Customer privacy notice
At Vivid Mortgages we respect your privacy and the confidentiality of your personal information.
Who are we?
Vivid Mortgages is an appointed representative of Quilter Mortgage Planning Limited who is part of the Quilter Group of companies.
For further details on the companies in our group, please visit: https://www.quilter.com/about-us/our-brands/
This Privacy Notice explains:
- Who we are
- What personal information we collect
- How we use your personal information
- Who we share your information with and why
- How we keep your information secure
- Your rights
- How to contact us
Who we are
Vivid Mortgages provide financial planning solutions and advice through experienced and qualified advisers based in the UK.
Currently, Vivid Mortgages and Quilter Financial Planning (Quilter) jointly determine the purposes and means of processing personal client data relating to giving advice. This means we’re joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.
However, Vivid Mortgages is solely responsible for some activities, for example any direct marketing that we undertake.
We will comply with relevant data protection law. Such laws require that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way;
Collected only for valid purposes that we have clearly explained to you;
Relevant to the purposes we have told you about and limited only to those purposes;
Accurate and kept up to date;
Kept only as long as necessary for the purposes we have told you about; and
We try to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below.
You have the right to ask us:
whether we are processing your personal information and the purposes (the right to be
informed) – this is delivered through ‘fair processing information’ such as this Privacy Notice;
for a copy of the personal information that we hold about you (the right of access);
to update or correct your personal information (the right to rectification);
to delete your information (the right to erasure); and
to restrict processing of your personal information where appropriate (the right to restrict
In certain circumstances you also have the right to:
object to the processing of your personal information (the right to object);
object to automated decision making and profiling (the right not to be subject to automated
decision-making including profiling); and
request that information about you is provided to a third party in a commonly used, machine readable form (the right to data portability).
Exercising Your Rights
What personal information we collect
Personal data means information by which you may be personally identified directly or indirectly. We collect certain personal information about you, this includes your name, address, or phone number and other information. We collect this information about you when you:
Use our website and secure online services;
Complete a fund application;
Apply for and receive our services;
complete our application form;
Visit a financial adviser; and
Register to receive one of our newsletters, communications or attend an event organised by Us.
The type of personal information we collect will depend on the purpose for which it is collected and may include:
Information about you to help identify you and manage your relationship with Quilter and, in some circumstances, as required by our regulators (e.g. Account number, Customer ID or
Number, Name, Address, Age / Date(s) Of Birth, Dependents’ Details, Tax ID, National Insurance Number, Identity Check Information (e.g. Mother’s Maiden Name, Name of First Pet), Email Address(es), Marital Status, Name(s), Postcode, Telephone Number(s), Title, Gender);
Information about your account with us (e.g. Past engagements with Quilter, Personal Preferences, Marketing Preferences, Policy and investment information, etc);
Copies of documentation (e.g. statements, letters, copies of official documents (e.g. passports, driving licences, etc));
Economic and financial information (e.g. credit card numbers, bank details, Past investment performance, etc and information pertaining to County Court Judgements (CCJs) and any debt history);
Investment preferences (e.g. your views and preferences around portfolios in which to invest, or not to invest in which may indirectly reveal some religious, political or philosophical views that you hold);
Audio and visual information when we are recording interactions with you, or when you visit
one of our premises (e.g. call recordings or Closed Circuit Television);
Employment and educational information (e.g. employer details, relevant professional
Marketing / Communications Data (e.g. Information relating to Marketing and External
Communications (e.g. Marketing Campaigns, Opt In Information, etc));
Lifestyle, Health and Medical information for you, your family and other parties with a
material interest in the product(s) (e.g. specific illness, smoker, disability, gender reassignment);
Relationship Information (e.g. information relating to other parties directly associated with
your policy (e.g. dependents, beneficiaries, trustees, etc); and
Complaint Information (e.g. Complaint Details, Complaint Description, Complaint Details,
complaint Type, Reason/Details of the complaint),
We collect personal information directly from you. For example, we ask for personal information at the
start of our relationship (e.g. when you apply for a policy or service) and in subsequent
communications in order to manage our relationship.
If we provide a service to your employees or a scheme, then personal data in relation to those
employees or members of the scheme isn’t processed by Us as part of the standard corporate advice
process. This information is normally provided directly to the product provider.
In limited circumstances, we may need to collect employee personal data, and where we do, we act as
data processer and it’s therefore provided to Us by yourself, with the knowledge and consent of your
Where we provide our services to trusts, we collect the personal information listed for the settler,
beneficiaries and trustees of that trust. Where we provide our services to companies we may collect
personal information for Directors, Shareholders and Beneficial Owners of the company. Where we
provide our services to charities, we may collect personal information about the trustees or directors of
We may also collect information about you from other sources such as:
another agent (if you have one);
external third parties (e.g. credit reference agencies to verify your identity and to check financial
from Cookies. (Cookies are small text files that are placed on your computer by websites that
you visit. They are widely used in order to make websites work, or work more efficiently, as well
as to provide information to the website owners). To learn more about information collected
through cookies, please click here.
We keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information will be securely disposed of when it is no longer required in accordance with our Personal Data Retention Standard.
Advice data is retained for 50 years to meet our regulatory requirements.
Special category data and criminal conviction data
We may also gather more sensitive personal data, called special category data, for example, as part of
recruitment. This type of data can include racial or ethnic origin, genetic or health information or sexual
orientation. The processing of some of this data is necessary for us to fulfil the obligations on us. In
such cases, we will always explain this during the process and explain what information we require and
why it is needed. Where we do require it, we will always seek your consent. Special category data will
always be processed and stored securely.
Where it is necessary, we may also collect information relating to an individual’s criminal convictions. If
this is the case we will explain what information we require, why it is needed and where required, will ask you for consent.
collects information from your computer using “cookies” which provides us with limited personal
information. Cookies are small text files that are placed on your computer by websites that you visit.
They’re widely used in order to make websites work, or work more efficiently, as well as to provide
information to the website owners.
You can choose not to accept any non-essential cookies for your interactions, however, in a few
cases, some of our website features may not function as a result.
More information about the cookies we use on our website can be found here. How we use your personal information
How we use your personal information
We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements. This includes the following:
- Providing our advice, products or services to you
- Carrying out transactions you have requested
- Confirming and verifying your identity for security purposes
- Credit scoring and assessment, and credit management (where applicable)
- Detecting and preventing fraud, crime, money laundering or other malpractice.
To investigate any complaint or enquiry raised in regards to your adviser or the advice given
We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we process your information to send you marketing that is tailored to your interests.
Our business purposes include the following:
- Enhancing, modifying, and personalising our services for the benefit of our customers
- Providing communications which we think will be of interest to you
- Market or customer satisfaction research or statistical analysis
- Audit and record keeping purposes
- Enhancing the security of our network and information systems.
- Supporting the testing and maintenance of systems
You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.
We may also process your personal data as part of an acquisition or sale. Should this happen, you will be notified about any change to processing or data controller arising as a result of this activity.
Who we share your information with and why
We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include:
- Quilter Financial Planning Limited;
- Other adviser firms in the network for the purpose of providing you with advice (with your Consent);
- The Quilter Group of companies to enhance the services and products we can offer you;
- Third parties to verify your identity, in line with money laundering or other requirements (this may involve carrying out checks with credit reference databases);
- Third parties who perform tasks for us to help us set up or service your plan (these third parties may be based in countries outside the UK but where they are, we’ll undertake an assessment of safeguards in place);
- Other organisations, including regulatory bodies, the police and fraud prevention agencies, to prevent and detect fraud;
- Third parties where required by law, court order or regulation; and
- Third parties as part of an acquisition or sale.
- The Quilter group or third parties for assurance or audit purpose
How we keep your information secure
We’re committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.
If we work with third parties in countries outside the UK, we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.
In limited circumstances, data may be accessed outside of the UK i.e. by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.
Basic identifiers about you (e.g. your name and address) is matched with information from Experian Marketing Services to create demographics and infer customer ‘types’ so that Quilter Financial Planning and the Quilter group of companies can define groups based on factors like interests, age, location and more. This helps Quilter Financial Planning and the Quilter group of companies better understand our customers in order to adapt and improve our products and services.
If you would like to know more about the information we receive from Experian Marketing Services, you can visit their website (www.experian.co.uk/privacy/consumer-information-portal) which explains who Experian Marketing Services are, what they do and why.
Vivid Mortgages tries to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below. This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have the right to opt out of receiving marketing information and tell us what your communication preferences are by contacting Quilter Financial Planning using the details provided at the end of this notice or by using the opt out option below or on any email marketing. You may opt out at any time if you don’t want to receive any further communications of this nature.
Individual data rights and requests
- The right to be informed – You can request that we provide ‘fair processing information’, typically through this privacy notice;
- The right of access – You may request a copy of the personal information we hold about you using the contact details found on the end of this privacy notice;
- The right to rectification – The accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information;
- The right to erasure – You may request the deletion or removal of personal data where there’s no compelling reason for its continued processing;
- The right to object – You may object to the processing of your data based on legitimate interests;
- The right to restrict processing – You have a right to request we ‘block’ or suppress processing of your personal data;
- The right to data portability – You may request to obtain and reuse your data; and
- The right not to be subject to automated decision-making including profiling.
If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the address or email listed below.
How to contact us
If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details. Quilter will liaise with Vivid Mortgages on your behalf to effect your requests.
The Office of Data Protection
Quilter Financial Planning Limited
85 Queen Victoria Street
How to complain
If you wish to raise a complaint about how we have handled your personal data, you can contact The Office of Data Protection who’ll investigate the matter.
If you’re not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can complain to our regulator:
Information Governance Department
Information Commissioner’s Office
0303 123 1113
Consent to gather special category data
As detailed above, in some instances, it is necessary for us to collect more sensitive information (such as health or lifestyle information) which is called special category data. This is to allow us to provide our financial advice service to you. This is where we need to gather your consent to the collection and processing of this data. You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.
|By signing this box, you are giving consent for special category personal data to be collected, stored and used in order for your adviser to provide you with a tailored advice service.
We may want to send you relevant marketing electronically from time to time. If you do not wish to receive electronic marketing, then please tick the box below to opt out.
|I do not wish to receive electronic marketing of relevant marketing information