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Privacy Policy

1. What is this document?

This document sets out how Lifetime Equity Release Limited (“LER” or “we”) uses personal data about you. We are committed to protecting your personal data which includes letting you know how we use it and telling you about your rights. This privacy notice is provided in a FAQ format so you can click through to answers to specific questions as set out above. Alternatively, you can download a pdf version of the full notice here. This website and our products and services are not intended for children.

In some situations, we may provide you with additional information about specific uses of your data. This privacy notice supplements those other notices and is not intended to override them. This notice was last updated on 1 April 2019.

2. Who is responsible for my data?

LER is the “data controller” in respect of the data. Our head office address is Dunbar House
Sheepscar Court, Northside Business Park, Leeds, West Yorkshire, LS7 2BB.

3. How can I contact you with questions or comments about how you use my data?

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice and other data protection issues. If you have any questions about this privacy notice, please contact our Data Protection Officer by e-mail at info@lifetime-group.co.uk;  by telephone on 0113 833 1003 or by post at Dunbar House, Sheepscar Court, Northside Business Park, Leeds, West Yorkshire, LS7 2BB.

4. What information do we collect and when?

 

Information

How is it obtained

1

Your full name*

Enquires on our website and during advisory discussion over the phone

2

Previous names

During advisory discussion over the phone

3

Your postal address*

Enquires on our website and during advisory discussion over the phone

4

Previous address(es)*

During advisory discussion over the phone

5

Your date of birth*

Enquires on our website and during advisory discussion over the phone

6

Your marital status*

During advisory discussion over the phone

7

Your contact telephone numbers (daytime and evening) *

Enquires on our website and during advisory discussion over the phone

8

Your e-mail address*

Enquires on our website and during advisory discussion over the phone

9

Property details, value, and remaining mortgage*

Enquires on our website and during advisory discussion over the phone

10

Nationality*

During advisory discussion over the phone

11

Your employment details/status*

During advisory discussion

12

Your income and expenditure*

During advisory discussion

13

Details of assets, investments, and pensions*

During advisory discussion

14

Details of existing credit arrangements including mortgage and unsecured credit

Enquires on our website and during advisory discussion

15

Your credit status and history (including the information set out in Section 4 below) *

During advisory discussion

16

Your requested loan amount and term*

During advisory discussion

17

The reason for your loan*

During advisory discussion

18

The number of children or dependents in your household

During advisory discussion

19

Your residential status (whether you own or rent your home) *

During advisory discussion

20

Details of any health and medical related matters*

During advisory discussion

21

Information about arrangements in the event of serious ill health, death and long-term care*

During advisory discussion

22

Bank Account Details*

During advisory discussion

23

Debit Card Details*

During advisory discussion

24

Photographs of documents such as passport, drivers’ licence, utility bills

From you if required (not in all cases)

25

Details of beneficiaries, executors, trustees, attorneys, related person for estate planning purposes (e.g. Wills, Trusts and Lasting Powers of Attorney).

During advisory discussions

26

Existing buildings and contents insurance arrangements

During advisory discussions

27

IP address

From the website

28

Details of any recommendation made including Lifetime Mortgage Provider and product taken out

From results of advice process concluded between us and you and the Lender.

5. What other information do you collect about me?

When we have provided you with advice and recommendations that you decide to proceed with, we carry out checks on your identity.  We need to do this in order to progress a lifetime mortgage application. In order to do this, we obtain information about via ‘Experian’ who check your details against financial sanctions lists. More information about how we work with credit reference agencies is set out at How do you work with Credit Reference Agencies?  

6. What do you use my personal data for? 

Purpose

Personal data used may include

Lawful basis for processing

To initially contact you to provide you with information on equity release and estate planning (lifetime mortgages and home reversion, property insurance, wills, trusts, and lasting powers of attorney).

Data set out in section 4 above at point - 1, 3 & 5 – 9.

Legitimate Interest – the provision of this information will generally be due to a request made by yourself about our products and services.

To provide you with advice and recommendation on equity release products (lifetime mortgages and home reversion), and

Information on buildings and contents cover.

All information set out in section 4 (points 1 – 19 & 21 – 23, 25 & 26

(see below for point 20).

Contractual Obligations – the provision of advice and recommendation is pursuant to you entering into a contract with a third-party Lender of Lifetime Mortgages and therefore are required to process the date to achieve this.

 

The category of personal data set out in section 4 above at point 20.

Explicit Consent – we will ask you to give explicit consent to process this data at the time we ask for it. Whilst you may prefer not to provide consent, failure to do so may lead to you not receiving the best solution for your circumstances.

To process an application for a lifetime mortgage or home reversion and/or

To process an application for buildings and contents cover.

All information set out in section 4 (points 1 – 23 & 26).

Contractual Obligations – the provision of advice and recommendation is pursuant to you entering into a contract with a third-party Lender of Lifetime Mortgages and therefore are required to process the date to achieve this and/or

Provision of information to pursuant to you entering into a contract for buildings and contents cover.

To provide you with information and guidance on relating to estate planning only (wills, trusts, and lasting lowers of attorney).

All information set out in section 4 (points 1 – 8).

Legitimate Interest – the provision of this information is required in order for us to provide the service via third parties. (see section 11 below).

To verify your identity.

All information at Section 4 point 1- 6, 10 & 24, and Section 5.

Legal obligations

Keeping you informed of ongoing equity release and home insurance products along with wider estate planning products and services   that might be of interest to you including wills, trusts, and lasting powers of attorney.

 

The categories of personal data set out in section 4 above at point - 1, 3, 5 ,6, 7, 8 & 26.

Legitimate interest – we believe that keeping you informed of products that could be financially beneficial to you is a key service. You will have the right to opt out of any communications of this nature if you no longer wish to receive them.

To contact you in connection with any enquiries that you raise.

The categories of personal data set out in section 4 above at point - 1, 3, 7 & 8.

Legitimate interests of responding to questions and comments raised by individuals that contact us.

Monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business including quality and training purposes.

The categories of personal data set out in section 4 above at point 20.

Legitimate interests of complying with regulatory rules and ensuring we are implementing quality checking and compliance processes.

7. Do I have the right to withdraw consent?

Where we rely on your consent to process personal data you have the right to withdraw consent. However, the majority of our processing of your personal data is not based on consent he majority of our processing is necessary for performance of the contract between us or so that we can comply with our legal and regulatory obligations. Our collections activity is not based on consent. We have a contractual right and legitimate interest in collecting sums due to us. Therefore, you do not have the right to withdraw consent to us using your information for this purpose.

8. How long will you keep my data for?

Any personal data you provide to us during the course of an enquiry where you have not specified that you do not wish to be contacted in future will be retained and processed in order that we can keep you up to date with our services and market developments.

If you notify us that you do not wish to be contacted (either at the point of enquiry or subsequently) we will apply this immediately. If you have not progressed to advice and recommendation or transacted business with us, your personal data will be deleted from our systems within two years.

Where we have provided you with advice and a recommendation you have not proceeded with, your personal data will be deleted from our systems after three years.

Where you have taken out a lifetime mortgage, we will retain the information provided by you and the subsequent advice and recommendation for six years after the term specified for your equity release plan for legal and compliance purposes. In addition, where you have not specified that you do not wish to be contacted in future, we will use your data to ensure you are kept up to date on products or services that may be beneficial to you  however, after ten years we will remove records from our live systems and will retain them as archived records.

9. How do you keep my data secure?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, inappropriately altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We regularly review our information collection, storage and processing practices, including physical security measures.

10.  Is any of my data transferred outside the EEA?

We will not transfer your data out of the European Economic Area (EEA) or to any country that has been deemed (by the Information Commissioners Office) to have inadequate data protection controls.

11. Do you share or disclose my personal data with anyone else?

Here is when we disclose information about you:

Equity release

 Estate planning

12. How do you work with affiliates? 

Some of our customers are referred to us by third parties who we call affiliates. Where a customer makes an enquiry through an affiliate, the data provided to contact you will be processed accordingly.

13. What rights do I have to access information about me? 

You have the right to find out what personal data we hold about you, and to receive a copy of that data. (See section 2 for contact details.)  We will process your request in accordance with your subject access rights set out in the DPA 2018 and General Data Protection Regulation ((EU) 2016/679). We will not charge you a fee and we will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.

14. What should I do if I think the details you hold are inaccurate? 

It is important that the personal data we hold about you is accurate and current lease keep us informed if your personal data changes during your relationship with us. If for any reason you are unsure about the personal and account information we are holding in your name, please contact us using the details in section 2.

Where data is simply out of date (for example you have moved house) we will update your file but may retain a record of the old data for audit and compliance purposes or example we may need to verify that we carried out searches against the address which was current at the relevant time. If you dispute the accuracy of the information we hold, we will restrict processing, where appropriate, while we consider your request.

15. Can I ask you to stop processing information about me? 

Where data is processed only on the basis of consent you can withdraw this consent at any time. However, this does not affect the lawfulness of any processing carried out before you notify us that you have withdrawn your consent.

Where we have another legal basis for processing your data, we may be able to continue to process this even if you do not consent to it. We also have no obligation to stop using your data if your data is required for legal proceedings or the establishment, exercise, or defence of legal rights.

Where we process data on the basis of legitimate interests you have a right to object to this. We will restrict what we do with your data while we consider this request and will stop processing the data if we cannot show overriding legitimate grounds for processing the data. We will not charge you a fee and we will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.

16. Can I ask for information about me to be deleted?

Where data is being processed only on the basis of consent and you withdraw that consent you also have the right to ask for the data to be deleted. You have the right to ask for data to be deleted where the data is no longer necessary for the purposes for which it was collected, or if it is being processed unlawfully. You can also ask for data to be deleted if you successfully object to processing based on our legitimate interests. Your rights to do this are described above.

This right does not apply to all information about you. Information required to establish, enforce, or defend our legal rights, or which is required for compliance purposes also does not need to be deleted.

We will not charge you a fee and we will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.

17. Do you make any decisions about me automatically?

We do not make any purely automated decisions.

18. How can I complain about how you use my data?

If you are unhappy with the products or services that we have provided you with or are dissatisfied with the handling of your customer data, you can contact us at the details provided at Section 2 above.

You may also refer your complaint to the Information Commissioner’s Office. The ICO has web forms for making complaints and also has a helpline you can call. Details are available at https://ico.org.uk/global/contact-us/

We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance the ICO will usually ask if you have done this before progressing your complaint.

19. How will I find out about any changes in how you use my data? 

Any changes we make to how we use your data will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.

20. Does your website use cookies?

Cookies are small text files placed on your PC, tablet, or mobile phone when you visit a website. They remain on your device and are sent back to the website they came from when you revisit that site.

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us for our use only. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products AND services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt e.g. cookie pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully as a result. 

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them. 

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products AND/OR services offered through it. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, enhancing your user experience.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Information on deleting or controlling cookies is available at the ‘About Cookies’ website www.aboutcookies.org.

Know Your Cookies
All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:

Strictly Necessary Cookies
A cookie falls into this category if it is essential to the operation of our website. Strictly necessary cookies may, for example, be required for functions such as logging in, storing items in a shopping basket, or enabling payment transactions.

Analytics Cookies
Understanding how users use our website can be extremely valuable. Analytics cookies provide insights into many factors such as how users are navigating around the site and what features they are using. Analytics cookies may often be set by third parties, but not always.

Functionality Cookies
Many websites offer some level of personalisation and functionality cookies play a key role here. For auditing purposes, however, it is important not to confuse these with the strictly necessary variety. If the site can be used properly without the cookie, it isn’t strictly necessary.

Targeting Cookies
It is important to know when and how often someone visits our website, and which parts of it they have used (including which pages they have visited and which links they have followed). As with analytics cookies, targeting cookies allow us to better understand our users, enabling us to make our site and, more importantly, the advertising on it more relevant to those users’ interests. Targeting cookies may often be set by third parties.

First-Party Cookies
As the name suggests, these cookies are placed directly by our website (as opposed to those placed by third-party services, for which see below). Most, if not all, of your strictly necessary and functionality cookies will likely be first-party cookies.

Third-Party Cookies
These cookies are placed by third parties providing services such as advertising and analytics. Analytics and targeting cookies are common types of third-party cookie as such work is often not undertaken in-house.

Persistent Cookies
Any of the cookies listed above may be a persistent cookie. Persistent cookies are those which remain active on a user’s computer or device for a predetermined period of time and are activated when that user visits your website.

Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.

For more specific details of the Cookies that We use, please refer to the table provided above.

Links to other websites
Our website may contain links to third party websites. It should be noted that we do not have any control over these websites and so we are not responsible for the protection and privacy of any information which you provide whilst visiting such sites, which are not governed by this privacy statement. For this information, please consult the privacy statement applicable to the website in question.

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