Version: 2.2
Effective: 30th July 2021
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.
Generation Home (trading name of Imagine Mortgages Limited) is registered in England and Wales (registration number: 11465987) with our registered office at 9th Floor, 107 Cheapside, London, EC2V 6DN.
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, Generation Home, Exmouth House, 3-11 Pine Street, London, England, EC1R 0JH.
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).
When we do need to collect personal data, we may obtain it from you directly in a number of different ways, including:
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.
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.
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:
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.
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:
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).
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.
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:
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
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 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.
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.
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.
If you discover that any information, we hold about you is inaccurate or incomplete, you have the right to have that information corrected.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 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.
Services we use your personal data for:
