Privacy Policy of Think Plutus

This Website collects some Personal Data from its Users.

Personal Data processed for the following purposes and using the following services:

    • Advertising

      • Facebook Lookalike Audience

        Personal Data: Cookies; Usage Data

    • Analytics

      • Alexa Metrics and Google Analytics

        Personal Data: Cookies; Usage Data

    • Backup saving and management

      • Amazon Glacier and Backup on Google Drive

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Contacting the User

      • Phone contact

        Personal Data: phone number

      • Mailing list or newsletter

        Personal Data: address; city; company name; Cookies; country; county; date of birth; email address; first name; gender; last name; phone number; profession; state; Usage Data; website; ZIP/Postal code

      • Contact form

        Personal Data: address; city; company name; country; county; date of birth; email address; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID

    • Device permissions for Personal Data access

      • Device permissions for Personal Data access

        Personal Data: Call permission

    • Displaying content from external platforms

      • Google Fonts

        Personal Data: Trackers; Usage Data

      • Google Maps widget and YouTube video widget

        Personal Data: Cookies; Usage Data

    • Hosting and backend infrastructure

      • Amazon Web Services (AWS), DigitalOcean and Google Cloud Storage

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Managing contacts and sending messages

      • Mailchimp

        Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data

    • Remarketing and behavioral targeting

      • Facebook Custom Audience

        Personal Data: Cookies; email address

      • Facebook Remarketing

        Personal Data: Cookies; Usage Data

    • SPAM protection

      • Google reCAPTCHA

        Personal Data: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data

    • Tag Management

      • Google Tag Manager

        Personal Data: Usage Data

    • User database management

      • HubSpot CRM

        Personal Data: email address; phone number; various types of Data as specified in the privacy policy of the service

      • HubSpot Lead Management

        Personal Data: various types of Data as specified in the privacy policy of the service

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

    • How do we keep your personal information secure?

      We understand how important it is to keep your personal information secure. We use a variety of technologies and procedures to protect your personal information from accidental or unlawful breaches of security. These include physical, organisational, and technological security measures.

      We also limit access to your personal data to only those Finance Planning Group staff, appointed representatives, advisers, business partners and suppliers who have a business need to know.

      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.

      How long will you store my information for?

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

      Purpose of processing
      Full application, where product goes into force: Contract term plus six years
      Failed applications, where the product does not proceed: 2 years
      Enquiries from third parties i.e. an estate agent: 2 years
      Affordability assessments i.e. property offer validation: 2 years

    • How do you collect my personal information?

      Personal data is collected by us using the following methods: Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing and applying for mortgage or protection products.

      Automated technologies or interactions with our website, by using the web enquiry form or the quick quote application, QuickStart™.

      Third parties or publicly available sources, 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.

    • Who do we share your personal information with?

      We disclose personal information to third parties such as lenders and insurers, but only to a level is necessary to conclude the mortgage and/or protection contracts and the ongoing servicing of these contracts. A list of the type of firms this might include is:

      A lender, to process your mortgage application

      A solicitor or conveyancer, to help process your mortgage application

      An estate agent or home builder, again to provide updates to help process your mortgage application

      An insurer, to process your protection application

      A packager, to help process your mortgage application

      A secured loan master broker, if it is felt that a second charge mortgage is more appropriate for your needs

      Also, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations. For instance, to meet our obligations to the Financial Conduct Authority and when responding to subject access requests, proceedings of a court of law or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.

      The personal information you provide will not be passed to any third-party organisation for marketing purposes.

    • How will you use my personal information?

      As your Adviser, we use your personal information to discuss your personal circumstances with mortgage and protection providers. In order to determine the most appropriate product for your needs. A lender may then undertake credit enquiries upon receipt of your mortgage application. There may be instances where your identity and address is also checked using electronic verification providers.

    • What information do you collect?

      There are a number of categories of data including Identity Data, Contact Data, Financial Data, Special Category Data (specifically medical history) and Profile and Usage Data.

      Mortgage Customers
      This involves sourcing the market to find the mortgage that best suits your circumstances. We do this by asking you about your identity and contact details; your product preferences; your property and tenancy history and types and number of occupants and their relationship to you; your lifestyle; nationality and residence status; employment, income and expenditure and other financial circumstances. How you answer these questions will determine what other questions we ask you, because different lenders serve different parts of the market and have different eligibility criteria. We will always explain the process to you and answer any questions you may have about why certain types of information may be needed.

      When you apply for a mortgage through us we will collect your direct debit details to pass on to your lender. If the products you select involve a cost, such as a valuation fee, we will ask for your payment information.

      Mortgage providers are data controllers in their own right and have their own privacy notices. However, because lenders may automatically profile your information against their lending criteria and against credit reference agencies as soon as your information is forwarded to them this may affect your credit score. We will always bring this to your attention as part of the process so that you are forewarned.

      Insurance Customers
      We routinely offer our customers a range of insurance and protection solutions. Where customers express an interest in protection, we will also collect information about health, as this maybe necessary for the insurers to determine level of cover and premiums.

    • What ‘legal basis’ will you process my personal information?

      when we say process we mean look after and store. The law on data protection sets out a number of different reasons for which a company may collect and process personal information.

      Contractual
      We process your personal information in order to provide you with Mortgage and Protection Advice. In this case, the performance of a contract is simple, you ask us for advice on your mortgage and we provide it. We would be unable to provide you with this advice or arrange your mortgage without this information.

      Legitimate interest
      We will process your personal information under this condition where our interest in using it is not outweighed by your privacy rights or interests. This means that we can use your personal information only in ways you would reasonably expect and which have a minimal impact on your privacy, or where there is a compelling justification for the processing.

      When it comes to staying in touch, we rely on legitimate interests because we only contact existing customers or people who have contacted us directly who are expecting us to do so. Each communication provides an easy to use opt-out.

      Legal compliance
      We may need to process your data in order to fulfil our legal obligations as a Financial Conduct Authority regulated business. For example we may need to verify your identity and comply with anti-money laundering legislation, and co-operate with law enforcement, legal proceedings or regulatory authorities.

Contact information

    • Owner and Data Controller

      Think Plutus is a trading name of The Finance Planning Group Limited
      Registered in England and Wales, Registration number 3894404.
      We are regulated by regulated by Financial Conduct Authority – Number 715721

      Registered Address.
      Hurstwood Grange,
      Hurstwood Lane,
      Haywards Heath,
      West Sussex,
      RH17 7QX.

      Owner contact email: privacy@thinkplutus.com