Customer Privacy Notice

Clearpath Mortgages and Protection (our Firm, we, our, us) an Appointed Representative of PRIMIS Mortgage Network a trading name of Personal Touch Financial Services Limited (Our Network)

Why are we asking you to read this document?

During the course of dealing with us we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Information). We would like to explain to you what we will need to do with Your Information, and the various rights you have in relation to Your Information.

What do we mean by "Your Information"?

Your Information means any information describing or relating to you. Your Information may identify you directly, for example your name, address, date of birth, National Insurance number and the like. Your Information may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your mortgage and/or insurance requirements Your Information may include:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports
• Any pre-existing mortgage and/or insurance products and the terms and conditions relating to these

The basis upon which our Firm will deal with Your Information

When we speak with you about your mortgage and/or insurance requirements we do so on the basis that a contract for the supply of services is in place between us. In order to perform that contract, and to arrange the products you require, we have the right to use Your Information for the purposes we set out below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Information provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Network relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Information to enable us to meet any contractual responsibilities we may owe our Network, or for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Information

Where you ask us to assist you with your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently our Network) will record information on our systems that relates to those children and potentially, to their Special Data.

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 (together "Criminal Disclosures"). This is relevant to insurance related activities such as underwriting, claims and fraud management.

Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as set out in this Customer Privacy Notice.

When we process your Special Data and 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 and as permitted by UK data protection related laws and regulations from time to time.

How do we collect Your Information?

We will collect and record Your Information from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to mortgages and insurance. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll.

What happens to Your Information when it is disclosed to us?

In the course of handling Your Information we will record and store Your Information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by our Firm as necessary to provide our service to you. We will also submit Your Information to mortgage lenders and/or insurance product providers in order to progress any enquiry or application made on your behalf.

Sharing and transferring Your Information

From time to time Your Information will be shared with our Network, mortgage lenders and insurance providers, and third parties who we believe will be able to assist us with your enquiry or application. This sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you.

The basis upon which our Network will deal with Your Information

Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you. In the course of doing so, our Network will also process Your Information generally, including Your Special Data and Criminal Disclosures. Your Information will be retained by our Network for a minimum of six years.

Please note that the above information is a summary of the Network Privacy Policy for customers. If you wish to understand in more detail what the Network will do with Your Information then please visit the Network Privacy Policy for customers located at https://www.primis.co.uk/index.php/terms-and-conditions/

Security and retention of Your Information

Your privacy is important to us and we will keep Your Information secure in accordance with our legal responsibilities. Your Information will be retained by us for a minimum of six years, or if longer than six years, the duration of this Firm's relationship with you.

Your rights in relation to Your Information

• Request copies of Your Information that is under our control
• Ask us to further explain how we use Your Information
• Ask us to correct, delete or require us to restrict or stop using Your Information
• Ask us to send an electronic copy of Your Information to another organisation
• Change the basis of any consent you may have provided

How to make contact with our Firm

If you have any questions or comments about this document, or wish to make contact please contact:

Daniel Cooper
Flat 1, Ombersley Court
Holt Fleet Road
Ombersley
WR9 0HH

daniel@clearpathmp.com
07718131916

If you have any concerns or complaints as to how we have handled Your Information you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.