PRIVACY NOTICE & COOKIE POLICY

 

At Rocha Finance Ltd, we are committed to ensuring that the personal information you share with us is treated responsibly. We want you to be confident that the way we collect, use, store and protect your information is appropriate, secure and respectful of your privacy.

This Privacy Notice explains how we collect, use, share and protect personal information relating to our existing and prospective customers and visitors to our website. It also explains your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

 

1. Who we are

For the purposes of data protection law, the data controller is:

Rocha Finance Ltd

The Old Exchange521 Wimborne Road East
Ferndown
Dorset
BH22 9NH

Email: adriana@rochafinance.co.uk

 

ICO registration number:  ZA569362

Rocha Finance Ltd provides mortgage, protection and, where appropriate, general insurance advice and arranging services.

 

2. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our business, the way in which we process personal information, or changes to legal or regulatory requirements.

Where appropriate, material changes will be communicated through our website or other suitable means.

The latest version of this Privacy Notice will apply to the personal information we hold.

 

3. What personal information we collect

The information we collect will depend on the services you ask us to provide and your individual circumstances.

We may collect information including:

• your name, date of birth and contact details;
• your current and previous addresses;
• identification and verification documents;
• nationality and residency information where relevant;
• marital or relationship status and information about dependants;
• employment and occupation information;
• income and other sources of earnings;
• expenditure and regular financial commitments;
• bank account information;
• savings, investments, pensions and other assets;
• mortgages, loans, credit commitments and other liabilities;
• credit history and information relating to affordability;
• details of properties owned or being purchased;
• mortgage requirements and preferences;
• deposit and source-of-funds information;
• existing mortgage, protection and insurance arrangements;
• protection and insurance needs;
• financial objectives, priorities and preferences;
• information provided during fact-finding and the advice process;
• correspondence, emails, meeting notes, telephone notes and other communications with you;
• information required to verify your identity or prevent fraud, money laundering or other financial crime;
• information about complaints or concerns you raise with us; and
• records relating to advice, recommendations, applications and products arranged through us.

 

Health, vulnerability and support information

In some circumstances you may provide us with information relating to your health, disability, communication requirements or other personal circumstances.

You may also tell us about events or circumstances that affect the support you need when dealing with us.

We will only collect information of this nature where it is relevant and necessary.

We may use this information to:

• understand whether you need additional support;
• adapt the way we communicate with you;
• provide information in an appropriate way;
• give you additional time where required;
• check your understanding;
• ensure that our advice takes account of relevant circumstances; and
• help prevent foreseeable harm and support good customer outcomes.

Where this information is classed as special category personal data, we will only process it where permitted under UK data protection law.

 

4. How we obtain your information

Most personal information is provided directly by you.

We may collect information when you:

• contact us by telephone, email or through our website;
• make an enquiry about our services;
• complete a fact-find or questionnaire;
• provide documents to support a mortgage, protection or insurance application;
• attend a telephone, video or face-to-face meeting;
• correspond with us;
• ask us to obtain quotations or research products;
• make an application through us; or
• contact us after your mortgage or policy has been arranged.

Where necessary and lawful, we may also receive information from other organisations or individuals involved in providing services to you, including:

• mortgage lenders;
• insurers and product providers;
• credit reference or identity verification providers;
• fraud prevention services;
• solicitors and conveyancers;
• valuers;
• accountants or other professional advisers where appropriate;
• a joint applicant;
• a person you have authorised to act on your behalf; and
• publicly available registers or sources.

 

5. Information provided through our website

Our website is primarily used to provide information about Rocha Finance and the services we provide.

If you contact us through our website or using contact details provided on the website, we may receive information such as your:

• name;
• email address;
• telephone number; and
• details of your enquiry.

We will use this information to respond to your enquiry and, where you decide to use our services, to begin or manage our relationship with you.

 

6. Links to other websites

Our website may contain links to websites that are not operated or controlled by Rocha Finance Ltd.

Once you leave our website, we are not responsible for the privacy practices or security of other websites.

You should review the privacy information provided by the relevant organisation before submitting personal information through another website.

 

7. Email and electronic communications

We use electronic communication systems to communicate with customers and other organisations involved in mortgage, protection and insurance transactions.

Although we take reasonable steps to protect electronic communications, email and other internet-based communications cannot always be guaranteed to be completely secure.

Where particularly sensitive information or documentation is required, we may ask you to provide it using an appropriate secure method.

Please take reasonable care when sending personal or financial information electronically.

 

8. Who we may share your information with

We will only share your personal information where there is a legitimate and lawful reason to do so.

Depending upon the service you require, this may include:

• mortgage lenders;
• insurers and other product providers;
• mortgage and insurance sourcing or application systems;
• credit reference agencies;
• identity verification and fraud prevention services;
• solicitors and conveyancers;
• valuers;
• accountants or other professional advisers involved in your transaction where appropriate;
• IT, email, document storage, CRM and technology providers supporting our business;
• website hosting and technology providers;
• professional indemnity insurers or legal advisers where necessary;
• the Financial Conduct Authority;
• the Financial Ombudsman Service where relevant;
• law enforcement agencies, courts, government bodies or other authorities where we are legally required to provide information; and
• any other organisation where you have asked or authorised us to provide your information.

Mortgage lenders, insurers and other product providers will normally have their own privacy notices explaining how they process personal information once it has been provided to them.

We will not sell your personal information.

We will not provide your personal information to another organisation for that organisation's own marketing purposes.

 

9. Service providers acting on our behalf

We use third-party organisations to support the operation of our business, including providers of IT systems, email, document storage, CRM systems, website services and other business technology.

Where an organisation processes personal information on our behalf, appropriate arrangements will be used so that information is handled securely and only for authorised purposes.

 

10. Why we use your personal information

We may process your personal information for purposes including:

• responding to enquiries;
• establishing your needs, circumstances and objectives;
• completing fact-finding;
• assessing affordability;
• researching mortgage, protection or insurance products;
• providing advice and recommendations;
• obtaining quotations;
• preparing and submitting applications;
• liaising with lenders, insurers and other parties involved in your application;
• administering and progressing your case;
• providing appropriate ongoing customer support;
• reviewing existing arrangements where appropriate;
• verifying identity and address;
• checking source of funds where required;
• preventing fraud, money laundering and other financial crime;
• identifying and providing appropriate support for customers who may need additional help;
• handling complaints;
• maintaining appropriate business and customer records;
• protecting our business, systems and customers;
• establishing, exercising or defending legal claims; and
• meeting legal and regulatory obligations applying to our business.

 

11. Our lawful bases for processing your information

UK data protection law requires us to have a lawful basis for using your personal information.

Depending upon the circumstances, we may rely upon:

 

We may process information where this is necessary to provide services you have requested or to take steps at your request before providing those services.

 

We may process information where this is necessary to meet a legal or regulatory obligation applying to Rocha Finance Ltd.

 

We may process information where this is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

• operating and administering our business;
• managing our relationship with customers;
• maintaining business records;
• protecting our systems and information;
• preventing fraud and financial crime;
• dealing with complaints and disputes;
• maintaining and improving the quality of our services; and
• protecting our legal rights.

 

Consent

There may be circumstances where we ask for your consent to process particular information.

Where we rely upon consent, you can withdraw that consent at any time.

Withdrawal of consent will not affect any processing which took place lawfully before consent was withdrawn.

Consent is not the only lawful basis on which we process personal information, and withdrawing consent will not require us to delete information which we are legally entitled or required to retain.

 

12. Automated decision-making

Rocha Finance's mortgage and protection advice process involves human assessment and adviser judgement.

We do not currently make decisions about the advice we provide to you based solely on automated processing which produces legal effects concerning you or similarly significantly affects you.

Mortgage lenders, insurers or other product providers may operate their own automated decision-making processes when assessing applications.

Where this happens, their own privacy notices will explain how they use your information and any relevant rights available to you.

 

13. How we protect your information

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Rocha Finance's security arrangements include, where appropriate:

• secure electronic systems;
• secure cloud-based document storage;
• restricted access to client files;
• password protection;
• multi-factor authentication;
• device security;
• encrypted devices or storage where appropriate;
• antivirus and security protection;
• backup and recovery arrangements; and
• access controls limiting information to authorised persons.

Client records are principally maintained electronically.

 

14. How long we keep your information

We will keep personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, regulatory and business requirements.

The appropriate retention period may depend upon:

• the nature of the service provided;
• regulatory record-keeping requirements;
• financial crime and identity verification requirements;
• complaint-handling requirements;
• relevant legal limitation periods;
• professional indemnity requirements; and
• whether an ongoing customer relationship exists.

Once information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate.

 

15. Your data protection rights

Under UK data protection law, you may have rights in relation to the personal information we hold about you.

These include:

• the right to be informed about how we use your personal information;
• the right of access to personal information we hold about you;
• the right to rectification of inaccurate information or completion of incomplete information;
• the right to erasure in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to object to certain processing;
• the right to data portability where applicable; and
• rights relating to automated decision-making and profiling where applicable.

These rights do not apply in every circumstance.

For example, we may need to retain information where there is a legal or regulatory requirement for us to do so.

If you wish to exercise one of your rights, please contact us using the details in Section 19.

 

16. Marketing

We do not sell your information or provide it to third parties for their own marketing.

Where Rocha Finance sends direct marketing communications, we will only do so where permitted by applicable data protection and electronic communications law.

Where your consent is required, we will obtain it before sending the communication.

You may ask us to stop sending direct marketing communications at any time.

Service-related communications about an enquiry, application, mortgage, policy or existing customer relationship are not treated as direct marketing.

 

17. Complaints about the use of your information

If you have concerns about how Rocha Finance Ltd has collected or used your personal information, please contact us so that we can investigate.

You also have the right to complain to the Information Commissioner's Office (ICO).

The ICO is the UK's independent regulator for data protection.

You can obtain further information about your data protection rights or make a complaint through the ICO's website:

www.ico.org.uk

ICO telephone: 0303 123 1113

 

18. Cookies

Cookies are small text files placed on your computer, tablet or other device when you visit a website.

Our website may use cookies that are necessary for the website to operate correctly.

Where optional cookies, such as analytics cookies, are used, we will obtain consent where required before setting them.

You can also control or delete cookies using your browser settings.

Blocking some cookies may affect the way some parts of a website operate.

The cookies actually used by the Rocha Finance website should be identified in the website's cookie settings or Cookie Notice.

 

19. How to contact us

If you would like further information about this Privacy Notice, wish to exercise a data protection right, or wish to raise a concern about how your personal information has been handled, please contact:

Adriana Rocha

Email: adriana@rochafinance.co.uk

Telephone: 01202 006355