For the purposes of the applicable data protection legislation, Equity Release Supermarket Limited is the ‘controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data) and responsible for this Site.
2 CONTACT DETAILS
Equity Release Partners is the business-to-business operation of one of the UK’s leading advisory firms – Equity Release Supermarket
Full name of legal entity: Equity Release Supermarket Limited
In writing: Data Protection Officer, Equity Release Supermarket, 304 Bridgewater Place, Birchwood Park, Warrington, Cheshire, WA3 6XG
By phone: 01925 830816.
By e-mail: email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4 THIRD-PARTY LINKS
5 PERSONAL DATA WE MAY COLLECT ABOUT YOU
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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes full name, username or similar identifier, marital status, title, age, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Mortgage Data includes property value and outstanding mortgage details.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, reviews, feedback and survey responses.
- Usage Data includes information about how you use our Site, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data which may include details about your health and medical details, where you provide such information to us in relation to our services.
We do not collect any information about criminal convictions and offences.
6 HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Mortgage and Financial Data by filling in forms / using tools on our Site or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use our range of “Calculators”, “Compare deals” or “smartER” tools on our Site or associated websites in order to obtain or request a quote or other relevant information;
- request a quote, appointment or information about our services;
- enter into a contract for the provision of our services;
- create an account on our Site;
- subscribe to our newsletter;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or otherwise contact us; or
- where you provide information via our associated websites.
- Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. For example, we may monitor how many times you visit our Site, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. This information helps us to build a profile of our users to provide a better experience and target our products and services to the appropriate audience. Please see our cookies policy at
https://equityrelease.partners/cookies-policy/ for further details.
- Third parties or publicly available sources. We may receive information about you from third parties or public sources, as set out below. We may combine this information we already hold about you in order to help us personalise our service and the products we offer you.
- Identity and Contact Data from broker-dealers, where you have asked them to obtain a quote for our services.
- Identity, Contact and Financial Data from credit
7 HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have provided Special Categories of Personal Data to us (for example, information about your health or medical condition) we will only process such data for the purpose of providing our services where you have given us your explicit consent to do so.
- Where we need to comply with a legal obligation.
Generally, other than as set out above, we do not rely on consent as a legal basis for processing your personal data. However, in some case, we may ask for your consent to send you direct marketing and for your communication preferences. You have the right to withdraw consent to marketing at any time by contacting us.
8 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||
||Performance of a contract with you|
|To undertake checks to verify your identity, which we may undertake at the time of entering into a contract for services with you and during the term of the contact||
|To contact you, were you have submitted a query or requested an appointment via our Site.||
||Necessary for your legitimate interests (to provide information that you have requested and/or make arrangements for an appointment, as requested)|
|To process Special Categories of Personal Data (e.g. information relating to your health or medical condition) in relation to your request for a quote or your contract for services, where you have provided such information to us. This may include passing your details to equity lenders, in order to submit applications and/or get quotes for equity||
||Data subject’s consent|
|To provide you with our email newsletter||
|To enable you to partake in a prize draw or competition or special offer||
|To ask you to complete a survey or provide feedback on our products or services||
|To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
|To store information and documents relating to you and/or your application / services in your “My Dashboard” on our Site||
|To publish customer reviews and testimonials on our Site||
|To record calls for quality control and training purposes||
||improve the quality of our services and to train our staff)|
9 DIRECT MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We do this to ensure you always get a great service fully tailored to your preferences, but if you would prefer we do not use these kinds of profiling techniques you can opt-out. If you opt-out, you may find your communications from us become less relevant to you.
You will receive email marketing communications from us if you enter into a contract with us for our services or request information about our services (including via the range of “Calculators” or “Compare deals” tools on our Site or associated websites) and do not opt out of receiving such marketing.
If you make a general enquiry via our Site, we will ask for your consent to send you direct marketing by email.
THIRD PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the purchase of products/ services or in relation to your contract with us.
11 DISCLOSURE OF YOUR INFORMATION
Sharing data with our group company
The “smartER” tool is an equity release comparison tool on our Site, which shows personalised results based on each user’s own requirements. In order to use the tool you are required to insert certain information (including personal data) into the online tool and the tool will return personalised results based on the user’s requirements. This will enable you to find out what equity release schemes are available, obtain product information and request further details.
The smartER tool is owned and operated by our group company Equitec Limited, with company registration number 11425582 [(trading as smartER)] (Equitec).
Any personal data that you input into the tool via our Site will be shared with Equitec, who will act as joint data controllers. Where you request a quote via the tool, we will use your personal data in order to contact you (by telephone or email) to follow up your request. Equitec will use information entered into the tool by users, in order to produce reports for third party equity release providers (who sign up to receive such reports) which shall include information (amongst other things) about the type of products users are searching for, which products are most popular at a particular time and the conversion rates from product enquiries to sale. Such reports will be based on aggregated data only and no identifiable personal data relating to users will be provided to the third party providers. Equitec will comply with this Policy at all times in respect of any personal data that it processes for this purpose. If you have any queries, please contact us at.
Sharing data with other third parties
In addition, we may share your personal information with selected third parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with them (which include brokers who make introductions to us, ID verification providers, data cleansing companies and marketing companies).
In addition, we may provide aggregated information about our users to advertisers and/ advertising networks (but we do not disclose any identifiable personal data about our users to advertisers). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
We may also disclose your personal information to third parties:
- if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Equity Release Supermarket Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about the registered users of the Site will be one of the transferred assets; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of
Equity Release Supermarket Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12 WHERE DO WE STORE YOUR DATA?
The third parties that we share personal data with may from time to time be based outside the EEA, in which case their processing of your personal data will involve a transfer of data outside the EEA. However, where your personal data is transferred outside of the EEA we will ensure a similar degree of protection is afforded to it by ensuring that an appropriate safeguard is in place. Please contact us at
email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
13 DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, 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.
14 HOW LONG WILL YOU USE MY DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Where you enter into a contract for our services, we will need to retain your personal data for the duration of the contract (which will usually be your lifetime) and for six years after you cease being a customer for accounting / tax purposes. Where you exit your policy early, we will only retain your personal data for a long as is reasonably necessary and for a maximum of ten years (depending on the relevant lenders repayment terms). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
15 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the GLOSSARY below below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.