PRIVACY POLICY

How We Use Your Personal Data

We will only collect, use and process your personal information where we have a lawful basis to do so under UK GDPR.

These lawful bases include:

To perform a contract with you or take steps before entering into a contract.
To comply with our legal or regulatory obligations.
Where we have a legitimate business interest that does not override your rights.
To protect your vital interests where necessary.
Where you have given us your consent for a specific purpose.

Where we obtain your personal information from someone other than you, we will inform you within the timescales required by law.

Who Collects Your Information

Your personal information is collected and processed by:

Passive Strategy Ltd t/a Stamp Duty Funding

If you have any questions regarding how your personal information is handled or wish to exercise your rights, please contact our Data Protection Officer or Data Privacy Manager using the contact details provided on our website or within your client documentation.

Why We Collect Your Information

We collect personal information to:

Assess your enquiry or application.
Provide our products and services.
Enter into and administer contracts with you.
Meet our legal and regulatory obligations.
Prevent fraud and financial crime.
Improve our products and customer service.
Respond to your enquiries.
Send marketing communications where you have given your consent.

We will only use your information for the purposes for which it was collected unless we are legally permitted or required to do otherwise.

How We Collect Your Information

We may collect your personal information through a variety of methods, including:

Telephone conversations.
Emails and written correspondence.
Application forms.
Our website and online enquiry forms.
Identity verification documents.
Financial information supplied during applications.
Communications with your authorised representatives.
Meetings with our advisers.

Automated Decision Making

As part of arranging finance or lending services, your information may be submitted to lenders who use automated systems to assess applications, including obtaining a Decision in Principle (DIP) or Agreement in Principle (AIP).

Passive Strategy Ltd does not make lending decisions using its own automated decision-making systems.

Information We Receive From Third Parties

We may receive personal information from:

Credit Reference Agencies.
Fraud Prevention Agencies.
Mortgage lenders.
Solicitors.
Estate agents.
Financial advisers.
Identity verification providers.
Other organisations involved in providing the services you request.

Where required, we will obtain your permission before carrying out credit reference checks.

Who We Share Your Information With

Your personal information may be shared with organisations where necessary to provide our services or comply with legal obligations, including:

Credit Reference Agencies.
Mortgage lenders and finance providers.
Banks.
Insurance providers.
Fraud Prevention Agencies.
Identity verification providers.
Solicitors and licensed conveyancers.
Valuers and surveyors.
Estate agents.
Professional advisers.
Regulatory bodies including the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), HM Revenue & Customs (HMRC), the Information Commissioner's Office (ICO), and other organisations where disclosure is required by law.

We will never sell your personal information to third parties.

Marketing Communications

We will only send you marketing communications where:

You have given your consent; or
We are otherwise permitted to do so under applicable legislation.

You may withdraw your consent or unsubscribe from marketing communications at any time. We will update your preferences promptly.

Keeping Your Information Secure

We take the security of your personal information seriously.

Appropriate technical and organisational measures are in place to protect your data from:

Unauthorised access.
Loss.
Misuse.
Alteration.
Disclosure.

Where we use trusted third-party service providers, we ensure they maintain appropriate security standards and comply with UK data protection legislation.

How Long We Keep Your Information

We will only retain your personal information for as long as necessary to:

Provide our services.
Meet our contractual obligations.
Comply with legal and regulatory requirements.
Resolve disputes.
Enforce our agreements.

Retention periods vary depending upon the nature of the information and our legal obligations.

Once your information is no longer required, it will be securely deleted or anonymised.

Your Rights

Under UK GDPR, you have a number of rights regarding your personal information. These include:

The right to be informed.
The right of access.
The right to rectification.
The right to erasure (where applicable).
The right to restrict processing.
The right to data portability.
The right to object to processing.
Rights relating to automated decision making and profiling.

Some of these rights are subject to legal exemptions and may not apply in every circumstance.

Further information can be found on the ICO website at https://ico.org.uk.

Exercising Your Rights

If you wish to exercise any of your rights or have any questions about how we process your personal information, please contact our Data Protection Officer or Data Privacy Manager.

Before responding to certain requests, we may need to verify your identity to protect your personal information.

We aim to respond to all legitimate requests within one calendar month.

Complaints

If you are unhappy with how we have handled your personal information, please contact us first so that we can try to resolve your concerns.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Website: https://ico.org.uk
Telephone: 0303 123 1113

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legislation, regulation or our business practices.

The latest version will always be available on our website.