Advantage Financial Solutions – Privacy Notice
The type of personal information we collect
We currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name and contact details);
- Financial information (for the purpose of combating fraud and money laundering);
- Health and medical information (for the purpose of providing insurance advice);
- Property informant (for the purpose of mortgage underwriting);
- See our website privacy policy for details of information collected by our website.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- Mortgage advice, assessment/qualification and underwriting;
- Insurance advice, assessment/qualification and underwriting.
This information is collected on a ‘contractual’ basis to assist us with providing you with a mortgage and protection advice service.
We also receive personal information indirectly, from the following sources in the following scenarios:
- Lenders – Will provide us with necessary information to assist in providing advice, establishment of a lending product or the ongoing servicing of our customers;
- Insurers – Will provide us with necessary information to assist in providing advice, establishment of an insurance product or the ongoing servicing of our customers.
We use the information that you have given us in order to provide you with mortgage and/or insurance advice.
We may share this information with:
- Lenders (the specific lenders approached will be disclosed to you during the advice process);
- Insurance companies (the specific insurers approached will be disclosed to you during the advice process);
- The Financial Conduct Authority (regulatory purposes);
- The Information Commissioner’s Office (law enforcement);
- National Crime Agency (Law enforcement)
- Other law enforcement bodies (law enforcement);
- Customer Relationship Management and Product Sourcing Systems (day to day processing of your data).
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- We have a contractual obligation;
- We have a legal obligation;
- We have a legitimate interest.
How we store your personal information
Your information is securely stored in electronic format using our customer relationship management system, The Key.
Additionally, we also make use of market leading product sourcing technology provided by Mortgage Brain and iPipeline.
We keep the above personal information for as long as is necessary to fulfil our regulatory and legal responsibilities. This means that we will retain your information for as long as you are legally able to file a complaint or as long as we have a legal obligation to do so under Anti-Money Laundering legislation. We will then dispose your information by permanently deleting from our files.
Your data protection rights
Under data protection law, you have certain rights; including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Post – How we handle your sensitive personal data
It is unlikely that you will ever need to post any documentation to us.
Occasionally it may be necessary for you to post supporting documents to us, these documents may
contain sensitive personal information and will be treated with the utmost care upon receipt. All
information received by post will processed the same day in concordance with General Data
Protection Regulation.
If you have posted original documents, these will be processed and returned by recorded delivery to
your correspondence address within 48 hours of receipt. Where we have received copies or printed
documents we will process and destroy the document unless you specifically request the documents
are returned to you.
Who will have access to this data?
This data can be accessed by members of Advantage Financial Solutions Ltd, our provider partners
and also by partners we engage with for the purpose of ensuring we are operating within our
regulatory responsibilities.
Your rights to our processing of your data
Under the General Data Protection Regulation, you have the following rights:
-The right to know if we are processing your personal data, what data we are processing and why we
are processing it- which we have detailed above.
-The right to access confirmation that we are processing your data and access the personal data we
hold for you. The way to request this information is detailed in the ‘Subject Access Requests’ section
of this policy.
-The right to request correction of any inaccurate personal data that we process relating to yourself.
This can be requested in writing using the contact details listed in the ‘Who We Are’ section of this
policy.
-The right to obtain and reuse your personal data for your own purposes across different services.
-The right to object to processing based on legitimate interests or the performance of a task in the
public interest/exercise of official authority (including profiling), direct marketing (including profiling)
-The right to request that we delete personal data that we process relating to you if:
- We no longer need the data
- If you withdraw your consent for us to process your personal data and we don’t have another legal basis to hold this data
- If you object to our processing and we don’t have a legitimate ground to process it
- If we are processing your personal data unlawfully
- If we must delete the data due to a legal obligation
The right to request that we restrict our processing of your personal data if:
- You contest the accuracy of the data
- Our processing is unlawful but you don’t want us to delete the data
- We don’t need to process your personal data anymore but you need it for a legal claim
- You object to our processing of your personal data on the basis of our legitimate interest
If you wish to enact any of these rights, please contact us using the details found on the ‘Contact us’ page. For further information on these rights, please visit the ICO website.
Subject Access Requests
You may request a copy of the information we hold for you through a subject access request. This can be done by contacting us using the details listed in the ‘who we are’ section, detailing which information you would like access to. There is usually no cost, and which will be complied with within 1 month. Where the request is considered to be manifestly unfounded or excessive, we may charge administrative costs or refuse the request. If you are unhappy with the response from Advantage Financial Solutions Ltd, and this cannot be resolved directly by contacting us, please contact the Information Commissioners Office.
What to do if you have a complaint about our service:
If you wish to register a complaint, please contact:
…in writing: Advantage FS, The Carriage Works, London Road, Bridgeyate, BS30 5NA
…email: info@advantagefs.co.uk
…by phone 01174420604
A summary of our internal complaints handling procedure is available on request. If we cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
What we’ll need from you if decide to make a complaint
It’s important provide us with as much information as possible when making your complaint. Please include:
- Your name and address
- Phone number
- A description of your complaint and how it has affected you
- A timeline of events
Why do we need this information?
This helps the complaint handler to investigate and resolve the matter effectively. We want to get things back to how they were before you approached Advantage FS.
What happens with your complaint?
- Acknowledgment and Initial Assessment – Update within 3 working days of receipt. We’ll also let you know about the Financial Ombudsman service and how they can support you.
- Full Assessment – We have 56 days to resolve the matter however we will aim to resolve all complaints as quickly as we possibly can. We will keep you informed of progress.
- Findings – We’ll send a final response by email or post where requested which details our findings. If you are still unhappy with the result then you can escalate the complaint to the
Financial Ombudsman Service. Contact details for the Financial Ombudsman Service
- Freephone 0800 023 4567
- Visit the website and fill out the online form
- Write to Exchange Tower, Harbour Exchange, London E14 9SR
- Email: complaint.info@financial-ombudsman.org.uk
Although you can refer your complaint to the FOS at any time, they’ll ask for our permission to investigate complaints where you haven’t complained to us first. This is to give us the chance to put things right or, you have complained to us, but we haven’t given you our Final Response yet and we’re still within our timescales.
You’ll need to contact them within six months of the date of our final response letter.
Please be aware that some complaints are not eligible to be referred to the Financial Ombudsman Service (for example – enquiries relating to Buy to Let mortgages) and where this is the case, we will inform you of this when we send you our final response.
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Our Website Privacy Policy
Advantage Financial Solutions is a controller of your personal data under the General Data Protection Regulation guidelines. We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, this information will only be used in accordance with this privacy statement.
Who We Are
Name: Advantage Financial Solutions Ltd
Registered Address: Advantage FS, The Carriage Works, London Road, Bridgeyate, BS30 5NA
Contact Email Address: info@advantagefs.co.uk
What information is being collected?
We are collecting information that is provided through our contact form, as well as data collected from cookies on our website.
How will we use information about you that’s been collected on this website?
We process personal information for certain legitimate business purposes, which include some or all of the following:
- By providing this data, you have registered interest in us contacting you using the contact details
- provided to discuss the products and services listed on our website.
- To update and maintain our internal records.
- To track website usage in order to make improvements to the website.
- We may periodically send promotional emails containing information which we feel may be of interest to you using the email address which you have provided. You are able to opt-out of receiving these.
If you have any concerns regarding the opt-out process, please contact us.
To the first person who reads this message and contacts info@advantagefs.co.uk to confirm they have read our privacy policy, we will send a complimentary bottle of wine. The wine (valued at up to £15) will be posted to you. You may specify your preference for Red, White, Rosé, or an alcohol-free variant in your email.
It should be noted that you have no legal or contractual obligation to provide your personal data for the purposes listed above, and there are no consequences to you for this data not being provided
outside of the purposes of the processing listed above not being fulfilled.
This data will not be used for any automated decision making or profiling purposes.
Data Retention
We will retain this data for a period of 12 months for use in the legitimate business purposes listed above.
You may choose to opt out of the processing of your data at any time by contacting us on the details listed in the ‘Who We Are’ section of this policy. We may retain some of your information to ensure that we can keep a record to identify that you wish no further processing of your data to take place, and to comply with any legal and/or regulatory responsibilities we hold.
If any business is transacted with the company, the new data retention period that supersedes any previously agreed retention period will be outlined to you as part of this process, and we will also supply you with the reasoning for this new retention period.
Who will have access to this data
This data can be accessed by members of Advantage Financial Solutions Ltd.
Under the General Data Protection Regulation, you have the following rights:
-The right to know if we are processing your personal data, what data we are processing and why we are processing it- which we have detailed above.
-The right to access confirmation that we are processing your data and access the personal data we hold for you. The way to request this information is detailed in the ‘Subject Access Requests’ section of this policy.
-The right to request correction of any inaccurate personal data that we process relating to yourself.
This can be requested in writing using the contact details listed in the ‘Who We Are’ section of this policy.
-The right to obtain and reuse your personal data for your own purposes across different services.
-The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling)
-The right to request that we delete personal data that we process relating to you if:
- We no longer need the data
- If you withdraw your consent for us to process your personal data and we don’t have another legal basis to hold this data. If you object to our processing and we don’t have a legitimate ground to process it
- If we are processing your personal data unlawfully
- If we must delete the data due to a legal obligation
The right to request that we restrict our processing of your personal data if:
- You contest the accuracy of the data
- Our processing is unlawful but you don’t want us to delete the data
- We don’t need to process your personal data anymore but you need it for a legal claim
- You object to our processing of your personal data on the basis of our legitimate interest
If you wish to enact any of these rights, please contact us.
Our Use of Cookies
Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us for our use only. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products AND services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt e.g. cookie pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully as a result.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Know Your Cookies
All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
Strictly Necessary Cookies
A cookie falls into this category if it is essential to the operation of our website. Strictly necessary cookies may, for example, be required for functions such as logging in, storing items in a shopping basket, or enabling payment transactions.
Analytics Cookies
Understanding how users use our website can be extremely valuable. Analytics cookies provide insights into many factors such as how users are navigating around the site and what features they are using. Analytics cookies may often be set by third parties, but not always.
Functionality Cookies
Many websites offer some level of personalisation and functionality cookies play a key role here. For
auditing purposes, however, it is important not to confuse these with the strictly necessary variety. If the site can be used properly without the cookie, it isn’t strictly necessary.
Targeting Cookies
It is important to know when and how often someone visits our website, and which parts of it they have used (including which pages they have visited and which links they have followed). As with analytics cookies, targeting cookies allow us to better understand our users, enabling us to make our site and, more importantly, the advertising on it more relevant to those users’ interests. Targeting cookies may often be set by third parties.
First-Party Cookies
As the name suggests, these cookies are placed directly by our website (as opposed to those placed by third-party services, for which see below). Most, if not all, of your strictly necessary and functionality cookies will likely be first-party cookies.
Third-Party Cookies
These cookies are placed by third parties providing services such as advertising and analytics.
Analytics and targeting cookies are common types of third-party cookie as such work is often not undertaken in-house.
Persistent Cookies
Any of the cookies listed above may be a persistent cookie. Persistent cookies are those which remain active on a user’s computer or device for a predetermined period of time and are activated when that user visits your website.
Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser. Our website may contain links to third party websites. It should be noted that we do not have any control over these websites and so we are not responsible for the protection and privacy of any information which you provide whilst visiting such sites, which are not governed by this privacy statement. For this information, please consult the privacy statement applicable to the website in question.
Complaints related to data processing
If you are unhappy with the way in which we are processing your data, please contact us directly in the first instance to resolve this issue. If this issue cannot be resolved directly by contacting us, please contact the Information Commissioners Office.
You can also complain to the Information Commissioner’s Office [ICO] if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk
Anti Slavery Policy
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Advantage Financial Solutions Ltd’s slavery and human trafficking statement for the current financial year.
As a responsible UK mortgage broker, Advantage Financial Solutions Ltd’s is committed to acting ethically and with integrity in all our business dealings and relationships. We are dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.
Our Business and Structure
Advantage Financial Solutions Ltd is a directly authorised mortgage and protection brokerage. Our core business involves providing mortgage and insurance advice to retail clients, primarily in the UK residential property market.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships. These include:
- Anti-Slavery Policy: This policy outlines our zero-tolerance approach to modern slavery and sets out the responsibilities of all employees and suppliers in preventing it.
- Whistleblowing Policy: We operate a confidential whistleblowing hotline and encourage all staff and external parties to report any concerns about wrongdoing, including any related to modern slavery, without fear of retaliation.
- Recruitment Policy: We conduct right-to-work checks for all employees to ensure they are legally entitled to work in the UK, helping to safeguard against human trafficking or forced labour.
- Supplier Code of Conduct: This code mandates that our suppliers adhere to the same high ethical standards we set for ourselves, including a strict prohibition on modern slavery.
Our Supply Chains
Our supply chains are limited and primarily consist of:
- Providers of financial technology (FinTech) and customer relationship management (CRM) software.
- Lenders and insurance providers.
- Professional service firms (e.g., legal, compliance, and marketing consultants).
- Office utilities and facilities management providers.
We assess all major suppliers for modern slavery risks and expect them to have suitable anti-slavery policies and processes in place.
Due Diligence Processes
We undertake the following due diligence processes to mitigate the risk of modern slavery in our business and supply chains:
- Supplier Vetting: We conduct risk-based assessments of new suppliers before engaging them.
- Contractual Obligations: Our standard terms of engagement with suppliers include warranties of compliance with the Modern Slavery Act 2015.
- Internal Risk Assessment: We continuously assess the potential for risk within our own operations, which we consider to be low due to our size, location, and sector. However, we remain vigilant.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide relevant training to our staff. This includes making them aware of the signs of modern slavery and the appropriate steps to report potential issues.
Measuring Effectiveness
We use the following key performance indicators (KPIs) to measure the effectiveness of our steps to ensure slavery and human trafficking are not taking place in our business or supply chains:
- Completion rates of mandatory modern slavery training for staff.
- The number of reports made through our whistleblowing procedure relating to modern slavery.
- The number of supplier contracts updated to include modern slavery compliance clauses.