Privacy Policy

Taking your privacy seriously
About us:
The Retirement Bridge Group, is Retirement Bridge Group Holdings Limited and all of its subsidiary companies, who operate from
 
3rd Floor, Cross House, Westgate Road,
Newcastle Upon Tyne,
NE1 4XX
 
More information on the Group can be found at www.retbridge.co.uk.

When applying to us as a new customer your personal information will be collected by a company in our Group.  You will be informed, at the time, which of the group’s companies is collecting your data.

If you are making an application to release further equity from your property you will be informed at the time which of the group’s companies is collecting your data.

If you are neither a new applicant or applying to release further equity then you may contact us at www.retbridge.co.uk to find out which company inside the group originally collected your personal information when you entered into your plan.

Your personal information will be held by Retirement Bridge Group Limited on a central database that will be accessed by other group companies in order to administer your plan. This Privacy Policy lets you know how the companies in this Group will look after your personal information.
 
This Privacy Policy applies to all our Group companies. This includes the relevant group company who will administer your plan during the life of the contract and the group company who collects your personal information.
 
In this Privacy Policy references to "we", "us" and "our" are to the Retirement Bridge Group Limited group of companies. It explains how we use personal information we collect about you and who it may be shared with. Our Group includes firms authorised and regulated by the Financial Conduct Authority (FCA) and, as such, are obliged to collect information about you. Further information can be found about us at www.retbridge.co.uk.

Data protection law and what this means for you:

We will use the personal information that we collect about you in accordance with all applicable data protection law in the UK and this includes the General Data Protection Regulation (GDPR).

Under data protection law, we can only use your personal information if we have a lawful reason to do so. We must have one or more of the following lawful reasons:
  • we have your consent;
  • to enter into or perform a contract we have with you;
  • It is in your vital interests;
  • is in our legitimate interests to do so; or
  • when we are under a legal duty.
 
Personal information is information about you and other individuals.  Before providing us with personal information about someone else, please tell that individual about this Privacy Policy and tell them that you will share their personal information with us.

Who is responsible for the personal information that we collect?

For all customers from April 2018 the data controller for the purposes of the GDPR will be the Group company that you were told is collecting your personal information and which is named on the application form you completed.

For existing customers pre- April 2018, the data controller for the purposes of GDPR will be available on request from:
Retirement Bridge Management Limited
3rd Floor, Cross House, Westgate Road,
Newcastle Upon Tyne,
NE1 4XX
 
This Group company will dictate the purpose for which your personal information is used and any personal information you give us about other individuals.

What personal information do we collect about you and how?

For all new customers, we collect your name, address, contact details, date of birth and gender from your Financial Adviser when they introduce you to us.

For new customers seeking to take one our plans with rent, we also collect details about your income and expenditure from your Financial Adviser or through direct contact with us.

For customers whose existing plans may transfer to us, for example, where we have acquired a firm your plan was previously part of, your name, address, contact details, date of birth, gender and marital status is provided to us by your previous plan provider/administrator. 

This personal information will be collected from you:
  • when you apply for one of our plans;
  • in the course of communications with you (including on the phone, when you meet with us or your Financial Adviser, by letter and email);
  • when you complete forms for us including when you complete the application for the plan or and any forms on our website;
  • we also record calls between us for training and monitoring purposes and quality control purposes;
  • when you use our website.  Please note that we use cookies on our website to collect information, please refer to www.retbridge.co.uk to see a copy of our Cookie policy.
 
We will also collect information about you from third parties we work with: 
  • Financial Advisers;
  • Credit reference agencies and tracing agents;
  • Fraud prevention agencies;
  • Land agents
  • Publicly available information including from the Land Registry;
  • Local councils and planning departments;
  • Government and law enforcement agencies; and
  • Doctors or other medical professionals.
 
Why we may process special categories of personal information about you:

In some circumstances we will collect special categories of personal information (also known as sensitive personal data) about you. This may include information concerning your health for example:
  • if you are forced to make an alteration or adaption to your home on medical grounds;
  • if you apply for funding for an alteration or adaption to your home from a Local Authority by way of a grant or loan and require our permission as legal owner; and
    • if you are unable to live in the property on medical grounds and your lease must be handed back.
 
If we need to obtain this information from you we will ask you to provide it to us.   In some circumstances we may need to obtain this information from a third party such as your doctor or other medical professional without asking you first.  This would be in limited circumstance such as where we need to establish, exercise or defend a legal claim against you.

Criminal conviction data

We may also need to process information about you relating to a criminal conviction.  We would need to do this, for example, where you are in breach of your lease by vacating the property due to incarceration following the conviction of a criminal offence. 

If we need to process information about you which relates to a criminal offence or conviction data, we will either:
  • ask for your consent; or
  • process it because:
    • you have manifestly made it public; or
    • it is necessary for us to do so due to legal proceedings, obtaining legal advice or establishing, exercising or defending our legal rights.
 
Why we may process personal information about other people:

If you give us personal information about another person you must tell that person you are going to share it with us.  The information you provide to us will be used in accordance with this Privacy Notice.  Please tell that individual about this

Privacy Policy
.

People living with you

If there is another person living at the property with you, you must tell us about them.  You must tell us this before you apply for one of our plans. You must also tell us if a person moves in with you at a later date after you have taken out a plan with us. The information you will need to tell us will include personal information such as their name and age.

We will also write to you each year and ask you to complete a form that we call the Certificate of Occupancy on which we ask you to confirm that you remain living at the property.  This form will also require you to declare the names of anyone else living at the property.  We must give our consent to other people living in your home because we need to make sure they do not create tenancy rights over the property.
 
Your next of kin

The Certificate of Occupancy form will also offer you the opportunity to provide the name and contact information of your next of kin. You will not be obliged to provide us this information.

If you provide us with details of your next of kin, you are confirming that you have informed this individual and that we may contact them in an emergency.  By an emergency we mean, after taking reasonable steps, we have been unable to make contact with you and we have legitimate concerns about your safety or wellbeing.

We may also need to contact them where we have been unable to make contact with you and we need to establish if you still reside in the property.   

Power of Attorney

If someone is appointed to manage your affairs, for example under a Power of Attorney or similar, we would need to be supplied with the relevant documentation confirming their appointment. This is so that we can act on instructions they may give us on your behalf.

How do we use personal information we collect about you?

We use your personal information in connection with your application and the provision of the plan. Under data protection law we can only use your personal information if we have a proper reason to do so.   A proper reason could be when:
  • we have your consent;
  • it is necessary to enter into or perform a contract with you;
  • it is necessary to comply with a legal obligation;
  • it is necessary in order to protect your vital interests or
  • it is in our legitimate interests.
Where we rely on our legitimate interests we mean our:
  • pursuit of our commercial activities and objectives, or those of a third party;
  • compliance with applicable legal and regulatory obligations and any codes of conduct;
  • improvement and development of our business operations and service offering, or those of a third party; or
  • protection of our business, shareholders, employees and customers, or those of a third party.
We have set out our reasons for using your personal information in the table below under the heading Legal Basis.  Where we rely on our legitimate interests, we have set out those interests in the table below. 
 
You have the right to object to our use of your personal information at any time.  A summary of your right to object and details of who to contact if you want to exercise this right can be found at the How to contact us section below. For further information on your rights please see the Your Rights section below.
 
  
Purpose Legal Basis
To communicate with you and other individuals. Consent and legitimate interests: we require your personal information in order for you to apply for the plan and for us to provide our services.
To make decisions about your plan application. Legitimate interests: we require your personal information in order to enable us asses and process your application for a plan.
To assist in the ongoing administration of your plan in accordance with the terms and conditions of the plan which if entered into, will be a contract between us. Performance of a contract we have with you.
For audit and statistical purposes. Legitimate interests: we require your personal information in order to enable us to carry out analysis and internal reporting procedures within our business and to share information with our auditors.
For assessment of affordability and debt recovery purposes, where for example you may be obliged to make payments of rent, ground rent, service charges or insurance as part of your plan obligations. Legitimate interests: we require your personal information to enable us to process your application for the plan and to enable us to provide our services. 
To comply with legal and regulatory obligations for example fraud prevention. Necessary for compliance with a legal obligation to which we are subject.
To manage complaints, feedback and queries. Legitimate interests: to enable us to deal with any issues you may have in relation to the plan and our services throughout the duration of the Plan.
To communicate with any other individuals who occupy your property. Legitimate interests: we require your personal information in order to enable us to ensure that we are informed about anyone who may be able to affect or undermine our legal rights in relation to the plan.
To communicate with any third-party individuals, such as your next of kin, or individuals who are doctors, member of the medical profession or social workers. Vital Interests: we require your personal information in order to enable us to deal with what we believe, acting reasonably, is an emergency situation where we believe you are in danger or incapacitated or seriously unwell.


Who we may share your personal information with:

For the purposes of processing this application, managing your plan throughout its duration and managing the sale of the property when the plan ends, your information may be shared with:
  • our business partners, financial advisers, suppliers and sub-contractors for the performance of the plan;
  • our professional advisers (including accountants and lawyers) that assist us in carrying out our business activities;
  • our financial services providers such as banks, lenders and payment processors;
  • our IT services providers;
  • Property agents, valuers, surveyors and estate agencies for the purpose of inspection, valuation, sales and contractual repairs;
  • credit reference agencies (such as Experian) so that we can ascertain the plan is affordable where payments such as rent are required;
  • insurers or brokers so that can confirm whether the property relevant to the plan may be adequately insured;
  • external agencies and organisations (including the police, the relevant local authority, the UK Visas and Immigration department and other law enforcement agencies) for the purpose of complying with applicable legal and regulatory obligations;
  • tracing agents, for the purposes such as debt recovery, ascertaining whether contrary to the plan the property may no longer be your main residence or to ensue you or your estate receive any sums such as surplus sale proceeds you may be due under the terms of the plan;
  • regulators such as the Financial Conduct Authority and the Financial Ombudsman Service, for example to help resolve a complaint you make;
  • Other members of our Group of companies. Principally this includes Retirement Bridge Management Ltd to enable them to perform their day to day duties in managing your plan; and
  • investors where they have funded your plan for the purposes of our internal reporting and management. Where such investors are based outside the European Economic Area (EEA) we will anonymise your personal information. For details of who these investors are, please get in touch via the How to contact section below.
We will also disclose your personal information to other third parties, for example:
  • in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;
  • if we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and website terms of use.
Other than as set out above, we will not disclose information about you to any other party without your consent, (or the consent of those who are authorised to act on your behalf) except to help prevent fraud, or where we have legitimate concerns about your safety and wellbeing, or if required to do so by law.
 
Where will we transfer your personal information?

We will process your personal information both within and outside the European Economic Area (EEA) (including Australia, South Africa and the United States of America).

When we transfer your personal information outside the EEA, we will seek to anonymise it. 

If we can't anonymise your personal information, we will take reasonable steps to ensure that your personal information is protected. To do this we use a set of standard data protection clauses which have been approved by the European Commission.

The above approach is compliant with data protection law (being Article 46.2 of the GDPR).  For further information about these transfers and the safeguards in place, please get in touch by using the How to contact us section below.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the website and any transmission is at your own risk.  Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.
 
How we use automated decision making when we process your personal information?

As part of our business operation some decisions about you are taken using automated computer software on a system.For this we use your personal information we have or are allowed to collect from others about you.For example, when you first apply for the plan, or where you seek to release any further available equity from an existing plan, we will need to carry out a credit history and affordability check.

These decisions do not involve human input and the systems apply pre-defined logic programming and criteria to make a decision.

Your rights

You have the right to challenge any automated decision with us directly.You can ask that we do not make automated decisions about you and you can object to an automated decision and ask that a person reviews it.If you want to know more details about your rights, please get in touch via the How to contact us section below.

Credit reference agencies

As mentioned above, when you first apply for a plan and throughout its lifetime, we need to carry out a credit history and affordability check.We use the following credit reference agencies to help us with this: Experian

We will also use the information that the credit reference agency has about you such as details of your financial situation and history and credit position.We use this information to:
  • assess whether you can afford the plan;
  • check the information you have given us;
    • trace and recover any debts;
    • detect and prevent financial crime and money laundering. 
When we ask a credit reference agency about you this will show up on your credit file.Other organisations may be able to see this too as we may be able to see other credit searches undertaken about you.

If you apply for a plan with another person (such as your spouse, partner or civil partner), your records will be linked with theirs both by us and the credit reference agency. Credit searches will also be made against them – you should make sure that they know that a credit search about them will be carried out and that your financial records will be linked.

Your rights

You have the right to apply to a credit reference agency for a copy of your credit file.

There are different agencies so please be aware that the information they hold may not be the same.There is a small fee that you may need to pay to each agency that you apply to. The address of the credit reference agency we currently use is set out below:
  • Experian Consumer Help Service, PO Box 9000, Nottingham NG80 7WP
  • You can call Experian on 0844 481 8000 or log on to www.experian.co.uk
You can also find out more information about credit reference agencies by reading the Credit Reference Agency Information Notice each agency makes available on its website (see www.experian.co.uk for a copy of Experian's notice). 
These notices will:
  • tell you about the credit reference agency;
  • provide further details on the information they hold and how they use it;
  • let you know who the credit reference agency shares information with and why;
  • explain how the credit reference agency works with fraud prevention agencies;
  • give you information on your rights.
Fraud prevention agencies

We (and financial advisers acting for you) will also need to confirm your identify before we can provide you with a plan and will need to share your personal information to help detect fraud and money laundering risks. We use fraud prevention agencies to help us with this.

Should fraud or money laundering be suspected, we will pass your personal information to a law enforcement agency so that they can investigate, prosecute and prevent financial crime.A fraud prevention agency may also share your personal information with a law enforcement agency.

Your rights

You have certain rights with respect to your personal information.The rights will only apply in certain circumstances and are subject to certain exemptions.
 
Please see the table below for a summary of your rights and who to contact to exercise them.
 
Your rights What this means
Right of access to your personal information You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions. 
Right to rectify your personal information You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information You have the right to ask that your personal information be deleted in certain circumstances.  For example:
  • where your personal information is no longer necessary for the purpose(s) it was collected or otherwise used;
  • if you withdraw your consent and there is no other legal reason to permit us to continue to use your personal information;
  • if you object to the use of your personal information (see below);
  • if we have used your personal information unlawfully; or
  • if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information You have the right to suspend our use of your personal information in certain circumstances.  For example:
  • where you think your personal information is inaccurate;
  • the use of your personal information is unlawful but you don't want us to delete it;
  • we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or
  • you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection
Right to data portability You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.
This right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.
Right to object to the use of your personal information You have the right to object to the use of your personal information in certain circumstances. For example:
  • where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and
  • if you object to the use of your personal information for direct marketing purposes.
Right to withdraw consent You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Who to contact
Write to us at:
Retirement Bridge Management Limited,
3rd Floor, Cross House, Westgate Road,
Newcastle Upon Tyne,
NE1 4XX
 
Telephone:  0800 032 2118
Email: enquiries@retbridge.co.uk
Your rights What this means
Right to complain to the relevant data protection authority You have the right to complain to the Information Commissioner's Office (ICO), where you think we have not used your personal information in accordance with data protection law.
Who to contact
Contact the ICO:
  1. ICO Telephone:  0303 123 1113
  2. ICO website: www.ico.org.uk

How long do we keep your personal information?
We will retain your personal information for the life of the plan plus seven years following its termination. This is to:
  • respond to any queries or complaints; and
  • to fulfil our obligations to the FCA, H.M Review & Customs and other governing bodies;
If your application for a plan is not successful we will only retain your personal information for a period of one year from the date that your application is declined/withdrawn.

Once we no longer need your personal information, it will be destroyed securely. We will not consent to any request to destroy the information we hold about you before these timescales have elapsed.

Data security

We maintain strict physical, electronic and administrative safeguards to protect your personal information from unauthorised or inappropriate access.  Our IT systems are manged by a third party professional services company which is ISO 27001 and ISO 9001 certified. Our data is held remotely in UK data centres and our infrastructure, servers and backups are maintained and managed providing the highest security protection.

Your personal information collected, processed, transferred and stored on our website, database and telephony system is encrypted and protected using compliant, secure methods. Whilst emails to our trusted third parties are encrypted, we cannot send or receive secure email from you.  We will therefore not include any of your personal information in an email to you unless you give us your consent to do so. We will not accept liability for any damages for any loss of confidentiality of these emails. We will respond by telephone or post where we do not have your consent.

How to complain:
If you think there is a problem with how your personal information is being handled, you have a right to complain to the Information Commissioner’s Office. They can be contacted on 0303 123 1113. See also www.ico.org.uk

No marketing pledge:
Other than for the purposes of servicing your plan, or undertaking our own internal analysis, we or other Group companies will not contact you for any marketing purposes.  Nor will we pass on your information to other organisations for the purposes of their marketing to you. 

Changes to our Privacy Policy:
Any changes we make to this Privacy Policy in the future will be posted on our website www.retbridge.co.uk and, where appropriate, we will give you reasonable notice of any changes.
How to contact us:
Write to us at: Retirement Bridge Management Limited, 3rd Floor, Cross House, Westgate Road, Newcastle Upon Tyne,
NE1 4XX.
Telephone us on: 0800 032 2118. (In order to verify the content of your call and for staff training and monitoring purposes we ensure all calls are recorded).
E-mail us at: enquiries@retbridge.co.uk

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