Privacy Policy - Giraffe

The General Data Protection Regulations (May 2018) require us to expressly state how we intend to collect, process and manage your personal data. This document sets out our lawful basis for collecting, processing and managing your personal data.

Giraffe Financial LLP t/a Giraffe Financial is an appointed representative of PRIMIS Mortgage Network, a trading name of First Complete Limited which is authorised and regulated by the Financial Conduct Authority.

All three businesses trade from the same premises and work in conjunction with each other to provide you with a co-ordinated approach and the most appropriate ongoing advice in each of our core areas.

The General Data Protection Regulations (GDPR) provide us with 6 different lawful reasons why we may process your data; Consent, Contract, Legal Obligation, Vital Interests, Public Task, Legitimate Interests.

We have chosen the following lawful reasons in each of our separate businesses for processing your data as follows:

· Consent: By purchasing a product or instructing a service from Giraffe Financial and/or Giraffe Wills, you are consenting to us processing your data in relation to the service you require.

· Legal Obligation: If you ask us to submit and process any financial services product such as a Mortgage or Insurance Policy, Wills, Lasting Power of Attorneys and/or Trusts then we will have to comply with statutory legal requirements and requirements set out by the industry regulator in each circumstance. This will necessitate that we process your data in accordance with industry guidelines.

· Legitimate Interest: By seeking advice from our organisation either in person, via email / social media, or via telephone and/or by purchasing a financial services product from us we class you as a client and we therefore have a legitimate interest in retaining your data for the purposes of managing the advice process and products that we may arrange for you i.e. contacting you near the time of your mortgage fixed rate expiry date. We will also keep in touch with you electronically via email to keep you periodically updated on industry updates and product enhancements which may be of interest and/or relevant to you. You have the right to opt out of these communications at any time by notifying us via email to office@giraffefinancial.com.

· Legitimate Interest: We may also need to pass your personal data to qualified third parties for the performance of our duties to you, for example if you are seeking investment advice. As we are not qualified to provide investment advice we will pass on your details to a qualified third party who will contact you separately to discuss your requirements. The same principle would apply if you were seeking tax advice where we may pass your details to a qualified tax adviser to ensure you receive the right advice in this area. These are not the only examples of instances where it may be appropriate to pass on your details to a qualified 3rd party but they give you an indication of the reasons why we may need to do this.

· Legitimate Interest: We will hold onto your data for the duration of your product or service and thereafter unless you specifically opt out of these communications. Although a product such as a mortgage may be repaid, this does not remove the legitimate interest we have in continuing to inform our clients of important updates unless you expressly opt out of receiving communications from us. Your data will be held on our secure Client Relationship Management software.

· Consent: By signing our Terms of Business you agree to Giraffe Lets and/or Giraffe Let’s Buy marketing, managing, finding tenants, and other services we offer, and the processing of your information as it relates to the products you’ve instructed without restriction.

· Legal Obligation: If you list your property with us for sale or for let and/or if you ask us to source a property for you and/or if you ask us to manage a property (or properties) on your behalf then we must comply with statutory legal requirements and requirements set out by the industry regulator in each circumstance. This will necessitate that we process your data in accordance with industry guidelines.

· Legal Obligation: Occasionally we may be asked by HMRC to provide them with details about you for the purposes of tax enforcement. We do not require your consent to do this.

· Legitimate Interest: As a client of Giraffe Lets and/or Giraffe Let’s Buy we may contact you in regard to products or services that may be of interest or beneficial to you, including but not limited to legislation changes and updates to products or services or related services and/or products within our group of companies.

· Legitimate Interest: We will hold onto your data for the duration of your product or service and thereafter unless you specifically opt out of these communications. Although a contract may come to an end, this does not remove the legitimate interest we have in continuing to inform our clients of important updates within the industry.

· Consent: By completing your application and paying the fees you consent to us processing your data by reviewing payslips, bank statements and other relevant information, contacting your employer and current/previous landlord for references, and obtaining any other information we may need to complete the processing of your application as and when necessary. You also consent to us passing your details to a 3rd party tenant referencing firm of our choosing who will obtain a copy of your credit score which will leave a footprint on your credit file for other providers to see. This is for the purposes of a credit worthiness check and also a fraud prevention check.

· Consent: By inquiring about and asking to be notified of future properties that come on the market you are giving us consent to keep in touch with you regarding any properties that may be of interest to you via our CRM systems. You have the right to opt out of these communications at any time by notifying us via info@giraffelets.co.uk

· Legal Obligation: If you are a tenant we need to collect your personal data from you
including name, telephone number, place of work and car registration etc to begin with prior to registering you on our data base to comply with the Health & Safety at Work Act 1974 to protect our employees and associates.

· Legal Obligation: Occasionally we may need to share your personal details with the
emergency services and/or other government agencies to comply with statutory legal
requirements and to enable potential benefit fraud and/or tax avoidance to be highlighted.

· Legitimate Interest: Because you contacted our organisation and/or completed an
application with us we have a legitimate interest in retaining your data for the purposes of contacting you in regards to renewal dates or related products, services, or properties. We may also keep in touch with you electronically via email or via telephone / postal mail to keep you periodically updated on industry updates which may be of interest and/or relevant to you. You have the right to opt out of these communications at any time by emailing info@giraffelets.co.uk

· Legitimate Interest: We will hold onto your data for the duration of your product or service and thereafter unless you specifically opt out of these communications More information on GDPR can be found via the following link: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr

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