Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We process your personal information for the primary purpose of providing our services, as a [commercial and residential (including first and second charge)] mortgage provider, to you.
The information that we generally process in connection with these services includes:
Identity Data
• Your full name and title;
• Your home address, correspondence address (where different from your home address), email address, home and mobile telephone numbers.
• Your address history;
• Your date of birth and/or age;
• Identification documents including document type, date of expiry and country of issue;
• A short video of yourself when you set up an account with us via a Secure Communications Network (for more information, please see the end of this section);
• Your e-signature;
• Your nationality, if this is necessary for us to comply with our legal and regulatory requirements;
• Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;
Financial Data
• Details of shareholdings, prominent functions, directorships and/or employment including for instance your occupation, salary, employer and length of service;
• Where relevant, information about any co-director or guarantor which you provide in any application
• Information about your employment status including whether you are employed, retired or receive benefits;
• Performance of your mortgage;
• Where relevant, in relation to adverse credit, information about creditors and supporting references;
• Bank account and payment card details.
Residency Data;
• Information about your occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property in which you live at the time of your application;
• Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK;
• For residential customers, your marital status, family, lifestyle or social circumstances if relevant to the mortgage product (e.g. the number of dependents you have or if you are a widow or widower);
Credit Reference Agency Data
• Personal information which we obtain from Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (see the section on ‘Fraud Prevention Agencies’ below);
• Some special categories of personal data such as about your health or if you are a vulnerable customer (more details below).
Technical and Profile Data
• Details of your services with us including for instance application information, (including on-line applications) affordability assessments, (including on-line calculators, tools and guides) credit history, customer ID number, account number, account balance, account history, security or collateral held by us, and details relating to any other signatories and/or guarantors;
• Security identifiers including for instance mother’s maiden name;
• Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Information about how you use our website, products and services.
• Details about payments to and from you and other details of products and services you have purchased from us.
Marketing and Communications Data
• Information you have provided in receiving marketing from us and/or companies within the Pepper Group and your communication preferences.
Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Using our video facing services
You can apply for some of our products and services using a video session from your mobile device to verify your identity and contact details.
If you use our video facing service both the images and the audio will be recorded and may be used for training and monitoring services. We’ll use any personal data captured about you for the performance of a contract or/with a view to entering into a contract with us as well as for our legitimate interests for good governance, accounting, managing and auditing our business operations, and to monitor emails, calls other communications in relation to dealings with us.
For your own privacy and protection please ensure that your location doesn’t include items and images that you don’t wish to be recorded.
If you fail to provide personal data
We are unable to provide you with products and services or to process your application without having personal information about you. Your personal information is required before you can enter into the relevant contract with us, and/or it is required during the life of that contract, and/or or it is required by laws that apply to us. If we already hold some of the personal information that we need – for instance if you are already a customer – we may not need to collect it again when you make your application.
In cases where providing some personal information is optional, we will make this clear in any discussions regarding the provision of that information. For instance, we will say in application forms, or via the broker or other intermediary, if the alternative (such as work) telephone number can be left blank.
Commercial applicants, joint applicants, guarantors and powers of attorney
If you make a joint application with your spouse, partner or family member, or an application on behalf of a company we will also collect the personal information mentioned above about that person, or where relevant, co-director. You must show this privacy policy to the other applicant and ensure they confirm that they know you will share it with us for the purposes described in it. If you look at section 5 (“How we use your personal data”) below, you will see reference to consent and a description of some limited scenarios where it may be relevant to what we do with personal information. If we ask you to obtain consent from the joint applicant (such as for marketing) you should do that using the consent capture mechanism that we give or make available to you for that purpose.
If you apply for your mortgage with a guarantor, that person will see a condensed version of this privacy policy when he/she submits his or her own personal information to us because he/she must necessarily sign the application form. They will also be able to access the privacy policy via our website.
If there is somebody who has power of attorney over your affairs, then we will notify that person of this privacy policy when we make contact with him/her directly.