Cookies, Privacy & Your Rights

Cookies Policy

Cookies are used on our site to ensure that we give you the best experience on our website. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on our website.

Some cookies are essential so you can move around the website and use its features. Without these cookies, some services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.

What are cookies and how do they work?

Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.

Some of the cookies we use

Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this will restrict the functions that you’re able to carry out on our sites.

Session cookies

These enable you to carry out some essential functions on our sites, such as maintaining log in details for the session or a transaction. They also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.

Secure cookie

A secure cookie is only used when a browser is visiting a server via HTTPS, ensuring that the cookie is always encrypted when transmitting from client to server. This makes the cookie less likely to be exposed to cookie theft via eavesdropping.

Persistent cookies

These are used to persist a user’s preference across e.g. setting items such as the open status of the carousel, and remain until the expiry date and time set by the web server (or otherwise manually deleted by the user).

Analytics

We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and help us provide a more friendly solution.

Third-party cookie

Google Analytics tracking (and most web tracking software) uses cookies in order to provide meaningful reports about site visitors. However, Google Analytics cookies do not collect personal data about website visitors.

Managing your cookies

You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.



PRIVACY POLICY



Straker Financial Services is directly authorised by the Financial Conduct Authority (939746). The privacy policy below is also published here. Both companies known together in this document are referred to as “Straker Financial Services”, “we” and “us”

As the controller of your data, Straker Financial Services comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how Straker Financial Services processes your personal data.

    The personal data we collect about you

     Personal data collected, used, stored and transferred by us may include:

o   Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier

o   Contact Data including home address, email address and telephone numbers

o   Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets

o   Special Category Data specifically medical history

o   Transaction Data including payments made for products and services you have purchased from us

o   Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Straker Financial Services website

o   Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services

o   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 personal data?

     Personal data is collected by us using the following methods:

o   Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing and applying for mortgage or protection products, processing Identity, Contact and Financial categories of personal data.

o   Automated technologies or interactions with our website, by using the web enquiry form or the Find A Mortgage function, processing Identity, Contact, Financial and Technical categories of personal data.

o   Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:

 Estate agents with whom you may be interacting, but only with your consent;

 New home builders, as a legitimate interest of the builder in order to assess affordability for the property;

 Enquiries you may perform on third-party mortgage sourcing websites.

    How do we use your personal data?

     We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Purpose / Activity

Type(s) of data

Lawful basis for processing

To initially engage with you to discuss your requirements

o    Identity

o    Contact

Consent

To process and deliver your application for a mortgage or protection product

o    Identity

o    Contact

o    Financial

o    Special Category

o    Transaction

o    Marketing & Comms

Performance of a contract with you necessary for our legitimate interest (to recover debts due to us)

To manage our relationship with you which will include:

o    Notifying you about changes to our terms or privacy policy

o    Customer reviews / surveys

o    Re-engagement when existing products nears expiry / review protection needs

o    Identity

o    Contact

o    Profile & Usage

o    Marketing & Comms

Performance of a contract with you

To comply with a legal obligation

Necessary for our legitimate interest (to re-engage with you to review your existing mortgage / protection needs, and to maintain and improve customer service standards)

To respond to case enquiries and input to & defend against complaints

o    Identity

o    Contact

o    Profile & Usage

o    Transaction

o    Marketing & Comms

To comply with a legal obligation

Necessary for our legitimate interest (to ensure that complains can be responded to accurately)

To perform an affordability check for a property

o    Identity

o    Contact

o    Profile & Usage

Consent

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

o    Identity

o    Contact

o    Technical

To comply with a legal obligation

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

o    Identity

o    Contact

o    Profile & Usage

o    Marketing & Comms

o    Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

o    Technical

o    Profile & Usage

Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our marketing strategy)

o   Change of purpose

o   We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

o   Marketing communications

o   You will also have the choice to opt-in to receiving other related marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by contacting our Compliance team at This email address is being protected from spambots. You need JavaScript enabled to view it. or by clicking on the relevant link in email communications you receive from us.

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

o   Data Security

o   We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those Straker Financial Services staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

o   Cookies

o   When using the Straker Financial Services website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

o   Website Third-party links

o   Straker Financial Services website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

o   Sharing of personal data outside of the European Economic Area

o   Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

We may also use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.

    Who we disclose personal data to

     Your personal data may be shared with third parties for the following purposes:

Type of recipient

Reason

Within Straker Financial Services

Depending on your requirements, it may be necessary to share your personal data with Straker Financial Services’s specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients

Lenders and protection product suppliers

To source and submit applications in order to conclude the contract for the mortgage / protection application and the ongoing servicing of these contracts.

External suppliers

Specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Straker Financial Services.

Estate agents / new home builders

We may share information about the progress of your application with the firm of mortgage / protection advisers, estate agents and home builders with whom you are interacting.

Licensed Credit Agencies

For the purposes of confirming your identity for fraud prevention; to perform a credit assessment to assess your eligibility; and as part of an application request for a Lenders Decision In Principle.

Regulators

Sharing of information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.

Others

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 privacy notice.

     These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Straker Financial Services instructions.

    How long is your personal data retained?

     We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

Purpose of processing

Retention

Successful mortgage / protection applications

For the full mortgage or protection policy term plus a further 6 years, or for a period of 30 years for historical cases if the original term is not recorded

Withdrawn, stalled, incomplete and failed mortgage/ protection applications

2 years from the date the latest application was started

Affordability assessments for new build property

2 years from Decision In Principle if affordability check does not proceed to a full mortgage application

Enquiry data obtained from third parties (Estate Agents, websites) that do not result in an application for a mortgage / protection product

2 years from the date the lead was received from the Introducer

    

Your legal rights regarding your personal dataAfter these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

    What are my rights with regards to my personal data?

     You have the right to:

o   Request access

o   Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

o   Request correction

o   Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.

o   Request erasure

o   Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

o   Object to processing

o   Object to 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 this ground 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.

o   Request restriction of processing

o   Request restriction of 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.

o   Request the transfer

o   Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

o   Withdraw consent at any time

o   Withdraw consent at any time where we are relying on consent to process your personal data. 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.

o   Exercising your rights or asking questions

o   If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing This email address is being protected from spambots. You need JavaScript enabled to view it. or by writing to us. We will respond to you as soon as possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

o   What if I am still not satisfied?

o   If you are not satisfied with how Straker Financial Services has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

Please call us on 07970328168 if you have any queries.

Changes to our Privacy Policy

We keep our Privacy Notice under review and we will place any updates on this web page.

Your Rights

 

Our number one priority is to provide customers with the highest level of service. However, we know that sometimes things can go wrong. Customer feedback helps us understand where things have gone wrong and gives us the opportunity to put them right. It also helps us understand where we need to improve our products and services.

 

If you have a complaint about your Adviser or the service you received please contact us.

Post: Resolutions Department (Complaints), Straker Financial Services Limited, Little Orchid  Close, Ivybridge, Devon, PL21 0FY.

 

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Phone: 07970328168.

 

We may record and monitor calls.

If your complaint cannot be resolved straightaway we will:

 

- Acknowledge receipt in writing, confirming our understanding of your complaint, who will be handling it and giving you the opportunity to provide any further information or documents

The Financial Ombudsman Service

If you’re dissatisfied with our response, you can ask the Financial Ombudsman Service for an independent review free of charge, but you must do so within six months of the date of SFS’s final response letter.

 

The Financial Ombudsman Service (FOS) will only consider your complaint once you’ve tried to resolve it with us, so please take up your concerns with us first and we’ll do all we can to help. We do our best to resolve complaints and only around 15% of cases are referred to the FOS for an adjudication.

 

The FOS is also only able to consider certain categories of complaint, for example complaints about Buy to Let mortgages, which are not regulated by the Financial Conduct Authority will normally be outside the jurisdiction of the FOS.

 

In addition, the FOS might not be able to consider your complaint if:

 

- What you’re complaining about happened more than six years ago, and

- You’re complaining more than three years after you realised (or should have realised) that there was a problem.

 

If your complaint was made outside of these time limits, which is a matter for The Ombudsman to decide, The Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if it believes that the delay was as a result of exceptional circumstances.

 

Further information on the services provided by the Financial Ombudsman Service can be found on their website: http://www.financial-ombudsman.org.uk or alternatively,

Post: The Financial Ombudsman Service, Exchange Tower, London. E14 9S

 

Phone: 0800 023 4567 or 0300 123 9123

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Alternative Dispute Resolution (ADR) Directive

 

Alternative Dispute Resolution (ADR) Directive. The ADR directive is European law, which means alternative ways of resolving contractual disputes between consumers and businesses are available. The Financial Ombudsman Service (FOS) is the ADR provider for Financial Services in the UK and will provide a complaint handling service under the ADR Directive in addition to its role as an Ombudsman Service.

 

Straker Financial Services has decided to continue dealing with customer’s complaints when they are received rather than pass responsibility to the FOS under the ADR Directive. This does not affect customers’ statutory rights of referral to the FOS as outlined above.

 

Online Dispute Resolution Platform (ODR). Complaints about Financial Services firms may also be sent to the Online Dispute Resolution website; http://ec.europa.eu/consumers/odr.

Any complaints received via the ODR, will be forwarded to the FOS and then to SFS. Complaints received by this method will be treated in the same way as those received through existing means.