Privacy Notice

Who we are

Generation Home (trading name of Imagine Mortgages Limited) registered in England and Wales (registration number: 11465987) with our registered office at Exmouth House, Unit 100 3-11 Pine Street, London, England, EC1R 0JH.

We are registered with the Information Commissioner’s Office under number ZA523493.We would appreciate if you could please read the following information carefully.

If you then have any questions about how we handle your personal information please contact us through our web chat or by email at [email protected], or by writing to us at Data Protection Officer, Exmouth House, Unit 100 3-11 Pine Street, London, England, EC1R 0JH.

Introduction

We are committed to protecting and respecting your privacy, being completely open and transparent in the way we collect or obtain your personal information and how we use that information.

For the purposes of EU data protection legislation 2016/679; together with all other applicable legislation relating to privacy or data protection, we are a data controller in respect of the information that we collect or obtain about you. This is because we determine why and how your personal information is processed and used.

The personal information we have collected from you may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering, and to verify your identity. If fraud is detected, you may be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found in this policy.

Personal information we may collect from you and how we obtain it

We collect and process various categories of personal information at different stages. This may include:

  1. basic personal information such as your name, address, date of birth, contact details, visual image and personal appearance,
  2. financial information, including account and transactional information, personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history,
  3. information about your family, lifestyle and social circumstances,
  4. information about your employment details, and
  5. device identifiers including IP address, which we touch on more below.

Information obtained from you

When we do need to collect personal data, we may obtain it from you directly in a number of different ways, including:  

  1. when you apply for a Mortgage on our website
  2. when you provide it online, through our application or by any other method of communication, for example, on Chatbot, or when you provide it through the course of our relationship and through your continued use of our services, for example, if you inform us of a change in your circumstances; and
  3. particular technical information, including the Internet Protocol (IP) address used to connect your device to the internet, your login information, system and operating system platform type and version, device model, browser or app version, language, location preferences and your location (based on IP address), which may be collected from you when you visit our website or app.

In providing the personal data of any individual (other than yourself) to us during your use of our services, you confirm that you have obtained authority from such individual to disclose their personal data to us, as well as their authority to our collection, use and disclosure of such personal data, for the purposes set out in this privacy notice.

Information obtained from third parties

If you are applying to us through a third party, then they should have provided you with their own privacy notice in order to tell you (whether online or in person) how they may process your personal information. They should have also told you that credit reference and fraud prevention agency checks will be performed before we consider your application more fully and that your personal information is being shared with us for the purposes and uses set out in this privacy notice. We may also obtain information about you from third parties who provide services to you or us such as credit reference, fraud prevention or government agencies (where permitted by law).

This Privacy Notice is readily available on our Website and will be updated from time to time.

Our Website may use “cookies” to enhance your user experience and distinguish you from other users.

Why we process your personal information

We process your personal information for a variety of reasons, the main types of which and the legal basis for doing so are as follows:

  1. We process your personal information in order to consider and process your mortgage application. This is necessary in order to take steps at your request before we enter into an agreement with you and is also necessary for our legitimate interests (i.e. in deciding whether or not we can offer you the product you have applied for). This type of processing is required in order for you to enter into an agreement with us. If you do not provide it, then we won’t be able to proceed with your application.
  2. Before we make a decision on your mortgage offer, we check your personal data against third party databases, for the purposes of preventing fraud and money laundering, and to verify your identity.
  3. If your application is accepted, we will process your personal information in order to administer your account in a number of ways. This will include, for example, collecting loan repayments; providing you with account statements, notices, and other information such as changes to your interest rate; managing any arrears on your account; enforcing any security that we have in place; and dealing with any queries or complaints that you may have. This type of processing is necessary for the performance of our contract with you and in order to fulfil our legal obligations.
  4. We will also process your personal information to manage our business operations, for example, our compliance functions, which will include monitoring communications and activities in relation to your account and for accounting and audit purposes. We have legitimate interests in doing so and we may also have legal obligations to fulfil.
  5. If your application is declined, we will store your personal information in compliance with our record retention policy to comply with our legal obligations.
  6. If we are dealing with a request you have made in order to exercise your legal and regulatory rights (including those referred to in the ‘Your rights under applicable data protection law’) below, this will be done in order to fulfil our legal obligation to respond to you.
  7. We process your personal information for marketing purposes. This is necessary in order to fulfil our legitimate interests of providing you with information about products and services that you may be interested in.

If you would like us to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised. To update your preferences, ask us to remove information from our mail lists (including stopping sending you marketing communications) or make a request to access, update, correct or delete your personal information, please contact us at the following email address [email protected] or please click the unsubscribe link within the marketing emails that you may receive from us.

Any consent that you give us will be as easy to withdraw as it was to give. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent.

Who could we share your personal information with?

We may share your personal information with the following third parties:

We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with Article 28 GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.

Foreign Jurisdictions

At present, Imagine Mortgages does not and has no desire to share your data outside of the United Kingdom.

However, it may become necessary for our business to have to share your personal data with third parties acting on behalf of us which may be located in other jurisdictions.

We will always ensure that such transfers are lawful and by ensuring that they are to jurisdictions that are considered to have equivalent privacy protections, and/or ensuring that the third parties to whom we transfer your personal data are under contract to Imagine Mortgages and bound by appropriate data protection clauses or other approved safeguards.

Whenever fraud prevention agencies transfer your personal data outside the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable data sharing.

Credit reference checks

In order to process your application, we will perform credit and identity checks on you with a Credit Reference Agency (CRA). We may also make periodic searches after your mortgage account is opened with a CRA to help us manage your account.

To do this, we will supply your personal information to the CRA and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRA will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

We will continue to exchange information about you with the CRA while you have a relationship with us. We will also inform the CRA when you repay your mortgage. If you do not repay your mortgage in full, then the CRA will record the outstanding debt shortfall. This information may be supplied to other organisations by the CRA.

When a CRA receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRA, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA information notice (CRAIN) at: experian.co.uk/crain/index.html

Automated decision making

In order to be as efficient and streamlined as possible, we may perform automated processing (i.e. processing that is carried out without human intervention) on your personal information, to evaluate certain things about you. In particular, we may do this to analyse or predict (amongst other things) your economic situation and credit history / behaviour.

This could mean that automated decisions (i.e. decisions that are made without human intervention) are made about you using your personal information.

For example, if you do not meet an element of our lending criteria (such as being over 18 or being a resident in the UK) any application for credit will be automatically declined. If you do meet our eligibility criteria, whether we lend will then be determined by your credit status.

When we do this, we take all necessary measures to ensure that your privacy and security are protected.

You have rights in relation to automated decision making; if you want to know more, please contact us using the contact information set-out in the ‘Introduction’ section of this privacy notice.

Your rights under applicable data protection law

Your personal information is protected under data protection law and you have a number of rights (explained below) which you can seek to exercise. Please contact us using the contact information set-out in the ‘Introduction’ section of this privacy notice if you wish to do so, or if you have any queries in relation to your rights.

If you seek to exercise your rights, and we cannot fulfil your request, we will always explain to you the reasons why as these rights do not apply in all circumstances. Please be aware that if your request is manifestly unfounded or excessive, we may refuse to deal with your request or may charge a reasonable fee for dealing with it.

Your Rights

Right to be informed

We have made available this Privacy notice to provide you with concise, transparent, clear and easily accessible information about how we use your personal data, including specific information depending on whether or not we have obtained your personal data directly from you.

Right to access

You have the right to access the personal information held about you and to obtain certain prescribed information about how we process it. This is more commonly known as submitting a 'data subject access request'. We may request proof of your identity before sharing such information with you. There is no fee for this service.

Right to rectify your personal information

If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information corrected.

Right to be forgotten

You may ask us to delete information we hold about you in certain circumstances, this is often referred to as the 'right to be forgotten'. This right is not absolute and only applies in certain circumstances. It may not therefore be possible for us to delete the information we hold about you, for example, if we have an ongoing relationship or are required to retain information to comply with our legal obligations.

Right to restriction of processing

In some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, it may be restricted until the accuracy is verified, or where the processing is unlawful but you object to it being deleted and request that it is restricted instead.

Right to data portability

You have the right to receive, move, copy or transfer your personal information to a controller which is also known as 'data portability'. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means. You should note that this right is different from the right of access (see above) and the types of information you can obtain under the two separate rights may be different.

Right to object to processing

You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing (including profiling to the extent it relates to direct marketing) and for the purposes of statistical analysis.

Rights with respect to automated decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way.

Keeping your personal data secure

We are committed to protecting the information you provide us. To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, we have in place appropriate technological and operational procedures to safeguard the information we collect.

If you believe we have handled your personal data in a manner that does not comply with this Privacy Notice, please contact us.

Changes to this Privacy Notice

If there are updates to the terms this Privacy Notice, we will post those changes to our website and update the revision date in this document, so you will always know what information we collect, how we use it, and what choices you have. If appropriate, we may also notify you by email of particular changes.

For how long will your personal information be stored?

We only keep your personal information for as long as it is necessary to fulfil the purposes for which it is processed (as described above).

In accordance with our retention policy, we will retain your personal information for a minimum of seven years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed (which will either be when all outstanding sums under the agreement have been repaid or when we stop pursuing arrears on the account) or when your application has been declined.

Please note that if your personal information is shared with third parties (as detailed above) they may have different retention policies. Fraud prevention agencies can hold your personal data for different periods of time.

Keeping your information accurate

We strive to ensure that your personal information is kept up to date and accurate. If any of the personal information you have given to us or third parties changes, such as your contact details, employment status or marital status, please promptly inform us in accordance with the terms and conditions of your agreement with us.

You will be required to provide us with any changes to your personal information under the agreement you enter into with us if your application for a mortgage product is accepted. If you fail to do so this will put you in breach of your agreement.

How we monitor your communications

Subject to applicable laws, we will monitor and record calls, emails, text messages, social media messages and other communications. We will do this for the purposes of complying with applicable laws and regulations and our own internal policies and procedures, to prevent or detect crime, to protect the security of our communications systems and procedures and for quality control and staff training purposes.

If you have any concerns or wish to make a complaint

If you have any concerns regarding our use of your information, please notify our as soon as possible using the contact information set-out in the ‘Introduction’ section of this privacy notice.

If we cannot resolve a complaint to your satisfaction, you can contact the Information Commissioner’s Office at www.ico.org.uk or by telephoning 0303 123 113 if the complaint relates to the way your personal information has been handled.