What personal information do we collect?

The personal information we collect depends on how you interact with us, ranging from browsing our website to formally engaging us for a product or service.

Personal information will be collected when you use our website when you contact us by telephone (or when we contact you by telephone), throughout the application process and in our aftercare service. Please note calls between us may be recorded and securely retained for training and compliance purposes.

Information will usually be collected directly from you or someone you have authorised to provide information to us such as a joint applicant or perhaps where you are acting as a guarantor. Information may, however, be collected from an Introducer or a Broker. When we are approached by an Introducer or a Broker on your behalf we undertake checks to ensure that you have been made aware of how your information will be used.

The information we may collect can be categorised as:

1. Identification data – including your name, title, date of birth, national insurance number;

2. Documentary information – including Passports, Driving Licences and any other documentary evidence we request to verify your identity, residency and the proof and source of any deposit or any other contribution you make towards a purchase;

3. Contact information – including your address (and previous address if relevant), your telephone number and email address;

4. Employment information – including your employment status, income, employer name, length of employment, details of previous employment;

5. Financial information – including your income and expenditure, assets and liabilities, financial status, financial history, bank details, bank/credit card/mortgage statements, and debit / credit card details;

6. Transactional information – including the type of product or service you have applied for, repayments, term, exit strategy;

7. Public domain information – including information held at Companies House, in electoral rolls, and widely available on the internet;

8. Behavioural information – including details about your usage of our products and services;

9. Marketing preference information – details of any preferences you have advised us of regarding receipt of marketing literature, details of how and when you gave us “consent” (where this is required) to contact you;

10. Technical data – including IP address, web browser type and version, operating system, a list of URLs starting with a referring site, your activity on this Web Site, the site you exit to and cookie information (see “our use of cookies” below).

We do not collect information classified as Special Category data, such as racial or ethnic origin, religious beliefs or criminal convictions etc unless it is lawful to collect such information and it is relevant to the transaction.

If you are an introducer of business into Lighthouse, we will collect some identification data, contact information and employment information. We will also ask you to confirm your/your firms’ status with the Information Commissioners Office, and that the client you are introducing has been made aware of how you will process and share their data with us.

How do we use your personal information?

We will store, process and where appropriate share your personal information with external parties necessary to provide the product or service.

Any personal information we collect will be retained by Lighthouse for as long as you are a client of Lighthouse.

After you cease being a client of Lighthouse we may retain your information for up to 6 years in order
to respond to complaints or questions you may have, to demonstrate we have observed our Treating Customers Fairly principles and to fulfil any legal or regulatory requirements. For instance, it is a regulatory requirement to retain information we gathered about you regarding your identity and residency for a period of time after you cease being a client.

We may retain your information for longer than 6 years if we are required to do so by law, or for research and statistical purposes where we can prove a “legitimate interest”. Where we do retain your information for more than 6 years we will ensure your information is used only for these stated purposes.

What lawful bases do we have for processing your information?

Where you approach us for a product or service, our lawful basis for processing your data is “contract” i.e. we are processing your data because you have asked us to do something before you enter into a contract.

For some of the data we process, we also have a “legitimate interest”, and / or a “legal obligation”. For example, we have both a “legitimate interest” and a “legal obligation” to process information to prevent financial crime.

There will also be occasions where we rely on your “consent” to process your data.

Where you have made an enquiry with us we have a “legitimate interest” to keep you informed about relevant products and solutions that may be of interest to you. When we first collect information from you, we will give you the option to restrict this processing i.e. prevent any marketing material being received. Where you do not exercise your right to restrict this processing, all marketing literature we send to you
will have an option to unsubscribe. You can also exercise your right to restrict processing for marketing purposes or withdraw any “consent” you have previously provided to us, at any time. Please see “how can you restrict us sending you marketing material?” below.

Who do we share your information with?

Where you request we provide you with a product or service, we will share information with the product or service provider. We will only share the information necessary to provide a quotation, to complete an application or to execute the product or service.

Before making an application to the provider of the product or service we recommend you read the providers Privacy Policy. We will signpost you to this Policy should you require us to.

In addition to the product or service providers outlined above, we may share your personal information with:

• Professionals appointed by yourself, appointed by the product or service provider or appointed by ourselves to negotiate and execute the transaction;

• Fraud Prevention / Money Laundering Agencies in order to verify your identity and address, and for fraud/money laundering prevention purposes;

• Organisations that formally introduce you to us;

• Associated companies of Lighthouse where we believe they can contribute to a competitive bespoke financial solution. Any approach we make to an associated company will be with your knowledge or on a no-names basis;

• Organisations you ask us to share your information with;

• Third parties specifically contracted by Lighthouse to deliver products and services to you as referred to in “our use of third parties” below.

How do we protect your information?

Information security is of great importance to Lighthouse and to protect your information we have put in place suitable physical, electronic and managerial procedures whether your personal data is stored in physical files or computer systems (including hard drives and storage systems). For example access to information is restricted internally within our business so that only colleagues with a legitimate need to access the information are permitted to access it.

We also have policies in place to ensure we do not collect excessive or (unless relevant to the transaction) special category information from you and systems to securely dispose of information in line with our retention policy.

Lighthouse also employs the services of third parties to control and protect your information and regularly reviews the security controls in place. Where we are considering appointing a new third party who would handle your personal information, we liaise closely with the ICO to ensure appropriate safeguards are in place. In the event your personal information is transferred outside of the UK, we ensure this is only done if the strict criteria regarding ‘International Transfers’ are met, and regular reviews of the safeguarding arrangements are undertaken.

Where you provide your contact information via our website we will securely store this data on our website in order to ensure we follow up on your enquiry appropriately.

How can you access and control the information we hold about you?

You can access the information we hold about you by writing to The Lighthouse Group Sports and Lifestyle Management Limited at 9th Floor, Cornerblock, 2 Cornwall Street, Birmingham, B3 2DX. To respond to your request we may need to contact you to ensure we fully understand your request and we will also need

to verify your identity to ensure we do not disclose information to a third party (unless you specifically authorise us to do so).

Information will usually be provided to you free of charge unless defined as unfounded, excessive or repetitious in accordance with current regulations.

• In certain circumstances, you can request us to:

• Rectify any inaccurate data we hold,

• Complete any incomplete data,

• Erase personal data (“the right to be forgotten”),

• Restrict or object to the processing of your personal data.

In the event we do not believe your request meets the qualifying criteria or we are unable to comply with your request for any lawful reason, we will explain these reasons to you.

Your right to withhold information

If you choose not to give us personal data which is required by ourselves or a product or service provider as part of your application, it may delay or prevent your application from progressing.

You may access certain areas of this Web Site without providing information at all, or where the only information collected is Technical data as defined above. You may also restrict your internet browser’s use of Cookies. For more information see “our use of cookies” below. However, to use all Services and Systems available on the Web Site you may be required to submit personal information.

Our use of Cookies

Cookies are small text files placed on your computer to collect information such as visitor behaviour information to help us improve our Website. Lighthouse has carefully chosen these Cookies and uses them to facilitate certain functions and features of the Web Site. We also use Cookies for analytical purposes.

For information about how you can delete and control cookies, visit www.aboutcookies.org or www. allaboutcookies.org. Please note deleting cookies may mean you lose any information that enables you to access the Web Site more quickly. It is recommended that you ensure that your internet browser is up- to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.

How can you restrict us from sending you marketing material?

You will be given the option to restrict processing for marketing purposes when we first collect personal information from you. If you do not exercise this right to restrict processing, every subsequent marketing message you receive will give you the option to unsubscribe. However,
you can also restrict processing or withdraw your consent at any time by emailing team@armcolighthouse.com

How do you make a complaint about how we have used your personal information?

If you are unhappy with how we have used your personal information you can submit a complaint to us by writing to the Complaints Manager, 1st Floor, 103 Colmore Row, Birmingham, B3 3AG, or contact us by phone on 0121 3120541. You can also complain to the Information Commissioners Office via their website www.ico.org.uk

Our use of third parties

Lighthouse may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, provision of Customer Relationship Management systems, delivery of purchased items, search engine facilities, advertising and marketing. We also use third parties to provide IT security solutions.

The providers of such services only have access to the information required by them to perform the services that Lighthouse requests. Any use for other purposes is strictly prohibited. Furthermore, any data handled by third parties must be processed within the terms of this Privacy Policy and in accordance with current legislation.

Changes to our Business Ownership and Control

Lighthouse may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Information you have provided to us will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the information for the purposes for which it was supplied by you.

In the event that any information you have provided to us will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your information deleted or withheld from the new owner or controller.

Our review of this Policy

This Privacy Policy is regularly reviewed. This Policy was last reviewed on 8th July 2023. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the Policy on your first use of the website following the alterations.