pepper Money mortgage products.

We ask that you read this Fair Processing Notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

1 Meaning of words used

In this Fair Processing Notice:

  • you and your means each person whose personal data has been provided to us by (or on behalf of) a borrower or by a third party in connection with a mortgage product for the purpose of verifying certain information provided by that borrower as is required by an application process made by that borrower.
  • borrower means a person that is a borrower (or has made an application to become a borrower) in respect of, or has granted security (including a guarantee) for, the mortgage advance that is the subject of the mortgage product, or, if the mortgage product is in the name of a limited company borrower, any officer or shareholder of that limited company borrower or any person who has granted security (including a guarantee) in respect of that mortgage product (and in the case of a limited company which has granted security, any officer or shareholder of that limited company);
  • we, us and our means Pepper Money Limited (registered in England and Wales as company number 11279253), trading as Pepper Money, and anyone who at any time in the future is entitled (as legal, equitable or beneficial owner) to all or any of the lender's rights under any agreement with the borrower;
  • mortgage product means the mortgage product with us in respect of a residential property that is occupied by the borrower as their home or, if the mortgage product is for a buy-to-let mortgage, which is used solely for rental purposes; and
  • information means the information relating to you which is provided to or received by us (whether or not by or from you or the borrower or on behalf of the borrower) in or in connection with the mortgage product (including enquiries or searches made by or on behalf of us).

 

2 Use of your information

DISCLOSURE - APPLICABLE DATA PROTECTION LAWS
IMPORTANT - USE OF YOUR INFORMATION

You have a right to know how we use your personal information. Please carefully read and understand this section 2.

If you would like to read the full details of how your data may be used by us, and/or to learn more about your data protection rights, please contact our Data Protection Officer at the contact details stated below:

Data Protection Officer:

Michaela Chiocca
Harman House
1 George Street
Uxbridge
London
UB8 1QQ

PM_DPO@pepper.money

 

2.1 We may hold information in our records or with persons providing storage facilities and use and disclose information:

  • to perform obligations or exercise rights that we may have under any agreement with the borrower;
  • for the purposes of market research, statistical and business analysis and creating and maintaining a customer profile;
  • to analyse and improve the content and functionality of our website (such as to determine pages of our website visited by users);
  • to assess the mortgage product and further applications from the borrower for this and other products and/or services, and make decisions on questions about any such application(s), any agreement or correspondence which the borrower may have with us;
  • when responding to proceedings of a court of law or similar legal process, or in cooperating with law enforcement agencies; and/or
  • with the intention of preventing, detecting, prosecuting or mitigating the consequences of fraud and money laundering or other crimes, trace debt and recover debt and to comply with applicable law and regulations.

2.2 We may disclose any information to and make enquiries to:

  • insurers of any asset securing or proposed to secure the borrower’s liabilities;
  • market research organisations for the purpose of confidential market research conducted on behalf of us; and/or
  • any relevant legal and regulatory authorities, or government bodies, and any other body having a legal right to access the information and anyone you authorise us to give information to.

2.3 A condensed guide to the use of your personal information by ourselves

(a) When the borrower obtains a mortgage product from us and provides us with information, or you (or a third party) provide us with information on request by or on behalf of the borrower, we will check our own records about you (to the extent we hold any such records).

(b) Your data may also be used for other purposes for which you give your explicit consent or, in very limited circumstances, when required by law or where permitted under applicable data protection laws.

In order to process and use your personal information, we reply on one or more of the following legal bases;

Legal Bases

(i) processing is necessary for compliance with a legal obligation to which we are subject; and/or

(ii) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party

Transfer of your information out of the EEA

We may transfer information for the use in the ways described in this Fair Processing Notice to countries outside the European Economic Area (EEA) which may or may not have the same level of legal protection as the countries within it. Any transfer of your personal data will be subject to the EU Model Clauses as permitted under applicable data protection laws that are designed to safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you would like to find out more about any such transfers, please contact our Data Protection Officer whose details are set out in section 2 of this Fair Processing Notice.

Your Rights

Under applicable data protection law, you have a number of important rights free of charge. In summary, those include rights to:

  • access to the personal information we hold about you;
  • require us to correct any mistakes in your personal information which we hold;
  • require the erasure of personal information concerning you in certain situations;
  • receive the personal information concerning you which you have provided to us (or which has been provided to us by or on behalf of the borrower), in a structured, commonly used and machine-readable format and require us to transmit those data to a third party in certain situations;
  • object in certain other situations to our continued processing of your personal information; and/or
  • otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of these rights, please email or write to our Data Protection Officer (see details in section 2).

 

3 How long your personal information will be kept

3.1 Where the borrower has a mortgage product, at the end of the borrower’s relationship with us, we retain your personal information for the period for which we are required to retain this personal information in order to meet our regulatory requirements. Where retention is based on other reasons, we will retain it for no more than 7 years.

 

4 Updates or changes to your personal information

4.1 Please let us know as soon as possible if any of your information changes or if you believe that any information held by us may be incorrect or out of date. You can do this by contacting our Data Protection Officer (see details in section 2 above).

 

5 English language

We will only communicate with you, provide information to you and enter into agreements with you in English.

 

6 Applicable law

This Fair Processing Notice and our dealings with you within the context of the mortgage product / loan applied for by the borrower and other related agreements, and any non-contractual aspects arising in connection with this Fair Processing Notice or those dealings, are governed by English law subject to the exclusive jurisdiction of the English courts.

 

7 Complaints

If you have a complaint about any aspect of our Fair Processing Notice or conduct then we urge you to contact us. You can contact us by phone, in person or in writing either by post or email. Details of our complaint handling procedures can be obtained from Pepper Money at Harman House, 1 George Street, Uxbridge, London UB8 1QQ or by telephone on 03333 701 101. You can find details of our complaints process by going to https://www.pepper.money/complaints. In some cases, you may also refer your complaint to the Financial Ombudsman Service.

Details are available on our website, or the Financial Ombudsman site which is http://www.financial-ombudsman.org.uk/.

If you have a complaint about how we process your personal information, you can contact our Data Protection Officer (see details in section 2). We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

If you believe our processing of your personal information does not comply with applicable data protection law, you can make a complaint to the UK Information Commissioner’s Office who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Pepper Money is the trading name of Pepper Money Limited which is a private limited company registered in England and Wales under Company Number 11279253 with its registered office at Harman House, 1 George Street, Uxbridge, London UB8 1QQ. Pepper Money is authorised and regulated by the Financial Conduct Authority under Firm Registration Number 811609.

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