Why should you 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 Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, National Insurance number. Your Personal Data 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 Investment/Mortgage/Finance and/or Insurance requirements Your Personal Data may include:
The basis upon which our firm deal with your personal data
When we speak with you about your investment/mortgage/finance and/or insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed 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 Personal Data 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 Compliance Service Provider 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 Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data 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 personal Data
Where you ask us to assist you with for example your insurance / ethical investments, 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 / investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we 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.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect You Personal Data?
We will collect and record Your Personal Data 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 investment/mortgages/finance and insurance (delete as appropriate). 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. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
From time to time, Your Personal Data will be shared with:
· Investment Providers/Mortgage lenders/Finance lenders and insurance providers (delete as appropriate)
· Third parties whom we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your investment/mortgage/finance and/or insurance (delete as appropriate) enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area. (delete if not appropriate)
Security and retention of Your Personal Data
Your privacy is important to us, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password-protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have a legal right to such information we will retain records indefinitely.
Your Rights in Relation to Your Personal Data
You can:
· request copies of Your Personal Data that is under our control
· ask us to further explain how we use Your Personal Data
· ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
· ask us to send an electronic copy of Your Personal Data to another organisation should you wish
· change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
If you have any questions or comments about this document or wish to make contact to exercise any of your rights set out within it, please contact:
Soul Mortgages Ltd is an appointed representative of Acer Consultancy Services Ltd, which is authorised and regulated by
If we feel we have a legal right not to deal with your request, or to action, it in a different way than how you have requested, we will inform you of this at the time.
You should also contact us as soon as possible upon your becoming aware of any unauthorised disclosure of Your Personal Data so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data, 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.
Data Subject Consent Form
I hereby grant Soul Mortgages Ltd permission to process my data for the purpose stated in the Privacy statement above.
Signed:
Print Name: Date:
Marketing Consent
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Important Information About Our Services
Soul Mortgages Ltd
Address: 167-169 Great Portland Street, 5th Floor, London W1W 5PF
Telephone: 0207 993 4210
Email: enquiries@soulmortgages.co.uk
Website: www.soulmortgages.co.uk
Our Mortgage and Insurance Services & Costs
What can we do for you?
Our mainstream service is to act on your behalf to arrange and advise on the following:
· Personal & Family Protection, for example, a Life Assurance or Critical Illness Plan.
· Mortgages, including Buy-to-Let.
· Bridging, Development & Commercial Finance.
· General Insurance, for example, Buildings, Contents or Private Medical.
For all the services described above, we will complete a detailed fact find to understand your circumstances, specific needs, and objectives to determine if these services suit you. We will then undertake research to provide a personal recommendation(s) and related information relevant to your circumstances. If, after due consideration, you would like to accept any of our recommendation(s), we will implement them and arrange any products and/or related services on your behalf.
Further details about these and other related services we provide are contained in the pages below. This also confirms the typical cost of our services and how we get paid for them.
The Financial Conduct Authority
Soul Mortgages Ltd is an appointed representative of Acer Consultancy Services Ltd, authorised and regulated by the Financial Conduct Authority. The FCA regulates financial services in the UK, and you can check our authorisation and permitted activities on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register.
Soul Mortgages Ltd Financial Services Register is 462302, and Acer Consultancy Services Ltd Financial Services Register is 750786.
Our Services
For Mortgages, we are independent mortgage advisors; we will recommend a suitable mortgage product for you following an assessment of your personal needs and circumstances. This will include a detailed assessment of affordability.
We will consider all products and lenders that we have access to. This means you will not view those lenders only available by going directly to them.
Where you are increasing your borrowing, we will consider the merits of a new first-charge mortgage and secure this with an additional mortgage on a second-charge basis. In addition, you may have the option of a further advance from your existing lender. However, we will only consider this where we can deal directly with the lender on your behalf.
It may be in your best interests to explore this option and look at the alternative of an unsecured loan, as these may be more appropriate for you.
We are an intermediary for protection and insurance contracts and will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and confidential analysis of insurers for term assurance, income protection, critical illness building and contents, private medical insurance, accident sickness and unemployment.
How much will you have to pay for our mortgage services?
You will pay for our services with one of the following options: to be agreed upon in the client agreement:
Mortgages
· We will not charge you a fee for the Services. This option is for existing clients for product transfers and standard re-mortgages and at our discretion.
·
An admin fee of £495 - £995 is payable when
you apply for a mortgage. This is our typical fee for straightforward cases.
The admin fee is held on account indefinitely until a transaction is completed
and is non-refundable.
· For more complex cases, for example, those involving adverse credit, debt consolidation, private banking services, property portfolio purchases and transfers, a fee of up to 1% of the loan will apply. This fee becomes payable when the mortgage offer is produced. In addition, we will request an initial admin fee payment of up to £995 with a typical admin fee of £495, which becomes payable upon submitting your application to the lender. The admin fee may be in addition to the broker fee or deducted from the initial broker fee amount. The exact amount depends on the case’s complexity and the sums involved.
E.g., £100,000 mortgage, 1% = £1,000 advice/application fee + £495 admin fee =
total fee £1,495,
or
£100,000 mortgage, 1% = £1,000 total fee – £495 admin fee = £505 advice/application fee.
These are given as examples only, do not constitute an exhaustive list, and will depend on individual client circumstances.
· If you proceed with our recommendation and the mortgage goes ahead, we will also be paid a commission from the lender for arranging the mortgage on your behalf.
· The amount of commission we receive varies from lender to lender. Information about the range of commissions available from the mortgage products we recommend is available on request.
· If you apply for a mortgage that does not go ahead, you will receive no refund. However, any administration fees charged will be kept on the account and put towards the following application if the initial application cannot proceed.
· You will receive a personalised illustration when considering a particular mortgage. This will highlight the key facts about the mortgage product, including any fees relating to it and the amount of any commission due to us from the mortgage lender.
Refund of fees
Please note that our fee will still be charged should the lender reject your mortgage application due to you not disclosing any material information about your situation. It should also be noted that we do not provide a refund should you decide not to proceed with the mortgage loan after we have made the recommendation.
Non-Investment Protection and General Insurance Contracts
We do not charge a fee, as we will receive a commission from the provider/insurer after the policy has been placed on risk.
Our Ethical Policy
We are committed to providing the highest standard of advice and service possible. However, the interest of our customers is paramount to us, and to achieve this, we have designed our systems and procedures to place you at the heart of our business. In doing so, we will:
Cancellation rights
Specific protection and insurance contracts allow you to cancel after an agreement has been put in force. Before you enter a contract of protection or insurance, we will provide you with specific details should this apply, including its duration, conditions, practical instructions and any costs for exercising it, and the consequences of not exercising it.
Instructions
We prefer our clients to give us instructions in writing to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided and asses how to continue.
Client Verification
We may be required to verify our clients' identities, obtain information about the purpose and nature of the business we conduct on their behalf, and ensure that the information we hold is up to date. For this purpose, we may use electronic identity verification systems and conduct these checks from time to time throughout our relationship, not just at the beginning.
Law
This agreement is governed and shall be construed by the Law of England, and the parties shall submit to the exclusive jurisdiction of the English Courts.
Force Majeure
Soul Mortgages Ltd shall not be in breach of this Agreement and shall not incur any liability to you if there is any failure to perform its duties due to circumstances beyond its control.
Termination
The authority to act on your behalf may be terminated without penalty by either party giving seven days’ notice in writing to that effect to the other, but without prejudice to the completion of transactions already initiated. Any trades effected before termination and a due proportion of any period charges for services shall be settled to that date.
Special category information
Sometimes, it is necessary to collect more sensitive information (such as health or lifestyle information) called “special” category data. This is to allow us to provide our financial advice service to you. We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely. You can withdraw your consent at any time to us processing this data. However, this may mean that you can no longer access the service or product the information was gathered for.
Cookies
We also collect information about you from other sources. For example, our website automatically contains information from your computer using “cookies, “providing us with limited personal information. Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work or work more efficiently, as well as to provide information to website owners. For further information, visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, some of our website features may fail to function in a few cases.
Complaints
If you wish to register a complaint if Soul Mortgages Ltd is unable to resolve an issue, please write to
Acer Consultancy Services Ltd
46 Camden Road London NW1 9DR
or telephone 0203 957 8996.
A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them at 0800 023 4567.
Compensation Scheme
If you make a complaint and we are unable to meet our liabilities, you may be entitled to compensation from the Financial Services Compensation Scheme.
Further information about the limits applicable to the different product types is available from the FSCS at http://www.fscs.org.uk/what-we-cover/products.