Fair Processing Notice for Intermediaries

1. Purpose of this Notice

This notice is intended to explain how your Personal Data will be handled by Pepper (UK) Limited, Harman House, 1 George Street, Uxbridge, UB8 1QQ ("the Company", "we" or "us") and sets out the information including the personal information detailed below relating to you ("Personal Data") that will be collected and processed by the Company and/or on its behalf by its third party service providers in the context of your relationship with the Company as an Intermediary.

For the purposes of this notice, the controller of your Personal Data is the Company. See section 7 of this notice for the contact details of our Data Protection Officer.

2. Scope

This notice applies to every individual who engages with the Company in the role of Intermediary.

3. How and Why We Process Your Personal Data

The following table details the types of Personal Data that we may collect from you (or that a third party may collect from you and transfer to us, with your consent) and that we shall process as a controller:

Your title; first name; middle name or initials; last name; date of birth; place of birth; mother maiden name; telephone number; mobile phone number; correspondence address; email address; Financial Conduct Authority register number; company address; company status; principal company name.

 

The following tables detail how ("Legal Basis") and why ("Purposes") we process your Personal Data. These tables also describe those recipients (and categories of recipients) with whom we may share your Personal Data ("Recipients") and the period for which your Personal Data may be stored ("Retention"). We encourage you to read this section.

 

Necessary for the Entering into and the Performance of your Contract as an Intermediary
Purposes We obtain, collect and process your Personal Data to:
  • on-board you as an Intermediary, including to contact you in relation to that process and thereafter to communicate with you until such time as that role expires or is terminated;
  • progress any cases or files originating from you as an Intermediary; and
  • process fee payments in exchange for Intermediary services that you provide.
Legal Basis It is necessary to process the Personal Data in order for us to consider whether we may enter into a contract with you for Intermediary services.
Recipients

Personal Data may be disclosed for these purposes to entities affiliated with the Company ("Pepper Group Entities") and our third party service providers. These Recipients may include:

  • one or more financial institutions;
  • IT system and network providers;
  • our professional and legal advisers, insurance providers, auditors and regulators;
  • background check providers;
  • recruitment providers and agencies;
  • outsourced business continuity consultants; and
  • broker networks, packagers and mortgage clubs which you are a member of or associated with.
Retention We will retain the above information within an intermediaries database in line with the Company's record retention policy, which is for six (6) years following termination of the end of your relationship with the Company as an Intermediary. Your data is retained for that duration to enable us to comply with legal and regulatory requirements.

IMPORTANT

  • In the event that you do not wish to provide us with your Personal Data for the above Purposes, we will not be able to appoint or engage you as an Intermediary on behalf of the Company.

 

Legitimate Interests
Purpose

We obtain, collect and process your Personal Data to:

  • on-board you as an Intermediary, including to contact you in relation to that process and thereafter to communicate with you until such time as that role expires or is terminated;
  • manage our business relationship in accordance with the contract; and
  • undertake any necessary activities relating to product launch and/or withdrawal.
Legal Basis We have a legitimate business interest to process your Personal Data for the above purposes. Where we process your Personal Data for these purposes, we carefully balance our legitimate business interest with your right to privacy.
Recipients

Personal Data may be disclosed for these purposes to entities affiliated with the Company ("Pepper Group Entities") and our third party service providers. These Recipients may include:

  • our professional and legal advisers, insurance providers, auditors and regulators;
  • background check providers;
  • Fraud Prevention Agencies such as CIFAS and SIRA; and
  • recruitment providers and agencies.
Retention We will retain the above information within an intermediaries database in line with the Company's record retention policy, which is for six (6) years following termination of the end of your relationship with the Company as an Intermediary. Your data is retained for that duration to enable us to comply with legal and regulatory requirements.

IMPORTANT

  • In the event that you do not wish to provide us with your Personal Data for the above Purposes, we will not be able to appoint or engage you as an Intermediary on behalf of the Company.
  • Please read your rights regarding our processing of your Personal Data in section 6 of this notice, in particular, please read about your right to object to processing and right to erasure.

 

Compliance with Legal Obligations to which we are subject
Purpose We obtain, collect and process your Personal Data in order to comply with the legal obligations imposed on us under applicable legislation.
Legal Basis It is necessary for us to process your Personal Data in order to comply with the legal obligations which apply to us as a regulated entity that appoints Intermediaries.
Recipients The Personal Data that you provide in your application will be disclosed to recipients including but not limited to Fraud Prevention Agencies, Company human resources team, legal advisers, government agencies, insurance providers.
Retention We will retain the above information within an intermediaries database in line with the Company's record retention policy, which is for six (6) years following termination of the end of your relationship with the Company as an Intermediary. Your data is retained for that duration to enable us to comply with legal and regulatory requirements.

4. Marketing Activity

In furtherance of the business relationship between Pepper and you, we will from time to time send information or materials to you that may constitute direct marketing for the purposes of applicable legislation. The purpose of such communications will be to provide information about Pepper, Pepper products, events and any other topics that may be relevant to financial services professionals that relate to the securement of a mortgage. Examples of such communications will include:

  • Product withdrawal/change notifications
  • Product launch notifications
  • Product/criteria promotion
  • Promotional giveaways
  • Portal/Service updates
  • eNewsletters – content could include case studies, thought leadership articles, insight from research, tips on submitting cases with us, tips on how to improve their business etc.
  • Notifications on the publication of new functionality/content on our website
  • Event invites
  • Event follow up
  • News about/promotion of the team and company
  • Surveys – both research and customer service based

When sending marketing communications to you, the legal basis on which we will rely to justify such processing will either be legitimate interests or such other legal basis as may be appropriate in the circumstances, having regard to Pepper's relationship with you.

If you do not wish to receive certain types of correspondence, or wish to unsubscribe from receiving any such communications from Pepper, please contact us at marketing@pepper.money.

5. Cross-Border Transfers of Your Personal Data

We will not transfer your Personal Data outside the European Economic Area ("EEA"). If circumstances change and we are required to transfer any of your Personal Data to outside the EEA, we will notify you of this change and will ensure that such transfers of your Personal Data are subject to the EU Model Clauses or alternative appropriate measures, as permitted under applicable legislation. If you would like to find out more about any such transfers, please contact our Data Protection Officer whose details are set out in section 7 of this notice.

6. Your Acknowledgment of this Notice and Your Rights

Under applicable data protection laws, you have a number of important rights which are available to you free of charge. We have summarised these below:

Right to Object to Processing

NOTE: We encourage you to read this section.

In certain circumstances, you have a right to object to our processing of your Personal Data where we process it for our legitimate business interests. We may not be able to comply with such a request where there are legitimate grounds for the processing that override your interests, rights and freedoms or where the processing of your Personal Data is required in connection with the defence, establishment or exercise of legal claims.
Right of Access You may access and obtain a copy of your Personal Data.
Right to Rectification You may request that we correct any inaccuracies in your Personal Data or amend it if it is incomplete.
Right to Erasure

In certain circumstances, you have the right to request that we erase your Personal Data.

For example, you may exercise this right in the following circumstances:

  • your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;
  • where you withdraw consent and no other legal ground permits the processing;
  • where you object to the processing and there are no overriding legitimate grounds for the processing;
  • where your Personal Data have been unlawfully processed; or
  • where your Personal Data must be erased for compliance with a legal obligation.

Where we store your Personal Data for statistical purposes, we may not be able to comply with such a request where it would likely impair such statistical purposes or where we require your Personal Data for compliance with a legal obligation or in connection with legal proceedings.

Right to Restriction

You have the right to restrict our processing of your Personal Data where any of the following circumstances apply:

  • where you consider that the Personal Data that we hold about you are not accurate. This restriction will be in place for a period sufficient to enable us to verify the accuracy of your Personal Data;
  • where the processing is unlawful and you do not want your Personal Data to be erased, so request the use be restricted instead;
  • where we no longer need to process your Personal Data (e.g. any of the Purposes outlined above have been completed or expire), but we expect it is needed in connection with the defence or establishment of legal proceedings;
  • where you have objected to our processing of your Personal Data pending the assessment as to whether or not our legitimate business interests undermine your interests, rights and freedoms.

Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it with your consent or in connection with the defence or establishment of legal proceedings or for the protection of the rights of other people or for reasons of important public interest.

Right to Data Portability You may receive or arrange for transfer of the Personal Data that you provide to us in a structured, commonly used and machine readable format where we process your Personal Data on the basis of consent or where processing is carried out by automated means. Where you make such a request, we will transfer your Personal Data to a controller of your choice (if it is feasible for us to do so).
Right to Object to Automated Decision-Making, including profiling

You have a right not to be subjected to decisions based solely on automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you. We may not be able to comply with such a request where we rely on your explicit consent or where it is necessary to enter and perform our contract with you (as detailed in section 2 above). You may request a person from our team to review the decision so that you can query it and set out your point of view and circumstances to us.

Note that no processing is currently carried out by automated means in the context of the Company's relationship with you.

 

If you would like to exercise any of your rights detailed above, please contact our Data Protection Officer whose contact details are set out in section 7 of this notice.

7. Concerns Regarding your Personal Data

If you have any concerns about the way your Personal Data is being used or processed by the Company or you are not satisfied, please contact our Data Protection Officer in writing at: Joy Warner, Pepper (UK) Limited, Harman House, 1 George Street, Uxbridge, UB8 1QQ. DPO@peppergroup.co.uk

If you are not satisfied by the effort and response by the Company, you have the right to lodge a complaint with the Information Commissioner's Office. Full details on how to do this may be accessed on the ICO website: https://ico.org.uk/concerns/.

8. Changes to this Notice

We may amend this Fair Processing Notice for intermediaries from time to time, in whole or part, at our sole discretion, and any changes to this notice will be effective immediately upon publishing the revised notice.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you, and you will have a choice as to whether or not we use your information in the new manner.

If you have questions or concerns about this notice, please contact our Data Protection Officer whose contact details are set out in section 7 of this notice.

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