Privacy Notice
Introduction
At Gen H, we’re committed to respecting and protecting your privacy. To this end, we work to be completely open and transparent in the way we collect your personal information and how we use that information.
This notice is to inform you about how we collect, use, share and store your personal information – including personal information we already hold and further information we might collect in the future, either from you or from a third party – and how we uphold your data protection rights.
This notice will update any previous information we have given you about using your personal information. If we make any significant changes to how we collect, use, or protect your personal information, we’ll update this notice on our website and contact you to let you know about the change.
Who we are
Gen H (trading name of Imagine Mortgages Limited) is registered in England and Wales under number 11465987 with our registered office at 1 Old Street Yard, London, EC1Y 8AF.
We are what is known as the “data controller” of personal information we collect and use. This means that we are responsible for determining the purpose and the means of processing your personal data. We are registered with the Information Commissioner’s Office under number ZA523493.
Our Data Protection Officer (DPO) ensures that we apply the best standards to protect your personal information and comply with our responsibilities for data protection.
If you have any questions about how we handle your personal information or concerns please contact us through our web chat, by phone on 0330 808 1791, by email at yourdata@generationhome.com, or by writing to us at Data Protection Officer, Gen H, 1 Old Street Yard, London, England, EC1Y 8AF.
Personal information we may collect from you and how we obtain it
We collect and process various categories of personal information at different stages of your homebuying journey and during the lifetime of your mortgage with us.
This may include:
- Information about your contact details and identity, for example, your name, address, date of birth, contact details, home address, email address, visual image or recording and personal appearance.
- Financial and payment information, for example, account and transactional information, personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history.
- Information about your family and others linked to you financially, such as your spouse, as well as your lifestyle and social circumstances.
- Information about your occupation and employment details, including your pay.
- How you access and use our website or other digital services, such as your Internet Protocol (IP) address, your location and the device and software being used.
- Subject to your individual circumstances, we may also process information about your health in order to accommodate your individual needs. We will only record this data where we have obtained your explicit consent or where this information is essential due to a legal obligation or to protect your vital interests.
Information obtained from you
When we do need to collect personal data, we may obtain it from you directly in a number of different ways, including:
- When you apply for a mortgage via a broker, or for a remortgage or mortgage term change with us directly;
- When you provide it online by any method of communication, for example, on chat on our website, or when you provide it through your continued use of our services; and
- Particular technical information, including the IP address used to connect your device to the internet, your login information, system and operating system platform type and version, device model, browser or app version, language, location preferences and your location (based on IP address), which may be collected from you when you visit our website or app.
In some circumstances you may provide details about your co-borrowers and deposit boosters.
If you provide the personal data of someone other than yourself during your use of our services, you confirm that you have permission from that individual to disclose their personal data to us, as well as their consent to our collection, use and disclosure of such personal data, for the purposes set out in this privacy notice.
Information obtained from third parties
If you are applying to us through a third party, then they will have provided you with their own privacy notice in order to tell you how they may process your personal information online and in person.
They will have also told you that we will perform credit reference and fraud prevention agency checks before we consider your application more fully, and that your personal information is being shared with us for the purposes and uses set out in this privacy notice.
We may also obtain information about you from third parties who provide services to you or us such as credit reference, fraud prevention or government agencies where permitted by law.
Our website may use cookies to enhance your user experience and distinguish you from other users. You can read our Cookies Policy for more information.
Why we process your personal information
We process your personal information for a variety of reasons. Namely:
- We process your personal information in order to consider and process your mortgage application. This is necessary before we enter into an agreement with you, and is also necessary for our legitimate interests in deciding whether or not we can offer you the product you have applied for. This type of processing is required in order for you to enter into an agreement with us. If you do not provide it, then we won’t be able to proceed with your application.
- Before we make a decision on your mortgage offer, we check your personal data against third-party databases. We do this to help prevent fraud and money laundering and to verify your identity. This type of processing is necessary for our legitimate interests and for compliance with our legal obligations.
- If your application is accepted, we will process your personal information in order to administer your account in a number of ways. This will include, for example, collecting loan repayments; providing you with account statements, notices, and other information such as changes to your interest rate; managing any arrears on your account; enforcing any security that we have in place; and dealing with any queries or complaints that you may have. This type of processing is necessary for the performance of our contract with you and in order to fulfil our legal obligations.
- We will also process your personal information to manage our business operations, for example, our compliance functions, which will include monitoring communications and activities in relation to your account and for accounting and audit purposes. We have legitimate interests in doing so and we may also have legal obligations to fulfil.
- If your application is declined, we will store your personal information in compliance with our record retention policy to comply with our legal obligations.
- If we are dealing with a request you have made in order to exercise your legal and regulatory rights (including those referred to in the section titled “Your rights under applicable data protection law” below), this will be done in order to fulfil our legal obligation to respond to you.
- We may process your personal information for marketing purposes when you have consented to it. This consent can be withdrawn at any time.
- In some instances, we may obtain your explicit consent to record something you tell us about your health. This is so we can improve the way we support you – for example, if you are hearing impaired, we can use an appropriate relay service. You can withdraw consent for us to record this information at any time.
If you would like to access, delete or amend information we hold about you, or update your marketing preferences, just reach out to us at yourdata@generationhome.com. To stop receiving marketing emails, you can also click the unsubscribe link in any marketing emails you receive from us.
Who could we share your personal information with?
During the course of your home purchasing journey and mortgage term with us, there may be occasions where we share some of your information with co-borrowers, income boosters and/or deposit boosters. This could include payment and mortgage balance information which is sent in your annual statements. In such instances, we’ll only share necessary data.
Should you wish for your data to not be disclosed to the other parties involved in the transaction, please contact us directly at yourdata@generationhome.com and we will ensure that the data being shared is restricted.
We may also share your personal information with third parties such as:
- Fraud prevention agencies such as SIRA and CIFAS. They’ll use your information to prevent fraud and money laundering, and to verify your identity. If fraud is detected, you may be refused certain services, finance, or employment. Further details of how your information will be used by us and these agencies, along with your data protection rights, can be found at https://www.cifas.org.uk/fpn and https://www.synectics-solutions.com/privacy-policy.
- Anyone acting on your behalf with authority to do so, such as a debt charity, power of attorney or your professional advisors.
- Credit reference agencies, who will use your information to perform credit checks and verify your identity (see the section titled “Credit reference checks” for further information), and to keep updated with the status of your payments.
- Legal and regulatory bodies, such as the Financial Conduct Authority, HM Revenue and Customs, the Information Commissioner's Office (ICO), the Financial Ombudsman Service (FOS), and our professional advisors and/or the courts when it is necessary for our legitimate interests or there is a legal basis.
- Our conveyancing partners, including Gen H Legal if you choose to appoint them as your conveyancer in relation to your purchase or remortgage transaction (for the purposes of completing the mortgage process), and our valuation partners if you choose to accept our mortgage offer.
- Third parties who have introduced you to us (e.g., mortgage brokers or builders) in order for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate, to help us administer your application, including processing and resolving queries arising from information relating to you obtained from any credit reference and fraud prevention agencies, and to help us to resolve any complaint made by you and/or any dispute between you and us. Personal information shared with mortgage brokers may include financial and credit information.
- Any entity (and their professional advisors) that provides funding to us; any entity that provides us with debt or equity finance; any entities that provide advisory services in relation to asset financing transactions; and any potential purchasers of any part of our business. This type of processing is necessary for our legitimate interests (e.g. to enable us to fund our business).
- If you provide information relating to a complaint you have made or any financial difficulties you may be experiencing, or you give us health information which you explicitly consent to us processing, then we may share that information with our professional advisors, any third party who introduced you to us (e.g. an intermediary or broker), or any administration companies or the FOS (as is relevant).
- If you have a New Build Boost mortgage, we will share information with the builder about your payments towards the builder loan to ensure they have an up-to-date record of how much remains outstanding.
We, as well as third-party fraud prevention agencies, may allow law enforcement agencies to access and use your data to detect, investigate and prevent crime where there is a legal basis.
We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with UK GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us and in ways which are compliant with UK data protection law (see Appendix 1 for further details).
Foreign jurisdictions
We may share your personal data with third parties acting on our behalf (as detailed in the previous section), and these may be located outside the UK.
We will always ensure that such data sharing is lawful; that data is only shared with jurisdictions that are considered to have equivalent privacy protections to the UK; and/or that the third parties to whom we transfer your personal data are under contract with Gen H and are bound by appropriate data protection contractual clauses or other approved safeguards equivalent to those required under UK GDPR.
Credit reference checks
In order to process your application, we will perform credit and identity checks on you with Experian, a Credit Reference Agency (CRA). We may also make periodic searches after your mortgage account is opened with a CRA to help us manage your account.
To do this, we will supply your personal information to the CRA, and they will give us information about you.
This will include information from your credit application and about your financial situation and financial history. The CRA will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the mortgage product;
- Verify the accuracy of the data you have provided to us;
- Manage your account(s);
- Trace and recover debts; and
- Ensure any offers provided to you are appropriate to your circumstances.
If the CRA information relating to your credit commitments is different from the information you supply in your application, and this difference impacts our decision to lend to you, we will share this information with your mortgage broker.
This is shared so that your broker can advise you of the reason for our decision, which is in your legitimate interest.
We will continue to exchange information about you with the CRA while you have a relationship with us. We will also inform the CRA when you repay your mortgage. If you do not repay your mortgage in full, then the CRA will record the outstanding debt shortfall. This information may be supplied to other organisations by the CRA.
When a CRA receives a search from us, they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or you tell us that you have a spouse or financial associate, we will link your records together. Make sure you discuss this with your financial associate and share this notice before submitting your application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your associate successfully files for a disassociation with the CRAs to break that link.
The identities of the CRA, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA Information Notice at: experian.co.uk/crain/index.html.
Automated decisioning
In order to be as efficient and streamlined as possible, we may perform automated processing (i.e. processing that is carried out without human intervention) on your personal information to evaluate certain things about you. In particular, we may do this to analyse or predict (amongst other things) your economic situation and credit history/behaviour.
This could mean that automated decisions (i.e. decisions that are made without human intervention) are made about you using your personal information.
For example, if you do not meet an element of our lending criteria (such as being over 18 or being a resident in the UK) any application for credit will be automatically declined. If you do meet our eligibility criteria, whether we lend will then be determined by your credit status.
When we do this, we take all necessary measures to ensure that your privacy and security are protected.
You have rights in relation to automated decision making; if you want to know more, please contact us using the contact information set-out in the “Who we are” section of this Privacy Notice.
Your rights under applicable data protection law
Under UK data protection law, you have a set of certain rights. These are:
- The right to access the information we hold about you;
- The right to rectification if the information we hold is inaccurate;
- The right to erasure (in certain circumstances);
- The right to restrict processing (in certain circumstances);
- The right to data portability (in certain circumstances);
- The right to object (in certain circumstances);
- Rights in relation to automated decision making and profiling; and
- The right to withdraw your consent at any time, if unnecessary for the managing of your mortgage.
You can exercise your rights by emailing us on the contact details below or by writing or emailing us at yourdata@generationhome.com.
Keeping your personal data secure
We are committed to protecting the information you provide to us. To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, we have in place appropriate technological and operational procedures to safeguard the information we collect.
If you believe we have handled your personal data in a manner that does not comply with this Privacy Notice, please contact us.
For how long will your personal information be stored
We only keep your personal information for as long as it is necessary to fulfil the purposes for which it is processed (as described above).
In accordance with our retention policy, we will retain your personal information for a minimum of seven years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed, which will either be when all outstanding sums under the agreement have been repaid or when we stop pursuing arrears on the account, or when your application has been declined.
Please note that if your personal information is shared with third parties (as detailed above) they may have different retention policies. Fraud prevention agencies can hold your personal data for different periods of time.
If you have any concerns or wish to make a complaint
If you have any concerns regarding our use of your information, please notify us as soon as possible using our web chat, by phone on 0330 808 1791, by email at yourdata@generationhome.com, or by writing to us at Data Protection Officer, Gen H, 1 Old Street Yard, London, England, EC1Y 8AF.
If we cannot resolve a complaint to your satisfaction, you can contact the Information Commissioner’s Office at www.ico.org.uk or by telephoning 0303 123 1113 if the complaint relates to the way your personal information has been handled.
Appendix 1
The following list details which third parties may be involved in handling your data as set out above.
- For business intelligence and analytics, we use providers such as Google Analytics and Hot Jar Limited and Looker.
- For credit referencing and ID verification we use providers such as Experian Limited and Veriff (Veriff OÜ).
- For customer communication and case management we use providers such as Intercom, Aircall, Calendly LLC and Zoom Video Communications Incorporation.
- For fraud prevention we use providers such as CIFAS, SIRA (Synectics Solutions Ltd) and Comply Advantage (IVXS UK Limited).
- For payment services we use providers such as Stripe Incorporation and GoCardless.
- For property evaluation we use providers such as LMSS and Hometrack Data System Limited.