Privacy Policy

1. Who we are

Fresh Finance Group Ltd ("Fresh Finance Group", "we", "us", "our") is a data controller registered in England and Wales (Company No. 05706346). Our registered office is at 10 King Street, Newcastle-under-Lyme, Staffordshire ST5 1EL.

We are an appointed representative of PRIMIS Mortgage Network (trading name of Personal Touch Financial Services Ltd), which is authorised and regulated by the Financial Conduct Authority. The Network is responsible for the quality of mortgage and insurance advice and regulatory compliance.

2. What personal data we collect

We may collect and process the following personal data:

• Identity data: name, date of birth, National Insurance number
• Contact data: email address, phone number, postal address
• Financial data: income, outgoings, credit history, existing debts, property details
• Technical data: IP address, browser type, pages visited (via cookies)
• Communications: emails, phone call notes, form submissions

Most information comes directly from you through written documentation or telephone calls, which may be recorded. Information may also come from joint account holders, authorised third parties, lead generators, professional contacts (accountants, employers, banks), lenders, insurers, or legal representatives.

If we receive any sensitive information about you, we will always ask for your agreement before using or retaining it. If you do not provide the information we require, we may be unable to provide our services.

3. How we use your data

We use your personal data to:

• Provide mortgage and protection advice (contractual necessity)
• Submit mortgage and insurance applications on your behalf (contractual necessity)
• Meet legal and regulatory obligations (legal obligation)
• Conduct identity verification and anti-financial-crime compliance
• Communicate with you about your enquiry or case (legitimate interest)
• Send you relevant information about products and services (consent, where given)

4. Who we share your data with

We may share your data with:

• Mortgage lenders and insurers, for the purpose of sourcing and applying for products
• PRIMIS Mortgage Network, for regulatory oversight and compliance purposes
• Credit reference agencies, to assess your creditworthiness (with your consent)
• Solicitors and estate agents, where required as part of a transaction
• Law enforcement agencies and regulated financial institutions, as required by law
• The Financial Ombudsman Service, in connection with complaints
• IT and system providers who process data on our behalf

We do not sell your personal data to third parties.

5. How long we keep your data

We retain records relating to mortgage and protection advice for a minimum of 6 years following expiry. Records relating to equity release and pension transfers are retained indefinitely. Marketing contact records are retained until you opt out or unsubscribe. In some cases, data may be retained longer where there is a legitimate legal or regulatory reason.

6. Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you
• Rectification of inaccurate or incomplete data
• Erasure of your data in certain circumstances
• Restriction of processing in certain circumstances
• Portability of your data
• Object to processing based on legitimate interests
• Withdraw consent at any time where processing is based on consent

To exercise any of these rights, please write to us at Fresh Finance Group Ltd, 10 King Street, Newcastle-under-Lyme, Staffordshire ST5 1EL, or email info@freshfinancegroup.com. Please include a copy of a valid form of identity (e.g. passport).

7. Cookies

Our website uses cookies to improve your experience. These include cookies for browser verification, login preferences, and screen settings. You can manage cookie preferences via your browser settings.

8. Data storage

Records are stored in secure UK-based paper and electronic formats. Our servers are located in the United Kingdom and your personal information is expected to remain within the United Kingdom at all times.

9. Complaints about data handling

If you have concerns about how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

10. Changes to this policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated date. We encourage you to review this page periodically.