Credit CheckPrivacy Policy Notice
Liquid Complete Limited trading as Liquid Expat Mortgages
Last updated: 07/05/2024
Under the UK GDPR rules we are required to notify the Information Commissioner’s Office (“ICO”) about our use of personal data.
You can view our current controller registration on the ICO here:
https://ico.org.uk/ESDWebPages/Entry/ZA110333
Introduction
This notice provides you with information concerning our collection and use of personal data. If you have any queries regarding this statement, please do not hesitate to contact us.
Information We Collect
Personal Information- This includes your name, contact details, date of birth, National Insurance number, employment details, financial information, and any other personal information necessary to assess your mortgage application.
Communication Data- We may collect data related to your interactions with us, such as emails, phone calls, and website inquiries.
Usage Data- We collect information about how you use our website and services, including your IP address, browser type, pages visited, and timestamps.
Legal basis
At Liquid Expat Mortgages, we are committed to protecting the privacy and security of your personal information.
We collect personal data about a range of people:
- Visitors to our websites
- People who contact us (enquirers)
- Clients (including clients of the businesses operating under us)
- Contractors and suppliers
- This Privacy Policy outlines how we collect, use, and disclose your data in accordance with the General Data Protection Regulation (GDPR).
Necessary to contract
We collect, control and process your personal information because this is necessary to provide you with information, answer any queries you may have and for the provision of our services to you. We will process your data as outlined below in order to advise & arrange mortgages and/or insurance protection. Our services are fully outlined in our terms of business and extend to include ongoing updates, for example, contact when a discounted or fixed rate period on the mortgage we have arranged for you comes to an end.
How We Use Your Information
Processing Mortgage Applications- We use your personal information to assess your eligibility for a mortgage and to provide you with mortgage products and services.
Communication- We use your contact details to communicate with you about your mortgage application, provide updates, and respond to your inquiries.
Improving Our Services- We analyse usage data to improve our website, services, and customer experience.
Legal Compliance- We may use your information to comply with legal obligations, such as anti-money laundering regulations.
Consent for processing of sensitive data
Data Sharing and Disclosure
Service Providers- We may share your information with third-party service providers who assist us in processing mortgage applications, conducting credit checks, and providing support services.
Affiliates- We may share your information with affiliated companies within the Liquid Expat Mortgages group for business purposes.
Legal Requirements- We may disclose your information when required by law or to protect our rights, property, or safety, or that of others.
Data Security
We implement technical and organisational measures to safeguard your personal information against unauthorised access, disclosure, alteration, or destruction.
We may also request or process sensitive personal data, but only if it relates specifically to the services you wish us to provide.
Sensitive personal data:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Data concerning health
- Data concerning sex life or sexual orientation
We would discuss with you the need for the provision of sensitive data before you provide this information. The subsequent provision of sensitive personal data will be taken as consent to this processing.
It is entirely up to you as to whether or not you choose to provide us with any personal information. If you choose not to, we simply may not be able to assist you.
Your Rights
Under the GDPR, you have the following rights regarding your personal information-
Right to Access- You have the right to request access to your personal information and to receive a copy of the data we hold about you.
Right to Rectification- You have the right to request that we correct any inaccuracies in your personal information.
Right to Erasure- You have the right to request the deletion of your personal information under certain circumstances.
Right to Restrict Processing- You have the right to restrict the processing of your personal information under certain circumstances.
Right to Data Portability- You have the right to receive your personal information in a structured, commonly used, and machine-readable format.
Legitimate Interests
On occasion we may communicate with you if you have given us your contact details in order to make you aware of beneficial new products and services. For example, if we have been unable to obtain a loan or insurance that you requested or required; then we may contact you when a new suitable product becomes available. We may also send you updates on this basis that are useful or beneficial to your business.
Consent to marketing
We will only send you marketing information if you have given informed consent for us to do this unless it is information that we consider to be covered by legitimate interests.
Processing
Visiting our website
When you browse our site your IP address will be processed and continued browsing is considered to be consent to our use of cookies. Please reference our Cookie Policy. This will be handled by WordPress.
Completing our initial enquiry form.
When you make an initial enquiry we will collect and process the data you provide. Your data is protected by a secure socket layer provided by Let’s Encrypt and it will be passed to our email hosted by Microsoft Exchange Server.
Calling our business line
If you leave a message on our answering service this will be processed for us by Orca.
Doing business with us
In order to communicate with you about our services we will initially require your contact details including personal email addresses.
When we undertake mortgage and insurance advice or arrangement services we will record and store your personal data with systems. Details of the third party processors and controllers with whom we share data are listed below.
Working for us
Employee personal data is also stored on our systems and shared in order to facilitate salary payments and to meet regulatory and operational requirements.
Sharing your data
In order to fulfil our obligations under any contract for services we will need to share your data with third party Data Controllers and Data Processors.
Data Controllers
This will include
- Product & service providers in relation to mortgages & insurance.
- Our compliance monitoring services.
- The Financial Conduct Authority.
- The Financial Ombudsman Service.
- Any other regulators where so required.
- Book keeping, accounting and reconciliation services
We also use external Data Processors that will hold information for the following purposes:
- Secure file sharing
- Data backup
- Dissemination of information
- Communications
- Research
- Client management
All external processors are only permitted to process your data in line with our instructions.
| Processor | Type of processing & data |
| WordPress | WordPress is a trading style or Automattic Inc. and it provides website hosting services and uses cookies to enhance your experience. |
| Let’sEncrypt | Provides a secure socket layer to protect the information you provide in our web forms. |
| Orca | Our answering service may collect data including your phone number and your message to us. |
| Microsoft | Provide our email hosting; personal data is processed for calendar, contact and email synchronization and Office 345 software where we may process your personal data. |
| Xero | We use accounting software to process payroll and staff information. |
| Mortgage Keeper | Software we use to maintain records of your information pertinent to our work with you. |
| Trigold | Mortgage sourcing software that helps us to find the best mortgage deal for you. |
| Twenty7 Tech | Mortgage sourcing software that helps us to find the best mortgage deal for you. |
| AWS | Amazon web servers host our remote back up to ensure data is always available for us to provide service continuity in the event of any local IT failure. |
| YMLP | Communications software enabling us to send you relevant information. |
| Mail chimp | Communications software enabling us to send you relevant information. |
| Commversion Ltd | Our Live-Chat service may collect data which you provide, including name, phone number, email address and your message. |
| Sendgrid | Communications software enabling us to send you relevant information. |
| MongoDB | Used for Data storage and retrieval for our fact find service. |
| Heroku | Hosting platform for our fact find service. |
In all cases we seek to minimize the amount of personal data shared and in some cases anonymise this. It is essential, however, that we can identify you quickly and easily so information shared may be identifiable as your personal data.
We will not share your personal information in any other circumstances than those necessary for the provision of service to you or where we are required to do so by law.
Otherwise we will not share your personal information with other companies without your express authority except if the firm is sold or where we are required to do so by law.
Marketing
The information we collect about you is used solely for the purposes for which it was provided. We will never share your data for marketing purposes.
Your rights
Under data protection law you have the right to ask us for a copy of the information we hold about you, and to have any inaccuracies corrected or removed. You may also ask us to delete all personal data held by us or any controller or processor with which we have shared your data.
To do this, please either contact us in writing, by telephone or email.
Contact
For any queries about data protection please contact:
| Contact name | Stuart Marshall |
| Address | Suite 4b, Link 665 Business Centre, Todd Hall Road, Rossendale, BB4 5HU, United Kingdom |
| Telephone | +44 161 871 1216 |
Where we store your Personal Data
All the data that we collect is stored on our local servers at our UK officer or with our listed processors under contract normally within the EU. Where data is stored outside the EU we ensure that this is in an adequate jurisdiction and protected; data stored in the US is with providers signed up to the EU-US Privacy Shield.
IP Addresses and Cookies
Our website uses cookies purely to enhance your experience.
(A cookie is a piece of information that is stored on your computer’s hard drive which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit.)
Vital cookies
Ones that are essential to the operation of the website. These cookies enable a site to remember text entered in a page within the same session or to remember whether a user is logged in or not, the site cannot function without them.
Performance cookies
Performance cookies, which collect information about website usage to enhance the web experience. Examples of these include website analytics (i.e. Google Analytics) and ad-response rates (where data is collected exclusively for calculating click-through rates). They don’t collect information that can identify a particular visitor. These cookies are usually persistent and have fairly long expiry rates.
Functionality cookies
These remember the choices that users make within a web page, such as usernames, language or region to provide an enhanced, more personalised web experience. They cannot track your activity on other websites and are anonymous.
Advertising cookies
Targeting or advertising cookies collect information about your browsing habits to tailor third-party advertising to meet your interests. They are usually placed by advertisers with website operators’ permission. We do not use this type of cookie.
Changes to this Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on our website, and we encourage you to review this Privacy Policy periodically for updates.
By using our website and services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
Contact Us
If you have any questions or concerns about our Privacy Policy or the processing of your personal information, please contact us at info@liquidexpatmortgages.com.