This Privacy Notice explains how Giraffe Private Finance limited (“Giraffe Private Finance”, “we”, “us” or “our”) collects, uses, stores and shares personal information when you visit our website, contact us, ask us about mortgage advice, become a client, make a mortgage application or otherwise interact with us.

We aim to handle personal information fairly, securely and transparently. This notice is intended to explain, in plain English, what information we collect, why we use it, who we may share it with and the rights you have in relation to your information.

Our processing of personal information is governed by applicable UK data-protection law, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the Privacy and Electronic Communications Regulations 2003 (PECR), together with relevant financial services and regulatory requirements.

Giraffe Private Finance limited is the organisation responsible for the personal information covered by this Privacy Notice.

Giraffe Private Finance limited is authorised and regulated by the Financial Conduct Authority.

Company number: 12063870

Registered office: The Racquets Court, 3 College Street, Newcastle upon Tyne NE1 8JG

FCA Firm Reference Number: 927402

Email: kathryn@giraffeprivatefinance.com

Website: www.giraffeprivatefinance.com

For data-protection questions, requests or concerns, please contact us using the email address above. If a separate Data Protection Officer or data-protection contact is appointed in future, the relevant contact details will be provided here.

Depending on the nature of your enquiry or our relationship with you, we may collect information such as:

· Your name and contact details, including email address, telephone number and postal address.

· Your country of residence and, where relevant to a mortgage enquiry, nationality or citizenship.

· Information about your employment, occupation, employer, income and financial circumstances.

· Information about property you own or wish to purchase, including property value and mortgage requirements.

· Information about existing mortgages, borrowing, assets, liabilities, expenditure and affordability.

· Information required for identification, anti-money laundering, fraud-prevention and regulatory checks.

· Documents you provide, such as identification documents, payslips, bank statements, tax documents and other supporting evidence.

· Information contained in correspondence and communications with us, including email, telephone, WhatsApp or other agreed communication channels.

· Information about your preferences and the services you are interested in.

· Technical information about your use of our website, where applicable, such as IP address, browser type, device information and website usage data.

· Information you provide when completing a website form, sending an enquiry, subscribing to communications or otherwise contacting us.

Please do not send sensitive personal information through a general website enquiry form unless we have specifically asked you to provide it and have explained how it should be sent securely.

We may collect personal information:

· Directly from you when you contact us by email, telephone, WhatsApp, website form or another communication channel.

· When you request mortgage advice or ask us to assess your circumstances.

· When you become a client or proceed with a mortgage application.

· From documents and information you provide during the advice and application process.

· From lenders, our mortgage network, compliance support providers, professional advisers or other parties involved in your application, where appropriate and lawful.

· From credit reference agencies, identity-verification providers, fraud-prevention services or other relevant providers where required for the advice or application process.

· Automatically through our website where cookies or similar technologies are used, subject to our Cookie Policy and applicable consent requirements.

Depending on the circumstances, we may use personal information to:

· Respond to enquiries and requests for information.

· Understand your mortgage requirements and circumstances.

· Provide mortgage advice and assess suitable mortgage solutions.

· Prepare, submit and administer mortgage applications and related services.

· Communicate with you about an enquiry, application, mortgage or service you have requested or are receiving.

· Carry out identity, anti-money laundering, fraud-prevention and other regulatory checks.

· Meet our legal, regulatory and compliance obligations, including requirements imposed by the FCA and our mortgage network where applicable.

· Maintain appropriate records of advice, communications and transactions.

· Manage our business, client relationships and internal administration.

· Protect the security and integrity of our website, systems and information.

· Handle complaints, disputes or legal claims.

· Improve our website, services and communications, where permitted.

· Send direct marketing communications where we are legally permitted to do so and, where required, you have given the necessary consent.

UK data-protection law requires us to have a lawful basis for processing personal information. The appropriate lawful basis depends on what we are doing with the information and the circumstances in which we obtained it.

We may process your information where this is necessary to take steps at your request before entering into a contract, or where processing is necessary to perform a contract with you. This can include responding to a mortgage enquiry, assessing your requirements, progressing an application and providing agreed services.

We may process information where necessary to comply with legal or regulatory obligations. This can include regulatory record keeping, identity and anti-money laundering checks, fraud prevention, responding to lawful requests and meeting obligations imposed by the FCA, our mortgage network or other competent authorities.

We may process information where this is necessary for our legitimate interests, or those of a third party, provided those interests are not overridden by your rights and freedoms. Examples may include managing our business, maintaining client records, administering our relationship with you, protecting our systems, dealing with complaints, preventing fraud and improving our services.

Where consent is the appropriate lawful basis, we will ask for it clearly and separately. You can withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

We distinguish between communications that are necessary to respond to or manage your enquiry or existing relationship and direct marketing.

We may contact you by email or other communication channels about an enquiry, mortgage application, mortgage or service you have requested or are receiving where this is necessary for that purpose.

We will only send direct marketing by electronic mail, such as marketing emails or text messages, where permitted by the Privacy and Electronic Communications Regulations 2003 (PECR) and applicable data-protection law. Where consent is required, we will obtain it through an appropriate positive opt-in. Where a lawful existing-customer exception applies, we will provide an appropriate opportunity to opt out.

You can unsubscribe from marketing communications at any time by using the unsubscribe option provided in the communication or by contacting us at kathryn@giraffeprivatefinance.com. We will respect your request.

We do not sell your personal information. We may share information where necessary, lawful and proportionate for the purposes described in this Privacy Notice.

· Our mortgage network and compliance support providers, where applicable.

· Mortgage lenders and lender panels where required to research, recommend, submit or administer a mortgage application.

· Credit reference agencies, identity-verification providers, fraud-prevention services and other verification providers where appropriate.

· Professional advisers or introducers where this is necessary to provide or coordinate services you have requested and where lawful.

· Solicitors, conveyancers, accountants, tax advisers or other professional firms where you ask us to involve them or where this is necessary for the service being provided.

· Technology and service providers that support our website, CRM, email, communications, document storage, security, analytics or other business functions.

· Regulators, law-enforcement bodies, courts or other authorities where we are legally required or permitted to do so.

· A purchaser, successor or professional adviser in connection with a business sale, restructuring or similar corporate transaction, subject to applicable confidentiality and data-protection requirements.

When you ask us to arrange mortgage advice, your information may need to be shared with lenders, our mortgage network and other parties involved in the regulated advice and application process.

Some of these organisations may act as separate data controllers for parts of their own processing and may provide you with their own privacy information. Where relevant, you should read their privacy notices as well.

We aim to provide only information that is relevant and necessary for the purpose for which it is being shared, subject to the requirements of the advice and application process.

Giraffe Private Finance specialises in helping British expatriates living outside the UK. As a result, we may communicate with clients who are located overseas and may use service providers whose systems or personnel are located outside the UK.

Where personal information is transferred to a country outside the UK, we will comply with the applicable UK data-protection rules governing international transfers. Where required, we will use an applicable adequacy regulation, appropriate safeguards or another lawful transfer mechanism.

Some third-party providers may have their own international data-processing arrangements. Where relevant, their privacy information and contractual arrangements will also apply.

We take appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

The measures used will depend on the nature of the information and the systems involved. They may include access controls, secure systems, authentication, confidentiality measures, backups and procedures for dealing with suspected data-security incidents.

Where you are asked to provide more than basic contact information through a website form, we will use appropriate secure transmission arrangements for that information.

We retain personal information only for as long as necessary for the purposes for which it was collected, including to meet our legal, regulatory, compliance, professional and business obligations.

Different categories of information may be retained for different periods. The applicable period will depend on factors such as the nature of our relationship with you, the type of information, the purpose for which it is held and any legal or regulatory retention requirement.

When information is no longer required, we will securely delete it, anonymise it or otherwise dispose of it in accordance with our internal retention procedures.

Subject to applicable legal conditions and exemptions, you may have rights in relation to your personal information, including:

· The right to be informed about how your information is used.

· The right to request access to the personal information we hold about you.

· The right to request correction of inaccurate or incomplete information.

· The right to request erasure of your information in certain circumstances.

· The right to request restriction of processing in certain circumstances.

· The right to object to certain processing, including direct marketing.

· The right to data portability in circumstances where the right applies.

· Rights relating to automated decision-making and profiling where applicable.

These rights are not absolute and may be subject to legal or regulatory requirements. For example, we may need to retain certain information to comply with our regulatory or legal obligations even if you ask us to delete it.

To exercise a data-protection right, please contact kathryn@giraffeprivatefinance.com. We may need to verify your identity before responding to a request.

If you have a concern about how we have handled your personal information, please contact us first so that we have an opportunity to investigate and resolve the matter.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection.

Information Commissioner’s Office: www.ico.org.uk

We would encourage you to contact us first where possible, but you do not have to do so before contacting the ICO.

Our website may use cookies and similar technologies to operate the website, remember preferences, understand how visitors use the site and, where applicable, measure or improve marketing activity.

Where required, we will ask for your consent before using non-essential cookies or similar technologies. Our Cookie Policy and/or cookie settings will provide further information about the technologies used and how you can manage your choices.

This Privacy Notice should be read together with the website's Cookie Policy once the final website technology and tracking arrangements have been confirmed.

If you choose to contact us through WhatsApp or another third-party messaging service, the information you send will be processed by both us and the relevant messaging provider. You should review the provider's own privacy notice and terms, particularly where the service may process information outside the UK.

Please avoid sending sensitive financial or identity documents through an ordinary messaging conversation unless we have specifically asked you to do so and confirmed that the method is appropriate.

We do not intend to make decisions about your mortgage application solely through automated decision-making on this website.

Lenders, credit reference agencies or other third parties involved in the mortgage process may use automated systems or profiling as part of their own processes. Where applicable, those organisations should provide their own information about such processing and any rights that apply.

Our website and mortgage services are not directed at children. We do not knowingly collect personal information from children through the website.

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. You should read the privacy notice of any third-party website you visit.

We may update this Privacy Notice from time to time to reflect changes to our business, services, technology or legal and regulatory requirements. The latest version will be published on our website with the date it was last updated.

Where a change materially affects how we use personal information, we will take appropriate steps to bring the change to your attention before the new processing begins, where required.

This Privacy Notice forms part of our wider website information and should be read alongside our Website Terms and Conditions, Cookie Policy and applicable regulatory disclosures.

Nothing in this Privacy Notice replaces any specific information or disclosures that we are required to provide under FCA rules, mortgage-network requirements, data-protection legislation, PECR or other applicable law.