We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.
Infinity Financials Ltd collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention "Infinity" we", "us" or "our" we are referring to Infinity Financials Ltd.
We provide you with intermediary services in relation to the products.
Infinity Financials Ltd is an appointed representative of Sesame Limited. Sesame Limited is a company registered in England and Wales (company number 2844161) whose registered office is at Pixham End, Dorking, Surrey RH4 1QA. Sesame Limited is authorised and regulated by the Financial Conduct Authority. Sesame Limited's Financial Services Register number is 150427.
We and Sesame Limited have certain shared systems (and so shared access to your personal data). This means that in respect of certain personal data of yours, we and Sesame Limited will be joint data controllers.
The manner in which Sesame Limited will process your personal data is set out in a separate privacy notice which we will provide you with at the start of our engagement. If you require a further copy of this privacy notice, please contact Sesame Limited at dataprivacy@sbg.co.uk or Data Protection Officer, Sesame Limited, Fourth Floor, Jackson House, Sibson Rd, Sale M33 7RR.
In the course of our intermediary services we may collect the following personal data when you provide it to us:
contact information
identity information
financial information
employment status
lifestyle information
health information
data about criminal convictions or offences
details of any vulnerability
details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.)
product details
We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that
- - PAGE 1 - -
they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.The personal data we obtain from other sources may include the following:
From lenders and/or product providers:
product details
From Sesame Limited:
details of any complaint about our services and/or the suitability of any advice we give you
From identification and verification checking agencies:
identity information
sanction check information
The below table sets out:
how we use your personal data
the lawful bases upon which we collect and use your personal data
who we routinely share your personal data with (some of these third-party recipients may be based outside the European Economic Area for further information including on how we safeguard your personal data when this occurs, see Transfer of your information out of the EEA below
|
Rationale/Reason for Processing |
Lawful Basis for Processing |
Third party recipients linked to that activity |
|
Performance of a contract |
Sesame Limited |
|
Performance of a contract |
Lenders/product providers External supplier(s) of software services through which we review, source and apply for decisions in principle, quotations and/or products on your behalf |
|
Consent |
Sesame General Insurance Services Limited
|
|
Compliance with a legal obligation |
Sesame Limited Our external solicitors Our professional indemnity insurers and insurance adviser |
|
Legitimate interests : we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation. This is needed to ensure that our legal rights and interests are managed appropriately] |
Sesame Limited Our external solicitors Our professional indemnity insurers and insurance adviser |
|
Compliance with a legal obligation |
Sesame Limited |
|
Legitimate interests : we have a legitimate interest in operating our business. This includes ensuring that the service we provide is of a satisfactory standard] |
Sesame Limited External supplier(s) of software services to obtain feedback from you |
|
Compliance with a legal obligation |
External supplier(s) of data storage and data hosting services to retain records on our behalf |
|
Legitimate interests : we have a legitimate interest in defending ourselves from legal claims and complaints. This is needed to ensure that our legal rights and interests are managed appropriately] |
External supplier(s) of data storage and data hosting services to retain records on our behalf |
|
Legitimate interests |
n/a |
|
Compliance with a legal obligation. [We also consider that we have a legitimate interest in protecting ourselves, other parties and the financial services industry more widely in detecting, preventing and investigating financial crime and/or misconduct] |
The Financial Conduct Authority Lenders/product providers Sesame Limited National Crime Agency (NCA) Police HMRC |
|
Compliance with a legal obligation |
Sesame Limited External supplier(s) to conduct anti-money laundering, identification and verification checks on our behalf Lenders/product providers |
|
Compliance with a legal obligation |
Information Commissioner s Office |
|
|
|
|
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Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as special categories of data and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process:
health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
criminal conviction or offence information when providing intermediary services in relation to a general insurance product.
In
addition to the lawful basis for processing this information set out
in the
--- PAGE 3 --- above table, we
will be processing it either (i) for the purpose of advising on,
arranging or administering an insurance contract or (ii) for the
establishment, exercise or defence of legal claims. In
the course of our activities
relating to the prevention, detection and investigation of financial
crime, we
may process criminal
conviction or offence information. Where we
do so, in addition to the lawful basis for processing this
information set out in the above table, we
will be processing it for the purpose of compliance with regulatory
requirements relating to unlawful acts and dishonesty. We
may use personal data we hold about you to help us
identify, tailor and provide you
with details of products and services from us
that may be of interest to you. We
will only do so where we have obtained your consent and then have a
legitimate business reason to do this and will do so in accordance
with any marketing preferences you have provided to us. In
addition, where you provided your consent, we
may provide you with details of products and services of third
parties where they may be of interest to you. You
can opt out of receiving marketing at any time. If you wish to amend
your marketing preferences please contact us:
By phone: 01173706363
By email:
admin@infinityfinancialsltd.com
By Post: Infinity
Financials Ltd, Suite 8,
The Old
Church, 113, Gloucester Road North,
Filton,
Bristol, BS34 7PT In
addition, you can opt out of receiving marketing at any time by
clicking the 'unsubscribe' link at the bottom of every email. We
will tell you if providing some personal data is optional, including
if we
ask for your consent to process it. In all other cases you must
provide your personal data in order for us
to provide you with intermediary
services. We
will hold your personal data for differing periods of time depending
upon the reason we have for processing it. These retention periods
are set out below.
Type
of Record Retention
Period
Customer file containing a
record of any intermediary
services provided
by us
For
as long as we
reasonably consider that:
we
may need to deal with your queries
you
might legally bring a claim against us
Complaint file containing a
record of any claim you have brought against us
For
as long as we
reasonably consider that you might legally bring an additional or
repeat claim against us
Marketing
lists Your
data will be retained for the period of the product or as long as
you have given express consent for. Results
of anti-money laundering, identification and verification checks,
including assessment of your sanction
check information
For
as long as we
are required/permitted to retain this personal data based upon
our
legal and regulatory obligations Fraud
and financial crime files
For
as long as we
reasonably consider that:
we
are required/ permitted to retain this personal data based upon
our
legal and regulatory obligations
they
may
be required in the establishment, exercise or defence of legal
claims Records
of satisfaction of any request made by you in accordance with
your rights under data
protection regulation
3
years from the date the request was satisfied
--- PAGE 4 --- We
will not transfer your personal data outside of the European
Economic Area or to any organisation (or subordinate bodies)
governed by public international law or which is set up under any
agreement between two or more countries.
You
have a right to ask us
for more information about the safeguards we
have put in place as mentioned above. To learn more, please see
Your rights below. You
have legal rights under data
protection regulation
in relation to your personal data. These are set out under the below
headings:
To access personal data
To correct / erase personal
data
To restrict how we
use personal data
To object to how we
use personal data
To ask us
to transfer personal data to another organisation
To object to automated
decisions
To understand how we
protect information transferred outside Europe
To find out more about how we
use personal data We
may ask you for proof of identity when making a request to exercise
any of these rights. We
do this to ensure we
only disclose information or change your details where we
know we
are dealing with the right individual. We
will not ask for a fee, unless we
think your request is unfounded, repetitive or excessive. Where a
fee is necessary, we
will inform you before proceeding with your request. We
aim to respond to all valid requests within one month. It may
however take us longer if the request is particularly complicated or
you have made several requests. We
will always let you know if we
think a response will take longer than one month. To speed up our
response, we
may ask you to provide more detail about what you want to receive or
are concerned about.
We
may not always be able to fully address your request, for example if
it would impact the duty of confidentiality we
owe to others, or if we
are otherwise legally entitled to deal with the request in a
different way. To
access personal data You
can ask us
to confirm whether or not we
have and are using your personal data. You can also ask to get a
copy of your personal data from us
and for information on how we
process it. To
rectify / erase personal data You
can ask that we
rectify any information about you which is incorrect. We
will be happy to rectify such information but would need to verify
the accuracy of the information first. You
can ask that we
erase your personal data if you think we
no longer need to use it for the purpose we
collected it from you. You
can also ask that we
erase your personal data if you have either withdrawn your consent
to us
using your information (if we
originally asked for your consent to use your information),or
exercised your right to object to further legitimate use of your
information, or where we
have used it unlawfully or where we
are subject to a legal obligation to erase your personal data. We
may not always be able to comply with your request, for example
where we
need to keep using your personal data in order to comply with our
legal obligation or where we
need to use your personal data to establish, exercise or defend
legal claims.
To
restrict our use of personal data You
can ask that we
restrict our
use of your personal data in certain circumstances, for example
--- PAGE 5 ---
where you think the
information is inaccurate and we
need to verify it;
where our
use of your personal data is not lawful but you do not want us
to erase it;
where the information is no
longer required for the purposes for which it was collected but we
need it to establish, exercise or defend legal claims; or
where you have objected to our
use of your personal data but we
still need to verify if we
have overriding grounds to use it. We
can continue to use your personal data following a request for
restriction where we
have your consent to use it; or we
need to use it to establish, exercise or defend legal claims, or we
need to use it to protect the rights of another individual or a
company. To
object to use of personal data
You
can object to any use of your personal data which we
have justified on the basis of our legitimate interest if you
believe your fundamental rights and freedoms to data protection
outweigh our
legitimate interest in using the information. If you raise an
objection, we
may continue to use the personal data if we
can demonstrate that we
have compelling legitimate interests to use the information. To
request a transfer of personal data
You
can ask us
to provide your personal data to you in a structured, commonly used,
machine-readable format, or you can ask to have it transferred
directly to another data
controller (e.g.
another company). You
may only exercise this right where we
use your personal data in order to perform a contract with you, or
where we
asked for your consent to use your personal data. This right does
not apply to any personal data which we
hold or process outside automated means. To
contest decisions based on automatic decision making
If
we
made a decision about you based solely by automated means (i.e. with
no human intervention), and the decision made by us
produces a legal effect concerning you, or significantly affects
you, you may have the right to contest that decision, express your
point of view and ask for a human review. These rights do not apply
where we
are authorised by law to make such decisions and have adopted
suitable safeguards in our
decision-making processes to protect your rights and freedoms. You
can contact us for more information If
you are not satisfied with the level of information provided in this
privacy notice, you can ask us
about what personal data we
have about you, what we
use your information for, who we
disclose your information to, whether we
transfer it abroad, how we
protect it, how long we
keep it for, what rights you have, how you can make a complaint,
where we
got your data from and whether we
have carried out any automated decision making using your personal
data. If
you would like to exercise any of the above rights, please:
email or write to our Data
Privacy Manager at admin@infinityfinancialsltd.com or
Infinity
Financials Ltd
Suite 8, The
Old Church,
113,
Gloucester Road North,
Filton,
Bristol, BS34 7PT.
let us have enough information
to identify you, e.g. name, address, date of birth;
let us have proof of your
identity and address (a copy of your driving licence or passport
and a recent utility or credit card bill); and
let us know the information to
which your request relates. We
have appropriate security measures in place to prevent personal data
from being accidentally lost or used or accessed in an unauthorised
way. We
limit access to your personal data to those who have a genuine
business need to know it. Those processing your information will do
so only in an authorised manner and are subject to a duty of
confidentiality. We
also have procedures in place to deal with any suspected data
security breach. We
will notify you and any applicable regulator of a suspected data
security breach where we
are legally required to do so. If
you are not happy with the way we
are handling your information, you have a right to lodge a complaint
with the Information Commissioners Office (www.ico.org.uk). We
ask that you please attempt to resolve any issues with us before the
ICO. Please
contact our Data Privacy
Manager if you have any
questions about this privacy notice or the information we
hold about you.
If you wish to contact our Data
Privacy Manager, please send an email to:
admin@infinityfinancialsltd.com
or write to:
Suite 8, The
Old Church,
113,
Gloucester Road North,
Filton,
Bristol, BS34 7PT.
Glossary
of Terms --- PAGE 6 ---
we,
us
or
our
Infinity
Financials Ltd
a company registered in
England and Wales company number 9607375 and having its
registered office at 14, Pen Park Road Bristol BS10 5SB.
contact information
these are
details that can
be used to contact a person, including title, first name,
surname, personal telephone number, fax, email address, home
address, country, postcode or city of residence. This may also
include work contact information such as work telephone number,
fax, work email and work address
data controller
means a natural or legal
person (such as a company) which determines the means and
purposes of processing of personal data. For example, we
are your data controller as we
determine how we
will collect personal data from you, the scope of data which will
be collected, and the purposes for which it will be used in the
course of us
providing you
with intermediary
services
data protection
regulation
applicable data privacy and
protection laws
employment status
this is information about
your work, if you are employed, self-employed, unemployed, a
student or on job seeker allowance
FCA
the Financial Conduct
Authority, being the independent watchdog that regulates
financial services
financial information
this is information relating
to your financial status, including salary/income,
outgoings/expenditure, tax rate and P60
health information
this is information relating
to your medical history, including symptoms, diagnoses,
procedures and outcomes, as well as information about your height
and weight. This could include previous and current or persistent
medical conditions and family medical history
identity information
this is any information that
can be used to distinguish a person or verify their identity,
such as name, date of birth, place of birth, gender, marital
status, national identity card/number, passport, drivers licence
and national insurance number
intermediary services
these are the services we
provide to you in relation to the products, which may include:
advising on the products
applying for a decision in
principle or quotation on your behalf in relation to a product
arranging or administering
a product
on your behalf
lenders
a mortgage lender and/or
specialist mortgage distributor providing us
with access to specialist lenders
(for
a list of current lenders which we
work with, please contact us
(see How
to contact us
above)
lifestyle information
this includes both work and
leisure behaviour patterns. Most relevant to your products
may be your
smoker status, alcohol consumption, health, retirement age and
exercise habits
product
this is a mortgage,
protection and/or general insurance product in respect of which
we provide intermediary
services to you
product provider
a company which provides
protection and/or general insurance products (for
a list of product providers which we
work with, please contact us
(see How
to contact us
above)
sanction check
information
this is information relating
to your politically exposed persons (PEPs) status and Her
Majesty s Treasury financial sanctions status, which is
recorded to prevent fraud and money laundering
vulnerability
a vulnerable consumer is
someone who, due to their personal circumstances, is especially
susceptible to detriment, particularly when an advisory firm is
not acting with appropriate levels of care. These customers are
more likely to suffer severe detriment if something goes wrong.
Details of vulnerability fall in to the following categories:
health; resilience (financial); life events; and capability
(financial knowledge/ confidence)Marketing
Whether
information has to be provided by you, and if so why
How
long your personal data will be kept
Transfer
of your information out of the EEA
Your
rights
Keeping
your personal data secure
Our
supervisory authority
How
to contact us
--- PAGE 7 ---
Your property may be repossessed if you do not keep up repayments on your mortgage.
For Mortgage and Insurance, we don't charge any fee as we get remunerated by commission from lenders and providers.
The FCA does not regulate some forms of buy-to-let mortgages.
Infinity Financials Ltd is Directly Authorised and Regulated by the Financial Conduct Authority (FCA registration number 993949).
Infinity Mortgage is a trading style of Infinity Financials Ltd.
Registered Office: Suite 8, The Old Church, 113A Gloucester Road North, Filton, Bristol, BS34 7PT.
Branch: Unit 4, St. James Court, 285 Barton Street, Gloucester, GL1 4JE.
Registered in England and Wales, No: 9607375