Fair Processing Notice
Neo Loans Ltd. (Neo) is a second-charge mortgage broker.
Our company number is 08587808. Our registered office and trading address is
Devon House, 1 Chorley New Road, Bolton BL1 4QR
The personal data we collect about you:
- Identity data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
- Contact data including home address, email address and telephone numbers
- Financial data including bank statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
- Transaction data including payments made for products and services you have purchased from us
- Marketing and communications data including your preferences in receiving marketing from us and our business partners and your communication preferences
How do we collect your data:
Personal data is collected by us using the following methods:
- Direct interactions with an adviser by post, phone (including call recordings and voicemail), email, videoconferencing or otherwise when sourcing and applying for mortgage products, processing identity, contact and financial categories of personal data.
- Automated technologies or technical interactions with our website, by using a web enquiry form, processing identity, contact, financial and technical categories of personal
- Third parties or publicly available sources (processing identity, contact and financial categories of personal data) such as enquiries you may perform on third-party mortgage sourcing websites.
Why do we need your data?
We will hold and process your data to assist you with obtaining a second-charge mortgage. If you do not provide the information we request, we will be unable to assist you in obtaining the right finance option. We will only collect the data we need.
What right do we have to process your data?
Neo Loans is authorised and regulated by the Financial Conduct Authority (FCA www.fca.org.uk), which means we are accountable for the products and services we provide
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Purpose/Activity |
Type(s) of data |
Lawful basis for processing |
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To initially engage with you to discuss your requirements |
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Consent |
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To source products, provide indicative quotes, and process & deliver your application for a loan product via our Matrix platform |
|
Performance of a contract with you to provide advice services |
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Purpose/Activity |
Type(s) of data |
Lawful basis for processing |
|
To comply with FCA rules including record keeping, consumer duty, vulnerable customers, and to meet Anti Money Laundering legislation, and notifying you about changes to our terms or privacy policy |
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To comply with a legal obligation Special Category data – Substantial Public Interest (Statutory & Government Purposes) supported by Vulnerable Customer policy |
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To recover debts due to us |
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Performance of a contract with you to provide advice services |
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To perform internal audits of our activity by third party auditors across the organisation |
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To comply with a legal obligation |
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To manage our client relationship with you which will include: On-going communications until you are ready to proceed Re-engagement when existing products nears expiry |
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Necessary for our legitimate interests (to maintain an on-going relationship with you and review your finance needs) |
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To respond to case enquiries, plus input to and defend against complaints |
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Legal & Regulatory Obligation Special Category data - Legal Claims & Judicial Acts |
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To perform customer service and satisfaction surveys for recently completed transactions |
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Consent |
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Record calls to perform checks on the quality of advice our advisers provide to customers |
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Legal & Regulatory Obligation Special Category data - Explicit Consent |
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To generate reports on business activity for the purposes of performance and capacity planning |
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Necessary for our legitimate interests of our business and marketing strategy |
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To use cookies, data analytics, and other systems to improve our website, products/services, marketing, customer relationships and experiences |
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Consent / Explicit Consent |
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Using systems including AI and automated decision making to support our services and assist with affordability and product sourcing |
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Necessary for our legitimate interests (to assist advisers with the advice process) |
What do we do with your data?
All of the personal data we hold about you will be processed by our staff based in the United Kingdom. Personal Data is data that identifies you as an individual.
Your information may be stored on a cloud-based system whose servers are located within the EEA. We take all reasonable steps to maintain the security of your data. Our data storage provider is Lantec www.lantec.co.uk.
We act in a broking capacity; we are not a lender. To help you achieve the finance you require, we will need to share your data with a lender at the appropriate time. We may also need to share your data with credit reference agencies, surveyors or other third parties relevant to the processing of your application. We pride ourselves on our systems and we take great care over how we process customer data, and ensure it is always done safely and securely. We want you to be confident in Neo Loans and be assured that we take the security and privacy of your data seriously.
Neo Loans also believes you should be fully informed about other organisations we may share your data with and have the opportunity to look at how they may handle your information. We have a comprehensive panel of lenders we use. A list of these can be provided on request if you wish to view their Fair Processing Notice.
During the processing of your application, your data may be utilised in conjunction with our third-party suppliers for the purpose of identity verification or fulfilment of our marketing communication strategy. We will remain the data controller in all instances.
We may also contact you in the future to discuss your second charge mortgage. Your preferences around this contact will be obtained during your initial contact with Neo Loans, and you have the right to amend these preferences at any time or withdraw entirely from this service.
We may use data analytics and other systems including AI and automated decision-making to improve our website, products/services, marketing, customer relationships and experiences.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this fair processing notice.
How long do we keep your data?
Neo Loans is an FCA regulated firm, and we need to retain full and detailed records of all of our customer transactions where they have taken place to meet regulatory requirements. We feel it is important to be able to retrieve any of our records for an appropriate time to respond to, or support, customer or regulator enquiries.
Neo Loans has taken the decision to retain customer records on the following basis:
|
Stage in regulated process |
Term of retention |
Action by us after term of retention |
|
Where no regulated advice has been provided |
Retain data for 2 years |
Records are anonymised, and all personal data removed |
|
Where regulated advice has been given but not taken forward |
Retain data for 6 years from the date of the advice |
Records are anonymised, and all personal data removed |
|
Where regulated advice has been given and the transaction completed |
Retain for a total period of the completed product term plus 6 years |
Records are anonymised, and all personal data removed |
Credit Reference Agency Data
At Neo Loans, we help customers obtain finance by a number of means. To get a picture of your true credit position, we access and search your credit file with a credit reference agency.
We believe in informing customers at all stages about searches we carry out, and we will seek your permission to complete these when they become necessary.
If you wish to know how the credit reference agencies will treat your data, please see their policies via these links:
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Equifax |
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TransUnion |
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Experian |
What are your rights?
Importantly you have significant rights as to how Neo Loans, or any business, uses and handles your data. Below is a summary:
- The right to be informed – and this notice you are reading is intended to provide this for you
- The right of access – you can always ask to see what data we hold about you
- The right to rectification – this is saying if you believe any data stored about you is incorrect, you can ask us to correct it, and we will
- The right to request erasure or the ‘the right to request to be forgotten’ – we do have an overarching legal requirement to maintain customer records in accordance with our regulatory responsibilities so you should be aware this right may not be always possible (See ‘How long do we keep your data’ above)
- The right to restrict processing – you can ask us to restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- The right to data portability – should you want to; we can arrange for your data to be formatted into a simple electronic file and sent to you
- The right to object – you can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on these grounds, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- The right to withdraw consent – this applies where we rely on consent to process your personal However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Rights in relation to automated decision making and profiling – you have a right to be made aware of this
You also have the right to make a complaint about how your data has been processed by Neo Loans. In the first instance, you can contact us directly by email compliance@neoloans.co.uk , or by phone 01204 933600. If you are not satisfied with how we respond to your enquiry you do have the right to complain to the Information Commissioners Office (ICO), who is the regulator for data protection in the United Kingdom
What may other organisations do?
If, with your permission, we pass your data on to another organisation to assist you; any data we have supplied plus any data requested or gathered by that business will be held by that business for the purposes they then set out in their own Fair Processing Notice or Privacy Policy. You are strongly advised to read that businesses’ guidelines on how they treat your data before entering into any agreement. Neo Loans bears no responsibility for the use of your data beyond our control