Noya Wealth Consulting Ltd (we/us) is registered with the Information Commissioners Office (ICO) for data protection purposes under reference ZA509248.
We are committed to ensuring that your privacy is protected, you can be assured that it will only be used in accordance with this privacy notice. Where you are arranging a product such as an insurance policy on behalf of any other party you must have received their consent to provide their personal data to us and you must show this notice to them. This privacy notice should be read in conjunction with our Financial Services Disclosure.
For the purposes of this notice references to ‘personal data’ or ‘data’ may include both personal data, such as your name, address, date of birth, financial details, employment information, insurance claims history and special categories of data such as information about any unspent criminal convictions or your medical history.
We may obtain your personal data from a variety of sources, usually directly from you, however a third party you have asked to act on your behalf such as a spouse/partner may sometimes provide information where permitted on your behalf. We may also receive data from other sources such as professional advisers (accountants/solicitors) or mortgage or finance lenders or insurers, however, in these cases you will normally be required to give your prior consent to the data being released. We may also receive data from marketing firms where you have given your consent to them passing this to us. Information about you may also be obtained from other relevant sources such as credit reference agencies including Experian, Equifax or Call Credit and in some cases, we may receive data from crime prevention and anti-fraud agencies either directly or through the product providers.
We will use your data for advising on and/or arranging home finance products including residential, commercial and buy to let and secured lending such as second charge mortgages and bridging loans (all referred to hereafter as ‘mortgage/s’ for simplicity) and/or insurance products. This may involve providing quotes/illustrations, managing and administering your mortgage or insurance policies, assisting you with any claims, responding to product enquiries, handling complaints or managing outstanding balances.
We may ask you to participate in surveys or feedback that assists us in developing and improving the service we offer. We may use your personal data to keep you informed about other products and services that we have available. Where we have your consent to do so, we may share your data with other carefully selected financial services companies to allow them to contact you about products and services that may be of interest to you. You can withdraw such consent at any time by contacting us using the information in the contact details section or using the ‘unsubscribe’ option in any marketing sent to you.
In order to prevent and detect fraud and other crimes, and to aid in the prosecution of offenders, we may use your personal data to –
Your personal data may also be used to allow us to fulfil our legal or regulatory responsibilities. This may involve sharing your personal data with authorities such as the Financial Conduct Authority (FCA), HM Revenue and Customs (HMRC), The Information Commissioner’s Office (ICO), police and governmental agencies if requested and required to do so.
If you are unable or unwilling to allow us to use your data in line with this privacy notice, we will be unable to enter into a contractual relationship with you.
We take the security of your personal data very seriously and have a ‘data protection by design’ philosophy for the protection of your privacy. In order to provide our range of products and services to you it is necessary to share your personal data with third parties. We always ensure that the required safeguards are in place before sharing your data outside of our firm. On occasion, it may be necessary to transfer or store all or some of your data outside of the EU, for example if we utilise ‘cloud’ storage systems. We will only do so where we have contractual security that the data will be afforded the same protections as within the EU and the country in which the processor is domiciled affords you these levels of data protection.
The following outlines who we may share your data with and the circumstances in which we would do this:
We can only process your personal data if we have a legal basis for doing so. It is your right as the subject of this data to be informed what the legal basis is for each type of processing that we undertake.
We will process your data using this basis for the purposes of providing a mortgage/ insurance quotation, advising and arranging your mortgage/insurance products(s), assisting in the administration your insurance policy(ies), assisting with any claims, responding to complaints and mortgage/policy enquiries, providing medical concierge service. Some personal data types that we need to process are classed as special categories of data as noted above, for example medical conditions, or criminal records data – information relating to unspent criminal or motoring convictions. These categories of data will be processed in accordance with the law on the legal basis that it is necessary for the performance of a contract with you AND such processing is necessary for reasons of substantial public interest.
We may also use your personal data for marketing purposes i.e. offering related products to you where we have a legitimate interest in doing so. We will normally seek your consent to marketing as an additional legal basis, but if we do not hold this we may still send you marketing material using legitimate interest alone. You have the right to request that we do not contact you for marketing purposes at any time by contacting us – see the ‘Contact Us’ section below. If you withdraw consent then your interests will override ours and we will be unable to use this legal basis to further process your data, however we may be able to rely on another lawful basis such as contractual performance.
We may use your personal data for the purposes of debt recovery using this basis.
We will only use this as a secondary lawful basis for marketing purposes, as noted above.
If you decide to take a mortgage or policy with us, we will retain your personal data for seven years from when the product is due to end. Most of the agreements that we hold with insurers or lenders require data to be retained for this long.
If your insurance is an employer’s liability policy, we will retain the details of this policy for at least 60 years. This is ensure that the details are available to you should an employee lodge a claim against you far into the future, such as may be the case for an industrial disease where symptoms may not present themselves for many decades.
In any other situations we will retain your personal data for no more than three years from when the requested service is completed or stopped.
Under data protection legislation you have certain rights in relation to the data we hold about you. We have processes in place that ensure your rights are upheld and that any requests you make in relation to these rights are responded to within the timescales required by law.
You have the right as a data subject to be informed in a clear and precise manner about the data we hold about you. Within this privacy notice we detail the nature of this data we hold, the reasons we hold it, how this data is used, who we will share this data with, how long we will retain your data and the rights you have in relation to your data. If you require any further information, you can get in touch using the details in the ‘Contact Us’ section.
In order to check the legitimacy of the personal data we hold on you, its accuracy and the lawfulness of the processing we undertake, you have the right to request a copy of data we hold about you. You can request this information free of charge using the details below in the ‘Contact Us’ section. We will normally provide the personal data we hold about you within 30 days of you making this request.
You have the right to ensure that all data we hold on you is both accurate and complete. If you are concerned that the data we hold about you is inaccurate or incomplete when considering the purposes for which your data is being used, you can ask us to rectify this. To do so, you should contact us using the details below.
You have the right to request that all of the data we hold on you be erased from our systems. We may only be able to comply with this request in specific circumstances. This request would also apply to any third party whom we had shared your data with, and we would notify them accordingly if your request was valid. We will not be able to erase your data in all circumstances. For example, we would not be able to erase data that is being processed for the purposes of administering a live or lapsed insurance policy unless policy has been lapsed for seven years or more. This is because we have a legal obligation to retain this data for the defence of legal claims should a third party make an insurance claim against you. If you require any further information, or you wish to exercise your right of erasure, you should contact us using the details below.
You have the right to restrict our processing of your data in the following circumstances:
If you wish to exercise your right to restrict processing, you should contact us using the details below.
Where we are processing data under the basis of contractual performance you have the right to request that we provide your data in a machine-readable format that you can then share with other businesses or in any other way you see fit. You have the right to request that we transfer your data to third parties directly for them to use as you see fit. We are able to provide your data either as an .XML file or a .CSV file. You are able to utilise your data in this way by contacting us using the details below.
You have the right to object to your data being used for direct marketing purposes or profiling of your data for the purpose of direct marketing. We do not undertake profiling activity and if we hold your consent for marketing this right would not be available (however, you may withdraw your consent). If you have any concerns surrounding this, please contact us using the details below.
You have the right to object to any automated decision making where there is no human intervention involved where this results in a legal implication to you. This right would not apply to underwriting decisions or to applications for credit made on our website or internal system as this automated decision making is required for entering into a contract with us. Currently, we do not use automated decision making for any other functions, but if you have concerns regarding this, please contact us using the details below.
You have the right to complain about the use of your personal data – in the first instance please get in touch using the details in the ‘Contact Us’ section. Our complaint handling procedure is available upon request or can be accessed from our website(s).
You are also entitled to complain to the Information Commissioner by writing to –
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
You can access their website at https://ico.org.uk/make-a-complaint/.
We will always endeavour to ensure that your personal data is accurate and up to date. If you notice that any information on your mortgage/policy documentation is incorrect or if any of your personal data changes, for example you change your contact details, occupation or your bank please let us know and we will inform you if it will be necessary to pass this information on to the lender/insurer.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure we have put in place a range of physical, electronic, contractual and control procedures to safeguard and secure the data we process.
By entering your details on any of our website(s), you agree that we may contact you to discuss a mortgage, finance or insurance product, or other service we provide, regardless of whether you choose to proceed with it.
A cookie consists of information sent by a web server to a web browser and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. We use session cookies on our website(s). We will use the session cookies to keep track of you whilst you navigate the website(s).
We use Google Analytics to analyse the use of our websites. Google Analytics is a web analytics tool that helps website owners understand how visitors use with their website; this is also the only cookie we use on our sites. Google Analytics uses first-party cookies to track visitor interactions. User data gathered in Google Analytics can be analysed to help us to improve our sites.
Google Analytics generates statistical and other information about website use, which are stored on users’ computers. Google will store this information and Google’s privacy policy is available at: https://policies.google.com/privacy. For more information on opting out of being tracked by Google Analytics across all the websites you use, visit this Google page.
For our reporting needs as well as system administration we may gather data about your computer which can include your IP address, operating system and browser type. This is statistical data about our users’ browsing actions and patterns.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. Please refer to your browser’s settings for details of how to do this. Blocking cookies may, however, have a negative impact upon the usability of many websites, including ours.
We may provide links to third party websites as part of our service to you. We accept no responsibility for any statements, information, content and products associated with these third party websites. We accept no liability for these third parties for any viruses or anything else that could be infectious or destructive.
We may change this policy from time to time; however we are not obliged to give notice of the changes, so you should check our website or contact us to ensure you are referring to the latest version.
