Customer Privacy Notice
Hypo Financial (our Firm, we, our, us) is an Appointed Representative of PRIMIS Mortgage Network a trading
name of First Complete 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 or 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 (further details are provided
below specifically with regard to the processing we may undertake in relation to this type of information)
• 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
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.
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. We will take reasonable steps to safeguard against Your Information being accessed
unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.
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 sent to us.
Your Information will be retained by us either electronically or in paper format 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
THE RIGHTS MARKED WITH A * ARE EFFECTIVE FROM 25 MAY 2018
• 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 (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 Information 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)
How to make contact with our Firm in relation to the use of Your Information
If you have any questions or comments about this document, or wish to make contact in order to exercise any
of your rights set out within it please contact: firstname.lastname@example.org
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have
requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised
disclosure of Your Information, 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 Information or Your Special
Data/Criminal Disclosures 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.