ABOUT US 

F&R Associates (The Principle Firm) & Smart Money Solutions Ltd (The Appointed Representative firm) (also referred to as “we”, “us”, or “our”) 

Smart Money Solutions Ltd is a registered company in England (Company no.4529347). Our registered business addresses are – 

F&R Associates trading as Cover My Business (CMB) FCA 450712 

33 High Dyke, Harrowby, Grantham, Lincolnshire NG31 9ER 

Smart Money Solutions Ltd FCA 409755 

33 High Dyke Harrowby Grantham Lincolnshire NG31 9ER 

THE PURPOSE OF THIS NOTICE 

This Notice is designed to help you understand what kind of information we collect in connection with  our products and services and how we will process and use this information. In the course of providing  you with products and services we will collect and process information that is commonly known as  personal data. 

This Notice describes how we collect, use, share, retain and safeguard personal data. 

This Notice sets out your individual rights; we explain these later in the Notice but in summary these  rights include your right to know what data is held about you, how this data is processed and how you  can place restrictions on the use of your data. 

WHAT IS PERSONAL DATA? 

Personal data is information relating to an identified or identifiable natural person. Examples include  an individual’s name, age, address, date of birth, their gender, financial and contact details. 

Personal data may contain information which is known as special categories of personal data. This  may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious  or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or  sexual orientation. 

Personal data may also contain data relating to criminal convictions and offences. 

For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this  data is treated in the same manner as special categories of personal data, where we are legally  required to comply with specific data processing requirements.

PERSONAL DATA WE COLLECT 

In order for us to arrange and administer the following mortgages / financial contracts, personal  insurances, commercial insurances and personal assurance contracts for you we will collect and  process personal data about you. 

We will also collect your personal data where you request information about our services, customer  events, promotions and campaigns. 

We may also need to collect personal data relating to others in order to arrange and administer  mortgage/finance / assurance / insurance contracts. In most circumstances, you will provide us with  this information. Where you disclose the personal data of others, you must ensure you are entitled to  do so. 

You may provide us with personal data when completing online quote or contact forms, Personal  Financial Review documents and application forms when you contact us via the telephone, when  writing to us directly or where we provide you with paper‐based forms for completion or we complete  a form in conjunction with you. 

We will share your personal data within our firm, group of companies and with business partners. This  is normal practice within the finance and insurance industry where it is necessary to share information  in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. 

This data is also used to place mortgage, financial products and protection contacts. It is also necessary to determine the premium payable and to administer our business. 

We also share personal data with authorised third parties, this is necessary where we are required to  do so by law, where we need to administer our business, to quote for, source, place and administer  your insurances / mortgage/ Assurance requirements including insurance premium finance and other  financial arrangements, to perform underwriting activities and to process claims. Some examples  follow: 

• Insurers; 
• Mortgage & Financial Lenders i.e. Banks & Building Societies 
• Underwriters; 
• Premium finance providers; 
• Credit reference agencies; 
• Debt recovery agencies; 
• Claims handling companies; 
• Loss adjusters; 
• Insurance brokers; 
• Reinsurers; 
• Regulators. 

We may record your communications with us when contacting our customer care, complaints and  other customer focused functions. We also collect personal data through the use of telephone calls  and emails etc. where you have agreed to the use of this particular service. 

Where we collect data directly from you, we are considered to be the controller of that data i.e. we  are the data controller. Where we use third parties to process your data, these parties are known as 

processors of your personal data. Where there are other parties involved in underwriting or  administering your mortgage, financial, assurance and insurance requirements they may also process  your data in which circumstance we will be a joint data controller of your personal data. 

A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines  the purposes and means of the processing of personal data. 

A data ‘processor’ means the individual or organisation which processes personal data on behalf of  the controller. 

As a provider of mortgage, assurance, financial and insurance services, we will process the following  categories of data: 

∙ Personal data such as an individual’s name, address, date of birth, gender, contact details and  details of historic claims 

∙ For mortgage and financial products credit and financial information financial data may  include but is not limited to income, expenditure, credit reports etc. 

∙ Special categories of personal data such as health and details on historic claims resulting in  injury (physical and physiological) 

∙ Data relating to criminal convictions and offences such as details of driving offences or insurance fraud 

If you object to the collection, sharing and use of your personal data we may be unable to provide you  with our products and services. 

For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United  Kingdom is identified as the named territory where the processing of personal data takes place. 

If you require more information about our mortgage, financial, assurance and insurance processes or  further details on how we collect personal data and with whom we share data with, please contact  our data privacy representative by e‐mailing stevef@smartmoneysolutions.co.uk . 

WHY DO WE NEED YOUR PERSONAL DATA? 

We will use your personal data for the performance of our contract with you, to quote for and provide  you with mortgage finance, other financial products, assurance and insurance products and services,  to process claims, renewals and applications, to administer your policy and our business, to respond  to any requests from you about services we provide and to process complaints. We will also use your  personal data to manage your account, perform statistical analysis on the data we collect, for financial  planning and business forecasting purposes and to develop new and market existing products and  services. 

We will use the special category and criminal conviction data we collect about you for the performance  of our contract with you which is deemed to be necessary for reasons of substantial public interest.  This allows us to quote for and provide you with mortgage assurance and insurance products and  services, to process claims and renewals and to administer your policy. 

In purchasing our products and services you should understand that you are forming a contract with  us. If you contact us for a quote or request details on the services we provide, we consider ourselves  as having a legitimate business interest to provide you with further information about our services.

In some situations we may request your consent to market our products and services to you, to share  your data. Where we require consent, your rights and what you are consenting to will be clearly  communicated to you. Where you provide consent, you can withdraw this at any time by contacting  our data privacy representative 

We will retain your personal data in the following areas 

At the end of any contractual agreement we will retain special category and criminal conviction data.  Where you have submitted a claim, we will retain your data, if it is a no injury claim; where an  individual has been injured (physical and physiological), we will retain your data. Where you have  requested a quote, we will retain your personal data. Where you have contacted us for details of our  services and products, we will retain your personal data where you make a complaint we will retain  the data. 

Where you or law enforcement agencies inform us about any active investigation or potential criminal  prosecution, we will comply with legal requirements when retaining this data 

We will retain your data for a minimum of 3 years BUT could be longer for the following reasons 

The retaining of data is necessary where required for contractual, legal or regulatory purposes or for  our legitimate business interests for statistical analysis (profiling) and product development and  marketing purposes. 

Sometimes we may need to retain your data for longer, for example if we are representing you or  defending ourselves in a legal dispute or as required by law or where evidence exists that a future  claim may occur. 

You should be aware that we use automated decision making (services/tools and techniques) to check  for customer suitability to our products, for example we might perform a credit search to check an  individual’s solvency and credit rating. We also analyse data to identify products and services that  customers may be interested in, this is commonly known as profiling. You have the right to object to  the use of profiling activities and the use of automated decision making (services/tools and  techniques). 

YOUR RIGHTS 

Individuals are provided with legal rights governing the use of their personal data. These grant  individuals the right to understand what personal data relating to them is held, for what purpose, how  it is collected and used, with whom it is shared, where it is located, to object to its processing, to have  the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing.  Individuals can also request the deletion of their 

personal data. 

These rights are known as Individual Rights under the Data Protection Act 2018. The following list  details these rights: 

∙ The right to be informed about the personal data being processed; 

∙ The right of access to your personal data; 

∙ The right to object to the processing of your personal data; 

∙ The right to restrict the processing of your personal data;

∙ The right to rectification of your personal data; 

∙ The right to erasure of your personal data; 

∙ The right to data portability (to receive an electronic copy of your personal data); ∙ Rights relating to automated decision making including profiling. 

Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a  fee to process these requests, however if your request is considered to be repetitive, wholly  unfounded and/or excessive, we are entitled to charge a reasonable administration fee. 

In exercising your Individual Rights, you should understand that in some situations we may be unable  to fully meet your request, for example if you make a request for us to delete all your personal data,  we may be required to retain some data for taxation, prevention of crime and for regulatory and other  statutory purposes. 

You should understand that when exercising your rights, a substantial public or vital interest may take  precedence over any request you make. In addition, where these interests apply, we are required by  law to grant access to this data for law enforcement, legal and/or health related matters. 

The flow of data within the insurance sector is complex and we ask you to keep this in mind when  exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations  to help satisfy your request this may impact on timescales. 

If you require further information on your Individual Rights or you wish to exercise your Individual  Rights, please contact our data privacy representative by e‐mailing stevef@smartmoneysolutions.co.uk marking the email data privacy or by writing to Compliance  officer F & R Associates 33 High Dyke, Harrowby, Grantham Lincolnshire NG31 9ER. 

PROTECTING YOUR DATA 

We will take all appropriate technical and organisational steps to protect the confidentiality, integrity,  availability and authenticity of your data, including when sharing your data within our firm, group of  companies, business, including affiliates, subsidiaries and authorised third parties. 

To ensure data privacy and protection has appropriate focus within our organisation we have a Data  Privacy Representative who reports to our senior management team. The Data Privacy  Representative’s contact details are as follows: Steve Foster. Tel. 03456440661 

COMPLAINTS 

If you are dissatisfied with any aspect of the way in which we process your personal data please  contact compliance officer F&R Associates. You also have the right to complain to the UK’s data  protection supervisory authority, the Information Commissioner’s Office(ICO). The ICO may be  contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline  on 0303 123 1113. 

HOW TO CONTACT US 

If you have any questions regarding this Notice, the use of your data and your Individual Rights please  contact our data privacy representative at 33 High Dyke, Harrowby, Grantham Lincolnshire, NG31 9ER  or by e‐mailing stevef@smartmoneysolutions.co.uk or by telephoning 03456440661