Terms & Conditions

Terms & Conditions / Privacy & Legal

Vita Financial Limited (“Vita”) takes your privacy very seriously. We promise to do all that we can to protect it.

 

Client Privacy Notice

Capital Protect Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 3368205

Mortgage Advice Bureau (Holdings) plc. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 04131569

Both companies known together in this document as “we” and “us”

As joint controllers of your data, Capital Protect and Mortgage Advice Bureau comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how we process your personal data.

 

The personal data we collect about you

Personal data collected, used, stored and transferred by us may include:

  • Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
  • Contact Data including home address, email address and telephone numbers
  • Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
  • Special Category Data specifically medical history
  • Transaction Data including payments made for products and services you have purchased from us
  • Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Vita or Mortgage Advice Bureau websites
  • Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
  • Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences

 

How do we collect your personal data?

Personal data is collected by us using the following methods:

  • Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing and applying for protection products, processing Identity, Contact and Financial categories of personal data.
  • Automated technologies or interactions with our website, by using the web enquiry form, processing Identity, Contact, Financial and Technical categories of personal data.

Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:

  • Third-party firms and advisers with whom you may be interacting, but only with your consent;
  • Enquiries you may perform on third-party protection product sourcing websites

 

How do we use your personal data?

We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Purpose/Activity Type(s) of data Lawful basis for processing
To initially engage with you to discuss your requirements ·         Identity·         Contact Consent
To process and deliver your application for a protection product ·         Identity

·         Contact

·         Financial

·         Special Category

·         Transaction

·         Marketing & Comms

Performance of a contract with you

Necessary for our legitimate interests

(to recover debts due to us)

To manage our relationship with you which will include:

·         Notifying you about changes to our terms or privacy policy

·         Customer reviews / surveys

·         Re-engagement to review protection needs

·         Identity·         Contact·         Profile & Usage·         Marketing & Comms Performance of a contract with youTo comply with a legal obligationNecessary for our legitimate interests(to re-engage with you to review your protection needs, and to maintain and improve customer service standards)
To respond to case enquiries and input to & defend against complaints ·         Identity

·         Contact

·         Profile & Usage

·         Transaction

·         Marketing & Comms

To comply with a legal obligation

Necessary for our legitimate interests

(to ensure that complaints can be responded to accurately)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) ·         Identity

·         Contact

·         Technical

To comply with a legal obligation

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you ·         Identity

·         Contact

·         Profile & Usage

·         Marketing & Comms

·         Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences ·         Technical

·         Profile & Usage

Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our marketing strategy)

 

 

Change of purpose

We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 25th June 2018. Historic versions can be obtained by contacting us.

 

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services. You can opt-out of receiving these types of communications at any time by contacting the Compliance team at compliance@mab.org.uk or by clicking on the relevant link in email communications you receive from us.

 

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

 

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Cookies

Vita sends cookies to your computer from the Vita website. Cookies are pieces of information that a website transfers to your computer. Cookies can make the web more useful to you by storing information about your preferences on particular websites, which allows website owners to provide more useful features for their users.

 

Vita uses cookies and tracking software to monitor customer traffic patterns and site usage in order to develop the design and layout of the site to better meet the needs of visitors to the Vita website. This will include non-specific data such as mouse-movements and pages visited.

 

Should you wish to restrict the data that we collect through our tracking software, you can alter your cookies setting in your browser.

 

Website Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

Sharing of personal data outside of the European Economic Area

Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where such transfers are necessary, we use specific contractual clauses approved by the European Commission that provide the same level of protection for personal data as it has in the EEA, and we rely on the EU-US Privacy Shield Framework for data shared with third parties in the US.

 

Who we disclose personal data to
Your personal data may be shared with third parties for the following purposes:

 

Type of recipient Reason
Within Mortgage Advice Bureau Group Depending on your requirements, it may be necessary to share your personal data with other specialist product providers in order for suitably qualified advisers to source relevant products (e.g. Building & Contents cover) and services or to re-engage with existing clients
Protection product suppliers To source and submit applications in order to conclude the contract for the protection application and the ongoing servicing of these contracts.
External suppliers Specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to us.
Firm of mortgage/protection advisers who referred you to Vita We may share information about the progress of your application with the firm of mortgage / protection advisers, with whom you initially interacted.
Regulators Sharing of information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.
Licensed Credit Agencies For the purposes of confirming your identity for fraud prevention; to perform a credit assessment to assess your eligibility
Others Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

 

These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.

 

How long is your personal data retained?

We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

 

Purpose of processing Retention
Successful protection applications For the full protection policy term plus a further 6 years
Withdrawn, stalled, incomplete and failed protection applications 2 years from the date the latest application was started
Enquiry data obtained from third parties (e.g. websites) that do not result in an application for a protection product 2 years from the date the lead was received from the Introducer

 

After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

 

 

Your legal rights regarding your personal data

 

You have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

 

Questions

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing Data.Protection@mab.org.uk or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

 

 

What if I am still not satisfied?

If you are not satisfied with the response to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

 

  1. 001-14.08.18

 

Errors and Omissions

If you believe that there may be an error in any of the information that you have submitted via this website, please email: questions@vita.co.uk. We will review your records as soon as possible.

Consent

We do not intentionally collect any information via this website from children under 16 years of age, and shall delete the details when a parent or guardian notifies us that details have been obtained from their child.

Additional Information

We will amend this privacy statement from time to time and for this reason, it is valid for a period of 1 day from the date you have viewed it. We recommend that you read this statement regularly.

Telephone Recording Policy

For our joint protection and for staff training, some calls may be recorded / monitored.

Vita has a telephone system in the Main Office that is capable of recording conversations made inbound and outbound via the landline. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes. If you require further details about our ‘Telephone Recording Policy’ please contact Vita and ask to speak to the Compliance Department.

Regulatory Information

Vita is a trading style of Vita Financial Ltd, which is an appointed representative of Capital Protect Ltd, which is authorised and regulated by the Financial Conduct Authority. Their Financial Services Register number is 531444.

The Financial Conduct Authority (FCA) was established by government to regulate the financial services industry in the UK. The FCA is committed to securing the appropriate degree of protection for consumers and promoting public understanding of the financial system.

The FCA have set out rules which regulate the sale and administration of insurance which we must follow when we deal with you. Our Financial Services Register number is 529693. This information can be checked by visiting the Financial Services Register or by contacting the FCA on 0800 111 6768 within the UK and Channel Islands or +44 (0)20 7066 1000 if you are calling from outside the UK and Channel Islands.

Vita is a trading name of Vita Financial Limited.

Registered address: 1st Floor Tudor House, 16 Cathedral Road, Cardiff, CF11 9LJ. Company No. 7266691, registered in England and Wales.

Your Rights

Vita is committed to delivering the rights that the Data Protection Act 1998 and Privacy and Electronic Communications Regulations provides to individuals.

Amongst these are:

  • The right to object to your personal information being used for direct marketing. We will give you the ability to object to this. Where required we will ensure we obtain your consent before undertaking marketing;
  • The right to request a copy of the personal information Vita holds about you. To do this, please write to us with full details of what you require at the following address: Compliance Department, Capital Protect Limited, Capital House, Pride Place, Derby, DE24 8QR.

Our number one priority is to provide customers with the highest level of service. However we know that sometimes things can go wrong. Customer feedback helps us understand where things have gone wrong and gives us the opportunity to put them right. It also helps us understand where we need to improve our products and services.

If you have a complaint about your Adviser or the service you received please contact us.

Post: Compliance Department (Complaints), Mortgage Advice Bureau Limited, Capital House, Pride Place, Derby, DE24 8QR.

Email: Compliance@mab.org.uk

Phone:  01332 200020 extension 2009. We may record and monitor calls.

If your complaint cannot be resolved straightaway we will:

• Acknowledge receipt in writing, confirming our understanding of your complaint, who will be handling it and giving you the opportunity to provide any further information or documents

• After investigating your complaint we will respond, as quickly as possible and if no decision has been reached we will update you on progress after 8 weeks.

The Financial Ombudsman Service

If you’re dissatisfied with our response, you can ask the Financial Ombudsman Service for an independent review free of charge, but you must do so within six months of the date of MAB’s final response letter.

The Financial Ombudsman Service (FOS) will only consider your complaint once you’ve tried to resolve it with us, so please take up your concerns with us first and we’ll do all we can to help. We do our best to resolve complaints and only around 15% of cases are referred to the FOS for an adjudication.

The FOS is also only able to consider certain categories of complaint, for example complaints about Buy to Let mortgages, which are not regulated by the Financial Conduct Authority will normally be outside the jurisdiction of the FOS.

In addition, the FOS might not be able to consider your complaint if:

• what you’re complaining about happened more than six years ago, and

• you’re complaining more than three years after you realised (or should have realised) that there was a problem.

If your complaint was made outside of these time limits, which is a matter for The Ombudsman to decide, The Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if it believes that the delay was as a result of exceptional circumstances.

Further information on the services provided by the Financial Ombudsman Service can be found on their website: http://www.financial-ombudsman.org.uk or alternatively,

Post: The Financial Ombudsman Service, Exchange Tower, London. E14 9S

Phone: 0800 023 4567 or 0300 123 9123

Email:  complaint.info@financial-ombudsman.org.uk

Alternative Dispute Resolution (ADR) Directive 

Alternative Dispute Resolution (ADR) Directive. The ADR directive is European law, which means alternative ways of resolving contractual disputes between consumers and businesses are available. The Financial Ombudsman Service (FOS) is the ADR provider for Financial Services in the UK and will provide a complaint handling service under the ADR Directive in addition to its role as an Ombudsman Service.

Mortgage Advice Bureau has decided to continue dealing with customer’s complaints when they are received rather than pass responsibility to the FOS under the ADR Directive. This does not affect customers’ statutory rights of referral to the FOS as outlined above.

Online Dispute Resolution Platform (ODR). Complaints about Financial Services firms may also be sent to the Online Dispute Resolution website; http://ec.europa.eu/consumers/odr.

Any complaints received via the ODR, will be forwarded to the FOS and then to MAB. Complaints received by this method will be treated in the same way as those received through existing means.

Cookies

Vita sends cookies to your computer from this website. Cookies are pieces of information that a website transfers to your computer. Cookies can make the web more useful to you by storing information about your preferences on particular websites, which allows website owners to provide more useful features for their users.

Vita uses cookies and tracking software to monitor customer traffic patterns and site usage in order to develop the design and layout of the site to better meet the needs of visitors to this website. This will include non-specific data such as mouse-movements and pages visited.

Should you wish to restrict the data that we collect through our tracking software, you can alter your cookies setting in your browser.

Third Party Links

This website may contain links to other websites which are outside our control and are not covered by this Privacy Statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.

Complaints

If you have a complaint, please contact us using any of the following methods:

  • By Post:

Compliance Department (Complaints), Capital Protect Limited, Capital House, Pride Place, Derby, DE24 8QR

  • By Phone

Tel: 01332 200020

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.