Privacy Notice

Introduction

At Generation Home we are committed to protecting and respecting your privacy. We do this by being completely open and transparent in the way we collect or obtain your personal information and how we use that information.

This notice is to inform you about how we uphold your data protection rights and how we collect, use, share and store your personal information – including personal information we already hold about you now and further personal information we might collect about you in the future, either from you or from a third party. How we use your personal information will depend on where you are in your home purchasing journey with us and during the lifetime of the mortgage you have with us.

This notice will update any previous information we have given you about using your personal information. We'll update this notice if we make any significant changes affecting how we use your personal information, and if so, we'll contact you to let you know about the change.

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.

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Who we are

Generation Home (trading name of Imagine Mortgages Limited) is registered in England and Wales (registration number: 11465987) with our registered office at 9Gen H, 1 Old Street Yard, Office 2.02, London, EC1Y 8AF.

We are what is known as the 'data controller' of personal information we collect and use. This means that we are responsible for determining the purpose and the means of processing your personal data.  We are registered with the Information Commissioner’s Office under number ZA523493.

Our Data Protection Officer (DPO) ensures that we apply the best standards to protecting your personal information and comply with our responsibilities for data protection.  If you have any questions about how we handle your personal information or concerns please contact us through our web chat, by phone on 020 3936 9685, by email at yourdata@generationhome.com, or by writing to us at Data Protection Officer, Gen H, 1 Old Street Yard, Office 2.02, London, EC1Y 8AF

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

We collect and process various categories of personal information at different stages of your home buying journey and during the lifetime of your mortgage with us. This may include:

• Basic personal information about your identity (for example, your name, address, date of birth, contact details, home address, email address, visual image or recording and personal appearance).
• Unique identifiers and a reference number that we have allocated to you (such as account numbers or dashboard username).
• Financial and payment information (account and transactional information, personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history).
• Information about your family and others linked to you financially (such as your spouse), your lifestyle and social circumstances.
• Information about your occupation and employment details.
• How you access and use our website or other digital services (your IP address, your location and the device and software being used). We touch on this topic more below.
• The profile information we create by analysing you and your behaviour, through the way you use your account with us and from other sources, including information gathered using artificial intelligence to analyse combined data sets.
• Subject to your individual circumstances, we may also need additional information about you. The law regards such additional information as sensitive personal data and this includes information relating to your health, ethnicity, political opinions, religious or philosophical beliefs, genetic or bio metric data and data relating to your sexual orientation. We will only record this data on our database where we have obtained your explicit consent and where this information is essential due to a legal obligation or to protect your vital interests.

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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 some circumstances you may provide details about your co-borrowers and Deposit Boosters.  If you are 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.

Sometimes where we ask for your information needed to enter into a contract with you or to meet a legal obligation (such as a credit check), we will not be able to provide you with a Generation Home product or service without that information. For some products and services, we will need to use additional information which we will collect about you, or we will not be able to provide any of these products and services to you.

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. You can find our Cookies Policy.

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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 (that is 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. This type of processing is necessary for our legitimate interests and for compliance with our legal obligations.
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.
8. In some instances, we may obtain your explicit consent to use information in a particular way or where the law requires consent to be obtained, for example if you consent to us recording something about your health so we can improve the way we communicate with you.

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 yourdata@generationhome.com 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.

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Who could we share your personal information with?

During the course of your home purchasing journey and the course of your mortgage term with us there may be occasions where co-borrowers and Deposit Boosters may be able to access your information. In such instances we will take care to only share data that you have given us permission to display (for example on the customer dashboard). Should you wish for your data to not be disclosed to the other parties involved in the transaction, please contact us directly via the methods detailed above and we will ensure that the data being shared is restricted.

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

• Fraud prevention agencies such as CIFAS 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 at https://www.cifas.org.uk/fpn
• Anyone acting on your behalf with authority to do so, such as a debt charity, power of attorney or your professional advisors.
• Credit reference agencies to perform credit checks and to verify your identity (see Credit reference checks section for further information).
• We, as well as third-party fraud prevention agencies, may allow law enforcement agencies to access and use your data to detect, investigate and prevent crime.
• Legal and regulatory bodies, such as the Financial Conduct Authority, HM Revenue and Customs, the Information Commissioner's Office (ICO), the Financial Ombudsman Service (FOS), fraud prevention agencies, our professional advisors and/or the courts when it is necessary for our legitimate interests.
• Our conveyancing partners which includes Generation Home Legal if you choose to appoint them as your conveyancer in relation to your purchase or remortgage transaction (for the purposes of completing the mortgage process) and our valuation partners if you choose to accept our mortgage offer.
• Third parties who have introduced you to us (e.g., mortgage brokers or comparison websites) in order for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate, to help us administer your application, including processing and resolving queries arising from information relating to you obtained from any credit reference and fraud prevention agencies, and to help us to resolve any complaint made by you and/or any dispute between you and us. Personal information shared with mortgage brokers may include financial and credit information.
• Market research organisations who we engage to assist us in developing and improving our products and services. This type of processing is necessary for our legitimate interests (e.g. for our commercial operations).
• Any entity (and their professional advisors) that provides funding to us, any entity that provides us with debt or equity finance, any entities that provide advisory services in relation to asset financing transactions and any potential purchasers of any part of our business. This type of processing is necessary for our legitimate interests (e.g. to enable us to fund our business).
• As mentioned above, if you voluntarily provide us with special categories of your personal information, this will be regarded as constituting your explicit consent to us processing such information. This includes us sharing that information with third parties as necessary. For example, if you provide information relating to a complaint you have made or any financial difficulties you may be experiencing, then you will be consenting to us sharing that information with our professional advisors, any third party who introduced you to us (e.g. an intermediary or broker), administration companies or the FOS (as is relevant).

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 of General Data Protection Regulations. 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 (see Appendix 1 for further details).

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Foreign jurisdictions

At present, we do not share your data outside of the United Kingdom.

However, it may become necessary for our business 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, that they are made to jurisdictions that are considered to have equivalent privacy protections, and/or that the third parties to whom we transfer your personal data are under contract with Generation Home (trading name of Imagine Mortgages Limited) and are 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.

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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 use Experian to conduct these checks. 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. The 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:

• Assess your creditworthiness and whether you can afford to take the mortgage product;
• Verify the accuracy of the data you have provided to us;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

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

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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.

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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.

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

Right to be forgotten

You may ask us to delete information we hold about you in certain circumstances, which 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 or regulatory 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.

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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.

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Changes to this privacy notice

If there are updates to the terms of 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.

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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.

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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.

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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.

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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 ‘Who we are’ 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.

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Appendix 1

Services we use your personal data for:

• For business intelligence and analytics, we use providers such as Google Analytics and Hot Jar Limited.

• For credit referencing and ID verification we use providers such as Experian Limited and Veriff (Veriff  OÜ).

• For customer communication and case management we use providers such as DocuSign Incorporation, Calendly LLC and Zoom Video Communications Incorporation.

• For conveyancing we use providers such as Juno Property Lawyers Limited.

• For fraud prevention we use providers such as CIFAS, SIRA (Synectics Solutions Ltd) and Comply Advantage (IVXS UK Limited).

• For payment services we use providers such as Stripe Incorporation.

• For property evaluation we use providers such as Connells Limited and Hometrack Data System Limited.