Privacy Policy

Kingsgate Law Limited is a mortgage and protection broker firm. We are committed to maintaining the trust and confidence of our clients. We take your privacy seriously and take every reasonable precaution to safeguard the personal information you provide to us. As the controller of the personal information you provide to us, we comply with UK Data Protection Laws and the EU General Data Protection Regulation (GDPR)

We are registered with the Information Commissioner's Office (ICO), registration Number: Z8114489.

You can check our registration details on the ICO Register here

1. Why we collect your personal information
Our Services

We collect and process your personal data as it is necessary for the performance of our services, enabling us to provide you with financial advice and recommendations, and to apply for mortgage and protection products on your behalf.

We will also use your personal information as part of our ongoing service to:

  • Carry out reviews on your existing and future mortgage and protection needs
  • Provide customer support
  • Respond to enquiries and complaints
2. What personal information do we collect and how do we collect it?

As your mortgage and protection broker, and to give you the best service possible, we need to ask you for personal information. This will include:

  • IDENTITY INFO: Your name, address and date of birth;
  • PERSONAL FINANCIAL INFORMATION: this could include your employment information; your pay slips; any benefits you have through an employer; bank, credit card and mortgage statements; your income & expenditure details; details of your liabilities for example loans hire purchase, credit cards, your credit file information.
  • SENSITIVE PERSONAL DATA: such as medical history for protection products
  • OTHER INFORMATION: to support any application to a lender or protection provider and confirm your identity (e.g.UK residency status, passport or driving licence details, your retirement age)
  • CONTACT INFORMATION: Home address; Home and Mobile phone number; Email address.
  • TRANSACTION DATA: including your card or bank account details for making payments to us for products and services provided such as any broker fee.

We mainly collect this information through our mortgage and protection advisers during a face to face meeting with you, or by telephone, or by email. We collect information through our website or Facebook pages if you click on the "Enquire" or "Contact Us" options.

We may also collect personal information from our appointed representative firms, to whom we delegate our financial services permissions to allow them to provide their customers with mortgage and protection advice. We monitor the advice these firms provide to their customers and provide additional services including commission payments and complaint handling.

We may also collect information from introducers (such as estate agencies or financial lead suppliers) or individuals who recommend you to us. This will normally only be your contact details, but you should check that these introducers have your permission to give us your information.

3. How we use your personal information - our lawful grounds for
obtaining and processing your personal information

When we request and process your personal information, we make sure we comply with the data protection laws to do so. Under GDPR, there are defined conditions that we must comply with in order to lawfully obtain, process and retain your personal information. We process your personal information using the following lawful purposes:

Our contract with you: Our advisers will provide you with and explain our Terms of Business letter. This explains the services we provide, to recommend and apply for mortgage and protection products on your behalf. It also explains that we may contact you at regular periods to review your existing products and check they remain suitable or to recommend new products to you.

Our legal obligation We may process your personal information because we have a legal responsibility to do so. For example, we have to comply with financial crime and money laundering regulations.

Our legitimate interests: A legitimate interest is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is

Your Consent: We will seek your consent for the following additional purpose- Marketing - To help you identify your options, from time to time we'd like to let you know about any new or additional products and services.

In most circumstances, you'll provide the information detailed in section 2 because you want to use our services, to recommend and obtain mortgage and protection products for you. It is your choice to give us this personal information and without it, we would likely be unable to perform the services you request from us.

The following table confirms what our lawful conditions for processing your personal information are.

What we use your personal information for Our lawful reasons for use Definition of our Legitimate Interest
To advise, recommend and submit your application for a mortgage or protection product Our contract with you
To manage our ongoing relationship with you;
To contact you and review your ongoing mortgage and protection needs with you at regular intervals;
Our contract with you
To respond to queries, investigate and resolve complaints and disputes;
To comply with our regulators;
To detect and help prevent financial crime and money laundering;
To prove your identity
Our contract with you
Legitimate Interest
Legal Obligation
Necessary to comply with our regulators, governing bodies and to meet our obligations with helping prevent financial crime
Protecting and running our business including maintaining records, administrative purposes, staff training, systems maintenance Legitimate Interest
Legal Obligation
Necessary for running of our business and providing administrative and technical Support services
Marketing - telling you about additional products, services and offers Your Consent (see section 4 below)

4. Your personal information and marketing - Your Consent

Whilst we may contact you at regular intervals to discuss your ongoing mortgage and protection needs under our contract with you and our legitimate interests, we may also contact you to let you know about additional financial services, products or offers. This is what we term "marketing" and we will not do so without your consent. Our advisers will update your marketing consent preferences at every meeting with you.

Where we process your information by consent, you can choose not to receive marketing communications from us at any time by withdrawing your consent. You can do so by contacting us via any of the methods detailed in section 9 below.

5. Who do we share your personal information with?

As your mortgage and protection broker, we may share your personal information with lenders and protection providers in order that we can provide our services to you.

We may share your personal information with our third-party specialist partners where we do not provide advice on the products you require. We will only do so with your consent.

We may share your personal information with fraud prevention, financial crime agencies and financial services regulators such as the Financial Conduct Authority, enabling us to fulfil our obligations with respect to preventing crime and investigating queries or complaints.

We may share your information with our service and support providers including specialist IT providers. These assist us to provide you with recommendations, to source for suitable products, to store your information as required legally by our regulators or governing bodies, and to be able to respond to enquiries or complaints.

We may share your information with third parties to whom we may choose to sell, transfer, or merge parts of our business. We may in the future set up a new business or acquire or merge with other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

6. For how long will we retain your personal information

We'll keep your personal information stored securely for as long as we need it to provide you with our services, to assist with resolving any queries or complaints about the service we have provided and to comply with the record keeping requirements of our regulators. For these reasons we may keep your personal information for up to 25 years after the original term of the product you purchased/applied for expires.

Where we have collected your information and not progressed to a recommendation, we will retain your information for 2 years.

We may keep your data for longer than this if we cannot delete it for legal, regulatory or technical reasons.

7. Access to your personal information - Your rights

Right to be informed: You have the right to be informed about how we collect and use your personal information. We explain this in our Privacy Notice.

Right of access: You have the right to access your personal data and supplementary information. The right of access also allows you to be aware of and verify the lawfulness of the processing.

Right to rectification: You can ask us to have inaccurate personal data rectified or completed if it is incomplete.

Right to erasure: Also known as 'the right to be forgotten,' you can ask us to have personal information erased, removed or to stop using your personal information. This right is not absolute and only applies in certain circumstances. We may have legal or other reasons why we need to keep or use your data.

Right to restrict processing: You have the right to request the restriction or suppression of your personal information. This is not an absolute right and only applies in certain circumstances. We may have legal or other reasons why are unable to restrict the use of your personal information.

Right to data portability: This right allows you to obtain and reuse your personal data for your own purposes across different services. This right only applies to information you have provided to us and when:

A) our lawful basis (see section 3) for processing this information is consent or for the performance of a contract; and

B) are carrying out the processing by automated means (i.e. excluding paper files)

Right to object: You have the right to object to us keeping or using your personal information, where processing is based on our legitimate interests or direct marketing. If you choose to do so we may be unable to provide you with our services, as processing your personal information is necessary for us to be able to assess your eligibility and make recommendations for mortgage and protection products.

Rights in relation to automated decision making and profiling: We do not use your personal information to make automated decisions or engage in profiling. As part of our service to you we may pass your information to lenders or providers who do make automated decisions or engage in profiling. You should contact these providers direct in order to exercise this right for how they use your information.

To exercise any of your rights detailed above you can contact us as detailed in section 9.

8. How we keep your personal information secure

Kingsgate Law understand how important it is that we keep your personal information secure. We use a variety of procedures to protect your private information from being accessed, used or disclosed in any way it shouldn't be. The processes we've put in place include organisational and technological controls such as:

Data protection policies and standards; staff training and awareness; password and encryption protection of customer documents; secure archiving and destruction procedures

As detailed in section 5, where we have to share your information with third parties to carry out some of our services, we require those third parties apply appropriate security safeguards and comply with the required standards for protecting personal information.

9. Who do I contact for further information

If you have any queries or complaints about how we handle your person information you can contact us at:

Email: dataprotection@kingsgatelaw.com

Tel: 01224 611611

Alternatively, you can write to us at:

Data Protection
Kingsgate Law Limited
Citrus House
Greenbank Road
Aberdeen
AB12 3BQ

If you're still unhappy with any aspect of how we use your personal information, you also have the right to contact the Information Commissioner's Office (ICO). This is the authority that regulates handling of personal information in the UK. You can contact them as below:

ICO Website: https://ico.org.uk

Tel: 0303 123 1113

Write to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

10. Changes to our Privacy Notice

We will regularly review our Privacy Notice. You can see our latest notice on our website www.kingsgatelaw.com

We last updated our Privacy Notice on 15/01/2019