About

This Privacy Policy explains what data is collected via the website (including via any web chat function and customer/adviser portals that are accessible via the website) and how we will treat that data. Our privacy policy may change as our processes are updated over time. Policy updates will be reflected in this document

We are committed to protecting the data of our website users by complying with United Kingdom (UK) Data Protection laws including the General Data Protection Regulations (GDPR). This applies to how we collect, process, and use the personal data of customers, financial advisers and business partners, when they enquire about and use our products and services. Please note, the pages of this website are intended for UK residents and refer to UK products. We do not share any personal data outside of the European Economic Area (EEA)

Where you interact with us other than through the Website (e.g. where you apply for a product by post or through a financial adviser), this Privacy Policy may be supplemented by separate privacy policies, notices or other privacy related information which will apply to personal data obtained by us (or on our behalf) other than through the Website. This additional privacy information will be made available to you at the relevant point at which we collect your personal data.

We reserve the right in our sole discretion to amend this Privacy Policy from time to time. In this event, we will post the revised policy on the Website, and we will notify you of any material changes via this website. By visiting the Website, you are accepting the practices set out in this Privacy Policy.

This website is operated by Pure Retirement Limited, a company registered under the reference 07240896. Our registered address is: 2200 Century Way, Thorpe Park, Leeds, LS15 8ZB.

Personal Data

‘Personal data’ is defined as information about a living individual that can be used to identify them, such as their name and address details. Any reference to ‘information’ or ‘data’ in this policy is a reference to personal information about a living individual. Please be aware that the personal information you provide to us, and which we collect about you, is required. Without this information, we may encounter challenges in providing our services to you.

This website provides users who are interested in our products/services with an opportunity to submit online enquiries to us and to set up and access their online account/portals. In order to facilitate this, we will require you to provide personal data about yourself or via your financial adviser. We will only use the personal data you provide to us as described in this policy and any supplemental privacy information which will be provided to you at the appropriate point in time (e.g. in the event of applying for borrowing)

What information we hold and how we use it

This Website provides users who are interested in our products/services with an opportunity to submit online enquiries to us and access their online accounts. The personal data that you may provide to us through the Website is set out below:

• Your name
• Your contact details (including postal address, email address and phone number)
• Your account number (when you are an existing customer)
• Your company details if you are an adviser acting on behalf of our mutual customer (including place of work and regulatory authorisation information)
• Any personal data you choose to include when typing into the webchat or when typing additional comments in the customer enquiry form
• Any personal data you may include when submitting a complaint online
• Your debit/credit card details (only when you choose to make a payment online through the online portal which is accessible via the Website)
• We may automatically collect technical information (such as but not exclusive to; IP address, geographic location, device details, login information) and information about each visit you make to the Website (such as but not exclusive to page response times and length of visit)

As stated above this Privacy Policy may be supplemented by separate privacy policies, notices or other privacy related information if you enter into a contract with us, at which point we will provide you with further privacy information relevant to your application.

The Website also uses cookies. Please see our Cookies Policy for information about the cookies we use and your choices in relation to cookie use.

How we use the personal data we collect

We will use your personal data collected (including from any third parties, where relevant and lawful) to provide products and services to our customers and their authorised representatives (such as their financial adviser). We will use your personal data to:

• Contact you about our products/services in response to requests for information
• Provide our products/services to you if you decide to go ahead and obtain them (but please note as explained above that supplemental privacy information, notices and/or statements will also be relevant to that processing)
• Manage and contact you about any products or services that we provide to you (and in doing so enter your details into our customer relationship management tool
• Contact you in respect of any complaints that you submit
• Make reasonable adjustments to enable you to access our services in full
• Process payments you choose to make if you make a payment to us relating to your loan/mortgage via the Website
• Comply with our legal obligations
• In an anonymised form, identify patterns which we can use to help us develop, administer, support and improve our services.

We will only collect and process your personal data where we have lawful grounds to do so.

Where do we get our information from

• Directly from you or via your authorised representation (e.g. financial advisers) via online form submissions (to register to use our products or services or to receive requested information.
• Information we receive from other sources: This could be anonymous information from your online browsing activity or information from a third party (e.g. sourcing platforms).
• Anonymous online behaviour: We use cookies and similar technologies to support the functioning of our websites. This includes allowing you to browse between pages effectively. Please refer to our Cookie Policy for more detail and to manage your preferences.

Lawful basis and Your data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. Which lawful basis we rely on may affect your data protection rights which are in brief set out below.

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.

Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.

Your right to erasure - You have the right to ask us to delete your personal information.

Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.

Your right to object to processing - You have the right to object to the processing of your personal data.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.

Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time.

Please note that the rights listed above may not apply in circumstances where we are required to retain your data for contractual and legal purposes.

How we will comply with Data Protection Laws

We take our data protection responsibilities very seriously and ensure we meet data protection laws before processing your personal information as described in this privacy policy. To use your personal information, we may use the following lawful basis (more than one lawful basis may be relevant to each example of our data usage)

• Contract: Where you are an existing customer/business partner we will process your personal data to the extent required for us to provide you with services related to your product/business relationship. All of your data protection rights may apply except the right to object (as we are required to collect your data to fulfil our contractual requirements)
• Legitimate Interests: We will also process your personal data where this processing is in our "legitimate interests". It is in our legitimate interests to collect your personal data as it provides us with the information that we need to run the Website or provide our services and/or products more effectively. We have assessed that we are able to collect this data because it is beneficial to you without causing an undue risk of harm to anyone. We will always act reasonably and give full and proper consideration to your interests.
• Legal obligation: Where there is a legal requirement upon us to record, retain or share your personal data with authorities, we must do so. For example, to comply with laws and regulations which govern our business, such as the Financial Services and Markets Act 2000 and the Proceeds of Crime Act 2002. All of your rights may apply except the right to object and the right to data portability.
• Public Interest/Task: We have to collect or use your information to carry out a task laid down in law and regulatory guidance, which the law intends to be performed by an organisation such as ours. (As an example, we are required to ensure all of our customers have fair access to our products and services. Where you have a health issue and we are notified about that issue by you or by someone else, we may record this sensitive personal data where it is necessary for reasons of substantial public interest, to allow us to comply with the Equalities Act 2010 and make reasonable adjustments if required.) All of your rights may apply except the right to object and the right to data portability.
• Public Interest/Task: We have to collect or use your information to carry out a task laid down in law and regulatory guidance, which the law intends to be performed by an organisation such as ours. (As an example, we are required to ensure all of our customers have fair access to our products and services. Where you have a health issue and we are notified about that issue by you or by someone else, we may record this sensitive personal data where it is necessary for reasons of substantial public interest, to allow us to comply with the Equalities Act 2010 and make reasonable adjustments if required.) All of your rights may apply except the right to object and the right to data portability.
• Consent: Where you have provided your consent, we also rely on your consent to use your personal data in certain ways (for example, in some circumstances to market our products and services to you or respond to queries from potential customers)

Additionally, if you are acting in the capacity of a professional business client, additional business to business services may be provided to you. For these services we will use your consent to collect your personal data for the following purposes:

• When you've specifically requested or opted in to receive marketing information about our services and products. You may opt out of marketing at any time by e-mailing or telephoning your relationship manager.
• To assess your company suitability.
• To carry out market research and product development.
• To manage risk for us and our retail customers.
• We may provide you with business-to-business marketing information about our services or products.
• We will provide you with product updates that we're legally obliged to inform you about.
• Study and also manage how our professional business clients use products and services from us and our business partners.
• Provide answers to any queries you pose via our online chat facilities
• Develop and test the effectiveness of marketing activities.
• Develop, test, and manage our products, services, and applications.

Please be aware that the personal information you provide to us, and which we collect about you, is required to ensure full product and service performance. Without this information, we may encounter challenges in providing our services to you.

Third-party websites

This Website may contain links to third-party websites. Please be aware that our Privacy Policy does not apply to these linked sites. We encourage you to read the posted privacy statement of third-party websites whenever you're interacting with them.

Disclosing your information

We may use third parties to provide services on our behalf which may include processing your personal data (but not using the data for their own purposes). We will provide your data to the following categories of third parties:

• Companies that provide data hosting and website management services such as Microsoft.
• Companies that provide website analytics services and /or help us to make advertising messages more relevant to you such as Google Analytics, (please see our Cookies Policy for further information).
• In each case, we will, in accordance with our obligations under Data Protection Laws, put in place appropriate written protections for your personal data.
• The provider of funds where you have a product with us in order to facilitate the provision of our products and services. The funders will process your data in compliance with Data Protection law, you can read the privacy statement of each funding partner on their websites:
• Rothesay Life: Data Protection | Rothesay
• Just.: Privacy Policy | Just.
• RGA: Documents | RGA (rgare.com)
• Phoenix: Privacy notice | Legal and policies | Phoenix Life
• PIC: Privacy policy - PIC (pensioncorporation.com)

If you are a customer and would like to check which funding partner has access to your data, please get in touch with our customer services team customerservices@pureretirement.co.uk

In addition to the disclosures described above, we may disclose your personal data to:

• Our auditors, solicitors, surveyors, document providers and other professional advisors/services, who have agreed to treat your personal details as confidential and in compliance with the applicable laws
• Anybody who has a legal right to your personal data, including the police and any other legal and regulatory authorities and government bodies (such as the Financial Conduct Authority)
• Fraud prevention and detection. In order to prevent and detect fraud it may be necessary to; share information about you with other organisations, such as the Financial Action Task Force or other official industry bodies and to check your details for credit and credit-related facilities.

Other than set out in this Privacy Policy (and supplemental privacy information, notices and/or statements where relevant), we will not otherwise disclose, sell or distribute your personal data we collect via the Website to any third party without your permission unless we are required to do so by law.

How do we keep your personal information secure?

Our security protocols are designed to safeguard your personal information from accidental loss, unauthorised use, alteration, or disclosure. Access to your personal data is restricted to authorised individuals with a legitimate business need to access them. As part of our security measures, we may request proof of your identity before sharing any personal information.

Additionally, we proactively monitor our systems for potential vulnerabilities and threats, continuously enhancing our security posture. In the event of a suspected data security breach, we promptly notify you and relevant regulatory authorities as required by law.

How long do we keep your information?

We keep personal data for the purpose for which it was originally collected and only for so long as is necessary, or where we are required to keep your personal data due to legal or regulatory reasons.

Website and Portal Availability

While we make every effort to maintain the accessibility of this website and our online portals, we cannot be held responsible if, for any reason, the sites become temporarily unavailable. Occasionally, we may need to suspend access for routine or emergency updates and maintenance, but we will strive to minimise any disruptions.

In accordance with our obligations under Data Protection Laws, to prevent unauthorised access to or disclosure of your personal data (including card payments), maintain data accuracy, and ensure the appropriate use of your personal data, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online.

You should be aware that there are inherent risks in transferring personal data over the Internet. For example, if you send us an e-mail from your private mailbox, we cannot guarantee the security of the content during its transmission to us. Furthermore, we cannot guarantee that this website or the online portals will be free from viruses or defects.

We cannot guarantee the security of your data transmitted to the Website: any transmission (i.e. your sending of the personal data to us) is at your own risk. Once we have received your personal data, we will use the steps detailed above to protect it.

Data Protection Officer

Pure Retirement has appointed a Data Protection Officer to provide independent expert advice and monitor compliance with data protection laws. If you would like to exercise the rights listed above, you can send a request to the below details. Please note, that in some instances your rights may not apply (for example where we are required by law to hold your data)

Name: Edward Halliwell, Data Protection Officer.

Correcting or updating your information

If you are a customer and would like to correct and/or update your registration information you can write to us at the following address:

Pure Retirement, 2200 Century Way, Thorpe Park, Leeds, LS15 8ZB, alternatively you can email: customerservices@pureretirement.co.uk.

If you are acting in the capacity of a registered financial adviser, you can contact your Business Relationship Manager who will be happy to assist with any queries.

If you are not happy with the way in which your personal data is held or processed by us, or if you are not satisfied with our handling of any request by you in relation to your rights or any automated profiling that we carry out, our Data Protection Officer would be happy to help.

Alternatively, you have the right to complain to the Information Commissioner's Office (ICO) by calling 0330 828 3149.

The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website Information Commissioner's Office (ICO)