Harbour Equity Release is a trading name of Equity Release Associates Limited, which is authorised and regulated by the Financial Conduct Authority. FCA registered number 932793.
This privacy notice explains how we use any personal information we collect about you. It relates to Age Partnership Group Limited and all subsidiaries, including Equity Release Associates Limited (collectively referred to as “Age Partnership”).
What information do we collect about you?
We collect information about you when you engage with us. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete survey forms or use website calculators provided by Age Partnership, when you provide feedback to us, or we may obtain information from referrals made by authorised third parties or from publicly available information.
Information relating to usage of our website is collected using ’cookies’. These are text files placed on your computer to collect standard internet log information and visitor behaviour information.
We may use your information collected from the website to personalise your repeat visits to the site.
How will we use the information about you?
We will process your data in order to fulfil our contract with you when you enquire about or purchase a service from us.
If you enquire about our services through our calculators or forms on our websites, we will use the information you provide to contact you and provide further information about our various products and services.
We may combine data captured from across our group as well as overlay additional demographic and lifestyle data from publicly available and other authorised sources, to help us understand your circumstances and needs for marketing and insight purposes. This will help us personalise the content we share with you with the aim of making it more relevant to you.
Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In certain specific situations we will collect and process your data with your consent. For example, before you submit your email contact details when using our online forms.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Where special category data is required, for example details about your health, we’ll always obtain your explicit consent in order to collect and process this information.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively.
Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
For example, in order to provide you with suitable equity release advice, we need to gather information about your current financial circumstances.
Legal/Regulatory compliance
If the law requires us to, we may need to collect and process your data.
For example, where we identify fraud or other criminal activity we will pass on personal data to relevant law enforcement agencies.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
When we process your personal information for our legitimate interests, we make sure to consider the balance and any potential impact on you (both positive and negative) and your rights under the data protection regulation.
Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Our legitimate business interests may include some or all of the following:
Who might we share your information with?
We won’t share your information for marketing purposes with organisations outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for printing services, professional accountancy or legal services, as well as product providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
At the end of any retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Your rights
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is kept accurate and up to date.
Please ask us to correct or remove any information that you think is incorrect.
Opt-out policy
If, at any time after registering, you change your mind about receiving our postal/email offers or sharing your information with third parties you can write to us at the following address: Equity Release Associates, 2200 Century Way, Thorpe Park, Leeds, LS15 8ZB, alternatively you can email eraenquiries@equityreleaseassociates.com.
Correcting/update
If you would like to correct and/or update your registration information you can write to us at the following address: Equity Release Associates, 2200 Century Way, Thorpe Park, Leeds, LS15 8ZB, alternatively you can email info@equityreleaseassociates.com.
Cookies
We may use cookies to track visitor use of the website and to compile statistical reports on website activity. Further details can be found in our cookie policy.
For further information about cookies visit https://ico.org.uk/for-the-public/online/cookies/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser.
However in a few cases some website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection.
In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Changes to our privacy notice
We keep our privacy notice under regular review and we’ll place any updates on this web page. This privacy notice was last updated on 17/05/2018.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you by email at info@equityreleaseassociates.com
Or write to us at
Equity Release Associates, 2200 Century Way, Thorpe Park, Leeds, West Yorkshire, LS15 8Z
We’re here to help you decide if releasing equity could get the things you want out of later life.
