Customer Privacy Notice  

KYLE FINANCIAL LIMITED (our Firm, we, our, us) an Appointed Representative of PRIMIS  Mortgage Network a trading name of First Complete Limited (Our Network).  

Why are we asking you to 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 Information). We would like to explain to you what we will need to do with  Your Information, and the various rights you have in relation to Your Information.  

What do we mean by “Your Information”? Your Information means any information  describing or relating to you. Your Information may identify you directly, for example your  name, address, date or 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 providing you with assistance in relation to your mortgage and/or  insurance 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 and/or insurance products and the terms and conditions  relating to these 

The basis upon which our Firm will deal with Your Information 

When we speak with you about your mortgage and/or insurance requirements we do so  on the basis that a contract for the supply of services is in place between us. In order to  perform that contract, and to arrange the products you require, we have the right to use  Your Information for the purposes we set out below. 

Alternatively, either in the course of initial discussions with you or when the contract  between us has come to an end for whatever reason, we have the right to use Your  Information 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 Network 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 Information to enable us to meet any contractual  responsibilities we may owe our Network, or for wider compliance with any legal or  regulatory obligation to which we might be subject. If this were to arise we would be  processing Your Information in order to meet a legal, compliance or other regulatory  obligation to which we are subject.  

The basis upon which we will process certain parts of Your Information 

Where you ask us to assist you with your insurance needs, 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 Data).  We will record and use Your Special Data in order to make enquiries of insurance  providers in relation to insurance products that may meet your needs and to provide you  with advice regarding the suitability of any product that may be available to you.  

If you have parental responsibility for children under the age of 16 it is also very likely that  we (and consequently our 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 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.  

You’re Special Data and any Criminal Disclosures will be used by us in the same way as  Your Information generally, as set out in this Customer Privacy Notice.  

When we process your Special Data and any Criminal Disclosures we do so on the basis  that it is in the substantial public interest to be able to provide vital insurance products  and as permitted by UK data protection related laws and regulations from time to time.  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. 

How do we collect Your Information? 

We will collect and record Your Information 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 mortgages and 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  Information, such as software that is able to verify your identity on-line or to access your  credit status and/or bank account entries, then you will be required to provide your  consent for us or our nominated processor to access your information in this manner, 

and details of how such software operates will be provided to you prior to the activation  of the service. 

What happens to Your Information when it is disclosed to us? 

In the course of handling Your Information we will: •record and store Your Information in  our paper files, mobile devices and on our computer systems (websites, email, hard  drives, cloud facilities) and it will be accessed by employees and consultants within, or  contractors engaged, by our Firm as necessary to provide our service to you and to  perform any administration tasks associated with or incidental to that service 

•submit Your Information to mortgage lenders and/or insurance product providers, both in  paper form and on-line via mortgage lender/insurance provider systems, in order to  progress any enquiry or application made on your behalf and to deal with any additional  questions or administrative issues that mortgage lenders and insurance providers may  raise 

•input Your Information, along with full details of the mortgage and/or insurance,  discussed with you or which you have taken out, to the computer systems of our Network 

•use Your Information for the purposes of responding to any queries you may have in  relation to any mortgage product or insurance policy you may take out, or to inform you  of any developments in relation to those products and/or polices of which we might  become aware 

Sharing and transferring Your Information 

From time to time Your Information will be shared with or transferred to: •our Network •to mortgage lenders 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, such third parties will include but may  not be limited to, product specialists (including those within our Network and other  Appointed Representatives of the Network), estate agents, providers of legal services  such as conveyancing, surveyors and valuer's (in each case where we believe this to be  required due to your particular circumstances). 

In each case for the purposes set out in this customer privacy notice, i.e. to progress your mortgage and/or insurance enquiry and to provide you with our professional services.  

Please note that this sharing of Your Information does not entitle such third parties to  send you marketing or promotional messages: it is shared for the purpose of ensuring we  can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer  Privacy Notice. 

We do not envisage that the performance by us of our service will involve Your  Information being transferred outside of the European Economic Area. 

The basis upon which our Network will deal with Your Information, Your Special Data and  Criminal Disclosures 

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. Please note that the above information is a summary of the  Network Privacy Policy for customers. If, you wish to understand in more detail what the  Network will do with Your Information and Special Data/Criminal Disclosures then please  visit the Network Privacy Policy for customers located at http://www.primis.co.uk/privacy policy-and-tcs  

Security and retention of Your Information 

Your privacy is important to us and we will keep Your Information secure in accordance  with our legal responsibilities. We will take reasonable steps to safeguard against Your  Information being accessed unlawfully or maliciously by a third party, accidentally lost,  destroyed or damaged. 

We also expect you to take reasonable steps to safeguard your own privacy when  transferring information to us, such as not sending confidential information over  unprotected email, ensuring email attachments are password protected or encrypted and  only using secure methods of postage when original documentation is sent to us.

Your Information will be retained by us either electronically or in paper format for a  minimum of six years, or if longer than six years, the duration of this Firm’s relationship  with you.  

Your rights in relation to Your Information 

THE RIGHTS MARKED WITH A * ARE EFFECTIVE FROM 25 MAY 2018 You can: •request  copies of Your Information that is under our control 

•ask us to further explain how we use Your Information 

•ask us to correct, delete* or require us to restrict or stop using Your Information (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 Information 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) 

How to make contact with our Firm in relation to the use of Your Information 

If you have any questions or comments about this document, or wish to make contact in  order to exercise any of your rights set out within it please contact: Kyle Financial  Limited, 36 Washington Street, Glasgow, G3 8AZ.  

If we feel we have a legal right not to deal with your request, or to action it in 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 Information, so that we may investigate and fulfil our own regulatory  obligations. 

If you have any concerns or complaints as to how we have handled Your Information or  Your Special Data/Criminal Disclosures you may lodge a complaint with the UK’s data  protection regulator, the ICO, who can be contacted through their website at  https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office,  Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.