Zeus Financial Services Limited – Privacy Policy

1. Who we are

This Privacy Notice applies to the use and processing of personal information collected by New Build Mortgage Services and Part Ex Mortgage Services, which form apart of Zeus Financial Services Limited. The ICO Registration number of Zeus Financial Services Limited is A8462209.

The phrases “us”, “we” or “our” will mean those businesses which are part of Zeus Financial Services Limited on behalf of and in respect of whom this Privacy Notice is made.

For information concerning the collection, use and processing of personal information by any of our third party business partners or suppliers, please contact our representative with whom you usually deal.

2. Information covered by this Privacy Notice

1. Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you
2. Special categories of personal data. This is information which is classified as sensitive (for example details of your health)

Please read this Privacy Notice carefully. If you have any questions about this notice or our use of your personal data, please contact the Connells Group Data Protection Officer by email to DPO@connellsgroup.co.uk or in writing to Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN.

Zeus Financial Services Limited is part of the Connells Group, and all data protection matters are managed at Group level. Information concerning the make-up of the Connells Group can be found by visiting http://www.connellsgroup.co.uk/our-group

3. Where we get personal information from

When you enquire or register for products and services provided by Zeus Financial Services Limited we may collect personal information from a variety of sources.

The majority of the personal information which we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet.

However we may also obtain your personal data from other sources including:

• other Connells Group companies
• other publically available sources such as the electoral roll and HM Land Registry

4. What information we collect

4.1 Information we collect directly from you

Depending on the type of service or product we are discussing, the following are examples of information we may collect directly from you:

Information we may collect directly from you	Why we collect it
Your name, postal address, phone number, email address and details of your requirements	To provide you with Mortgage and Protection advise
Your marital status, date of birth, nationality and tax status	To provide you with Mortgage and Protection advise
Your date of birth, nationality and details from identity documents you provide	To perform ‘know your client’, anti-money laundering checks, as required by law
Proof that you have sufficient funds to support any offer that you may wish to make to buy a property	To ensure you able to pay the required amount of deposit
Financial information, for example, a copy of your bank statement	To provide evidence of the source of funds you will be using to buy a property
Your bank account details	Where we take payment for the services we provide to you
Your marital status, employment details, national insurance number, nationality, residential status, bank details and credit history	To carry out credit checks and the results of those checks
Your name, gender, previous name, mother’s maiden name, date of birth, contact telephone numbers, current address and previous addresses, details of your health and family history , information about your status and dependents, your nationality, bank account details, savings and investments, existing financial commitments, your credit history, your mortgage requirements and existing protection arrangements	To enquire or apply for mortgage or protection products on your behalf
Your communication and marketing preferences	To ensure we only send you details of products and services you are interested in through your preferred communication channel

Where you ask us to help you with your life, critical illness or income protection insurances, and we collect personal information from you which is of a sensitive nature, we treat this ‘special category’ information in accordance with the additional protection it is given under data protection laws. We may, during the course of your relationship with us, request additional information from you which is relevant to the provision of specific services.

Any telephone calls either to or from our customer service teams may be recorded for training, monitoring, compliance and security.

4.2 Information we obtain from other Connells Group companies

For activities related to providing advice on regulated mortgages and non-investment insurance contracts, Zeus Financial Services Limited is an appointed representative of Connells Limited, and may share your information within the Group.

Connells Ltd is authorised and regulated by the Financial Conduct Authority; the Financial Services Register number is 302221.

4.3 Information we obtain from third parties

Where we are required by law, or for business needs, we will obtain information about you from third parties, but only after we have your agreement to do so. For example (but not limited to) the third parties we may need to contact are credit reference agencies, banks, employers, accountants and solicitors in order to obtain references, undertake identity verification, and validate your income level and financial history.

4.4 Circumstances under which criminal disclosures will be collected

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. This is relevant to insurance related activities such as underwriting, claims and fraud management.

When we process 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 as permitted by UK data protection related laws and regulations from time to time. Information on Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as us and insurance providers, to enable customers to secure the important insurance protection that they require.

5. How we use your information

We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have.

The following are examples of how we use the information we collect:

• To process your registration and confirm your identity
• To provide advice on financial products and services, such as mortgages, insurance and protection products
• To keep you informed of any developments in relation to any mortgage product, protection product or insurance product which we help you to take out;
• To provide will writing and associated legal services
• To process payment for our services
• To protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent or franchise quality, integrity, compliance and security of business processes
• To provide, administer and communicate with you about Connells Group products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners
• To operate, monitor, evaluate and improve our products, services and websites
• To evaluate your interest in and suitability for employment

5.1 Customer Surveys

From time to time we may provide your information to our customer service agencies for research, survey and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may occasionally contact you including by post, email or telephone to ask you for your feedback and comments on our services.

5.2 Information about our products and services

We may also use your personal data to contact you by post, e mail, telephone or other electronic means to provide you with information about products and services from the Connells Group and carefully selected third parties which we feel may be of interest or relevant to your needs.

Please see Section 12 for information about how you can exercise your rights.

5.3 Credit scoring

Some of the services provided by third parties may involve an automated decision and/or credit scoring to determine whether we are able to provide a service or product.

Using third parties to undertake searches and collate information on our behalf helps make fair and responsible decisions. When coming to these decisions we and third parties will consider:

• the information provided on the application form
• information about previous account conduct , including any payment arrears and
• official public records information such as fraud record information and insolvency records

Any credit scoring methods used by third parties are regularly tested to ensure they remain fair, effective and unbiased.

For further information about automated decisions or credit scoring, please contact the Connells Group Data Protection Officer by e mail at DPO@connellsgroup.co.uk

6. Who we share your information with

We may share your information both within the Connells Group of companies and also relevant third party business partners, both for the purposes set out in this Privacy Notice, or for other purposes approved by you.

6.1 Connells Group

We may share information within the Connells Group of companies for the following purposes:

• where services are provided by one Connells Group Company to another pursuant to an intra-company
• for the purpose of administering our business
• to provide you with information about products and services
• for any other purpose agreed by you

6.2 Third Party service providers

Where we engage third party service providers to provide products (such as mortgages, house and contents and family protection insurances and utility services) or other business services and operations, we provide them with only the personal information they need to perform the service or provide the product we request. We contractually require them to securely protect information, and not to use it for any other purpose.

Indicatively - but not limited to - we may disclose your information to the third parties listed below for the purposes listed:

Third party	Why we share your personal information
Our panels of mortgage lenders	To progress your enquiry or application for a residential or buy to let mortgage application
Ageas Insurance Limited	To progress your enquiry or application for buildings and contents insurance
Aviva	To progress your enquiry or application for term insurance, critical illness cover and income protection
Rent and Legal insurance providers	To set up landlord insurances, and in the event of a claim
Law enforcement bodies including the police, HMRC and local authorities	To comply with court orders or legal obligations
Debt collection companies	To assist us in recovering any monies which are owed and overdue

7. Lawful basis of processing

Zeus Financial Services Limited processes your information under any of the following lawful conditions:

1. Performance of a contract - this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract
2. Legal obligation - this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example verification of identity and fraud prevention
3. Consent - where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example to send and/or receive marketing information from other Connells Group companies
4. Legitimate interests - some information is processed by Zeus Financial Services Limited as part of its legitimate interests which include network and information security, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided

8. Other situations

We may transfer or otherwise process your personal information:

• As part of the sale of a Connells Group business to another company, or in relation to the purchase of another business
• When we have received your instruction to pass the sale of your property to another agent
• To enforce our terms and conditions
• When required by law and/or government authorities
• When requested by the Financial Ombudsman Service

9. How long we keep your information for

We will keep your information for as long as is reasonably necessary for the purposes set out in this privacy notice, and to fulfil our legal and regulatory obligations.

For further information about how long we will keep your information, please contact the Connells Group Data Protection Officer by email at DPO@connellsgroup.co.uk

10. When we communicate with you

10.1 Service related

We will send you service related communications and respond to any questions which you may ask.

10.2 Marketing our services to you

We may also contact you in order to provide you with information, in accordance with your preferences including:

• information on mortgages, protection and insurance products and conveyancing services

We may also carry out targeted advertising to you on social media websites such as Facebook where you have already shown an interest in our services. This is done through analysing information we collect about your interactions on our websites and making this available to social media networks.

11. How we communicate with you

For service related communications, we will contact you either by e mail or through the post. We may also telephone you or send you SMS messages, which may include automated SMS reminders for viewings.

We give you choices about how we communicate promotions and offers to you.

11.1 By e mail

We only send you promotional emails if you explicitly select to receive these (you opt in). You can stop receiving promotional email messages from Zeus Financial Services Limited by contacting us on 01525 244200, or by emailing us at zeusfinancialservices@connellsgroup.co.uk

11.2 By post

We only send you promotional postal mail if you explicitly select to receive these (you opt in). You can stop receiving promotional postal mail from Zeus Financial Services Limited by contacting us on 01525 244200, or by emailing us at zeusfinancialservices@connellsgroup.co.uk

11.3 Mobile Text Messages

We will only send you promotional text messages if you explicitly select to receive these (you opt in). You can stop receiving promotional text messages from Zeus Financial Services Limited by following the opt-out instructions provided in the text message or by contacting us on 01525 244200, or by emailing us at zeusfinancialservices@connellsgroup.co.uk

11.4 Telephone

We will only contact you by phone for promotional reasons if you explicitly select to receive these (you opt in). You can opt out of receiving promotional telephone calls from Zeus Financial Services Limited by informing our telephone agents or by contacting us on 01525 244200, or by emailing us on zeusfinancialservices@connellsgroup.co.uk

12. Your statutory rights

You have a number of rights concerning the personal information we use. These include the right to:

• ask us for access to a copy of your personal information we hold about you
• ask us to correct your personal information
• ask us to delete your personal information

You can delete your online account at any time. This will delete any personal information in your account that we have about you, and it will mean any data about how you’ve used the online account will be made anonymous.

However, deleting your online account will not delete any data you’ve shared with us for reasons that are not connected with your online account. If you wish us to delete your data which is unconnected with your online account, please contact us as described below

• withdraw your consent to use your personal information

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data in relation to good or service we are still contracted to provide

If you would prefer not to receive information from Zeus Financial Services Limited or carefully selected third parties you can opt out by contacting us on 01525 244200, or by emailing us on zeusfinancialservices@connellsgroup.co.uk

We will act to respond to your request to stop receiving promotional email, phone, text or postal messages from Connells Group as quickly as is practicable (around 10 working days, as systems take time to replicate). We will keep information for record keeping purposes, to ensure we fulfil your request not to send particular types of messages.

• ask us to restrict the use of your personal data, including direct marketing
• object to our use of your personal data
• object to an automated decision, including profiling (for example, in terms of credit risk)
• lodge a complaint with the Information Commissioner’s Office, if you object to the way we use your personal information. For more information please go to www.ico.org.uk

If you wish to make a request for access to a copy of your personal data, please write to the Connells Group at Group Legal Services, Bridgegate House, 5 Bridge Place, Lower Bridge Street, Chester CH1 1SA or email DSAR@connells.co.uk

If you wish to exercise any of your other rights, please write to the Connells Group Data Protection Officer at Connells Group, Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN or e mail DPO@connellsgroup.co.uk

We will acknowledge your request and let you know what we will need from you to carry out your request. Every effort will be made to respond to or comply with your request as quickly as possible, and we will ensure our systems are updated as soon as is practicable in response to your request.

13. Our use of cookies

A cookie is a small file placed on your device when you visit a website that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and to store your preferences when using a particular site. It may contain a unique identifier to ensure that you are not shown the same information and/or are only shown information you have stated that you are interested in.

Our security software may use your IP address and browser version to help protect our systems and provide diagnostic information in the case of an issue.

14. How we protect your information

We store your personal information on our computer systems and in our paper records. We have implemented strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information.

The information that we collect is stored in a secure facility with restricted physical access.We also use a number of security measures to prevent electronic access.Where - in line with this Privacy Notice - information is shared with third parties, similar security measures are used to protect your information.

15. Data Transfers

If we need to transfer data outside the European Economic Area (EEA) and the country it’s transferred to is not on an approved list for having adequate security controls in place, we will limit when we do this and the amount of personal data we send. We will also ensure that there is adequate protection in place before sending anything to other countries outside the EEA by imposing contractual obligations on the recipients to ensure the security and confidentiality of your data.

16. Children’s privacy

We do not offer any products or services to children. In certain circumstances (for example a mortgage application) we may need to collect the name and date of birth of children from mortgage applicants, and share this with the selected mortgage provider.

17. Links to other websites

Our websites, other electronic portals and documentation may provide links to other websites for your convenience and information. These may operate independently from us and have their own privacy notices or policies, which we strongly suggest you review.

Where linked websites are not owned or controlled by us, we are not responsible for their content or data privacy practices.

18. Our Promise to you

When you provide us with this information, you agree to the collection, use and sharing of your information in accordance with this data privacy notice. Our promise to you is that

• We’ll work with other businesses to put together offers we think you might like
• You are in control of your data
• You can change your privacy settings at any time
• If you don’t think the data is correct tell us and well put it right
• We will keep your data secure
• We also promise to collect, process store and share your data safely and securely and to make sure the businesses we work with do the same

19. Updates to our Privacy Notice

We will occasionally update our Privacy Notice, so we suggest that you review this Notice from time to time. If we make substantial changes to our Privacy Notice, we will endeavour to inform you directly about these changes.