Privacy Policy
1 Level Limited are committed to respecting and protecting your privacy.
Your personal data includes all the information we hold that identifies you or is about you. Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it.
This privacy notice applies to all personal data processed by 1 Level Limited. Company Number 11474463.
The controller of your personal data will be the company with which you are interacting or which is providing you with services.
This policy applies to all our clients, customers, suppliers and contacts including (but not limited to):
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Home owners;
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Applicants;
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Building managers;
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Business suppliers;
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Website users;
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Individuals who have made enquiries with us either in person, by phone, email, post or through our website;
How do we collect personal information about you?
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We may collect personal information from the following general sources:
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From you directly;
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From your family members (for example, mortgage or conveyancing referrals);
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From a broker or other intermediary who we work with to provide products or services or quote to you;
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From business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are involved in providing your products and services or operating our business; and
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From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents and other organisations to the extent they share your data with us in relation to the prevention and detection of crime, including police and law enforcement agencies.
What kinds of personal information about you do we collect and process?
The personal information we collect from you and that we will process in connection with all our products and services might include (but is not limited to):
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Personal and contact details, such as your title, full name, email address, phone number and residential address;
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Your date of birth, gender and age;
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Information about your family members (if relevant to the product or service);
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Information about the ways in which you have previously made contact as well as your contact preferences including whether you prefer to be contacted by phone, personal visit, email or via our smartphone app;
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Information about the products and services you have purchased from us and/or our business partners and group companies;
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Payment information;
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Information about your interactions with our marketing communications as well as analytical data that we use to determine which marketing communications you may be interested in;
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Information we obtained from third parties, including information such as landlord references, title checks (property ownership), ID checks (Anti Money Laundering requirements), credit reference checks and history together with financial situation and history (including salary and other income, savings and expenditure, borrowings and loans), fraud prevent checks, and information from public sources such as default and CCJ data;
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Where it is relevant to the services we provide to you, information about your health and medical conditions or if you are a vulnerable customer to ensure we can properly deliver our services;
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Where it is relevant to the provision of home set up services, details of the property you are moving from and to, moving dates, council tax status and other associated information such as the number of occupants moving;
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Information about your property, such as location, value, number of rooms, property type and building work you have had done;
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Information about your employment status, if relevant;
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Information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application;
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Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK together with identification documents such as passport and recent utility bill;
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Your marital status, family, lifestyle or social circumstances, if relevant to the product or service (for example, the number of dependents you have);
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Where relevant, information about any guarantor which you provide in any application;
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Tax information, if relevant (for example, mortgage application, landlord inland revenue status); and
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How long do we retain your personal information?
We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including product and/or service delivery, and to satisfy any legal, tax, health and safety, reporting or accounting requirements to which we are subject.
In most cases we retain your personal data for a period of 7 years following our last contact or communication with you.
If we send you marketing materials and do not have any other relationship with you, we will send you marketing for a 7 year period. If at the end of the 7 year period you have not contacted us or interacted with our marketing communications, we will cease to send marketing to you. We will also delete your personal data at that stage unless we have reason to retain it for a longer period.
We will retain your personal data for longer than the 7 year period if required or permitted under applicable laws, regulations and guidance.
If you are a candidate and your application is successful, we will retain your personal data in line with our employee facing privacy policy. If your application is unsuccessful we will retain your personal data for a period of 6 months in case an alternative suitable role becomes available.
How do we use your personal information?
We may use the information that you directly provide to us in the following ways:
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Where you are a home owner or another individual or employee of an organisation that has entered into a contract with us, we process your personal data to provide you with products and services you have requested and otherwise to fulfil our contractual obligations to you, including management of our relationship with you. Where our contact is with you individually, we process the information on the grounds of contract fulfilment or, where we are taking steps that fall outside of our contractual obligations, on the grounds of our legitimate interests in managing our relationship with you. If our contract is with the organisation for which you work, we process your personal data on the grounds of our legitimate interests in fulfilling the contract with your organisation;
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If you have contacted us via our website, in person, by email, post or any other means we will process your personal data to the extent necessary to provide you with information you have requested from us, respond to enquiries or requests from you, communicate with you in relation to those enquiries or requests and, if applicable, to arrange visits to your property by our staff or lettings contractors in order to fulfil a repair request.
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Where you have provided your consent for us to do so we will process your personal data to the extent necessary to send you marketing communications.
We may use your name, email address and postal address to provide you with information regarding similar goods and services to those you have already enquired about or purchased. Our legal basis for this use is our legitimate interests, namely the ongoing marketing of our goods and services to individuals with whom we have an existing relationship in connection with our goods and services and/or who have expressed an interest in those goods and services; -
Where you have provided your consent we will process special category data about you (usually health and medical information) to the extent we need to know the information in order to provide services to you, for example to ensure properties are accessible; or
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Where you have entered into a contract with us or we have provided you with services, we may process your personal data for the following reasons on the grounds of our legitimate interests in administering and managing our business contracts, relationships and, where necessary, improving the quality of our services:
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To ask you to provide feedback about our products and services;
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To notify you of changes to our terms and conditions of services or other relevant documents, such as our privacy policy; and
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To undertake fraud and credit risk searches and applications.
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We may also process your information on the grounds of our legal obligations to verify your identity where necessary to enable us to market your property or provide services in relation to mortgage applications, purchase or rental of a property.
We may use the information that we automatically collect using technical means through our website to:
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Administer our site and for troubleshooting, testing, research and statistical purposes. We use Google Analytics, a third-party website monitoring tool. Our legal basis for this is our legitimate interests, namely monitoring the use of our software and IT systems, improving our website;
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Measure or understand the effectiveness of our own advertising activity. Our legal basis for this use is our legitimate interests, namely improving the relevancy of our advertising; and
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Measure or understand the effectiveness of our marketing emails. Our legal basis for this use is legitimate interests and/or consent.
Automated collection of information may involve the use of cookies. Please see our Cookies Policy for further detail about these.
We may analyse the personal information we collect directly from you and obtain using automated technical means to create a profile of your interests and preferences so that we can contact you with information relevant to you (if you have chosen to receive marketing communications from us).
We rely on the following legal bases to use your personal data:
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Sharing your personal information with business partners and services providers when you apply for a product to help manage your product; and
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For some of our profiling and other automated decision making to decide whether to offer you a product and/or service, particular payment method and the price or terms of this.
Who has access to information?
We will not sell or rent your information to third parties.
We may share your information with third parties to the extent necessary for us to achieve the purposes listed above, including (but not limited to):
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Business partners (for example, financial services institutions, insurers, solicitors, accountants, removals, account beneficiaries and and services providers) or others who are involved in the provision of our products and services or operating our business or who require sight of or access to your personal data in order to provide us with services or advice;
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Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Ombudsman, the Information Commissioner’s Office and the Financial Services Compensation Scheme;
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Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
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Credit Reference and Fraud Prevention Agencies;
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When we share your data we do so in accordance with agreements that require the recipient to keep your information secure and to use it only in accordance with applicable data protection law.
We may also transfer your personal information to a third party as part of a sale of some or all of our business and assets, or as part of any business restructuring or reorganisation, or where such disclosure is necessary for compliance with a legal obligation to which we are subject for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure (for example, to our legal advisers).
Your rights
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organis...). These rights apply for the period in which we process your data. There are certain caveats and exemptions to those rights which mean that in some circumstances you may not be entitled to exercise them, if we believe that is the case upon receipt of a request from you, we will let you know.
Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information.
Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you.
Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data, but we do not have to delete it.
Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller.
Right to object
You are entitled to object to us processing your personal data:
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If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
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For direct marketing purposes (including profiling); and/or
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For the purposes of scientific or historical research and statistics.
We do not intend to use your personal data to send you direct marketing nor for scientific or historical research and statistics.
Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement.
Use of Cookies
To help us improve our website and the products and services we offer, we collect data about the ways in which you use our website. This includes, for example, technical data such as your IP address, which is collected through our use of cookies. More information (including the retention period for each cookie) can be found in our cookie policy, available here Cookies Policy
How do we share your information with credit reference agencies?
To process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take insurance, financial or credit services from us we may also make periodic searches at CRAs to manage your account with us. To do this we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
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Assess your creditworthiness and whether you can afford to take the product;
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Verify the accuracy of the data you have provided to us;
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Prevent criminal activity, fraud and money laundering;
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Assess payment methods available to you;
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Make sure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also notify the CRAs about your settled accounts. If you borrow and don’t repay in full and on time, CRAs will record the outstanding debt. This information may be given to other organisations by CRAs. The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail on our website.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
What should you do if your personal information changes?
You should tell us so that we can update our records by calling one of our offices or emailing contact@1levelltd.uk.
Do you have to provide your personal information to us?
We are unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we will make this clear.
Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: taking and keeping records (as the case may be) of email, text messages, social media messages, in person (face to face) meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
Questions or concerns
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, please get in touch with us so we can help. You can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.