GDPR Privacy Statement

1. Introduction

Capital Finance Brokers Limited (trading as Capital Finance) is committed to protecting the privacy and security of your personal data. This Privacy Statement explains how we collect, use, store, and protect your personal information when you visit our website, use our services, or otherwise interact with us.

Capital Finance Brokers Limited is a directly authorised mortgage and insurance intermediary, authorised and regulated by the Financial Conduct Authority (FCA), Firm Reference Number 943805. We are registered as a data controller with the Information Commissioner’s Office (ICO), registration number ZB288088.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is Capital Finance Brokers Limited, 81 Rivington Street, London, EC2A 3AY.

This Privacy Statement applies to all visitors to our website at www.capitalfinance.co.uk and to all individuals whose personal data we process in connection with our mortgage and protection intermediation services. We may update this Privacy Statement from time to time. The most current version will always be available on our website.

2. Who Is Covered by This Statement

This Privacy Statement applies to all individuals whose personal data we process, including:

Visitors to our website
Prospective, current, and former clients
Joint applicants and connected parties to mortgage or protection applications
Individuals whose data is provided to us by third parties (such as introducers or solicitors)
Individuals who contact us with enquiries or complaints

3. Personal Data We Collect

We may collect, use, store, and transfer different categories of personal data about you, depending on the nature of your interaction with us. The table below sets out the categories of personal data we may process:

Category of Data	Examples
Identity Data	Full name, title, date of birth, gender, marital status, nationality, National Insurance number
Contact Data	Residential address, email address, telephone numbers
Financial Data	Income details, employment information, bank account details, credit history, existing mortgage and loan details, pension and investment details
Property Data	Property address, property value, property type, tenure, rental income details
Identity Verification Data	Passport or driving licence details, electronic identity verification results, proof of address documentation
Technical Data	IP address, browser type and version, time zone setting, operating system, device information
Usage Data	Information about how you use our website and services
Marketing and Communications Data	Your preferences in receiving communications from us
Special Category Data	Health information (where relevant to protection product applications or vulnerable customer assessment)

3.1 How We Collect Your Personal Data

We collect personal data from you through a variety of means, including:

Direct interactions: when you complete fact-find forms, submit enquiries through our website, correspond with us by telephone, email, or otherwise, or provide documentation in support of a mortgage or protection application.
Automated technologies: when you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns using cookies and similar technologies. Please see Section 10 (Cookies) for further details.
Third parties: we may receive personal data about you from various third parties including lenders, introducers, solicitors, credit reference agencies, electronic identity verification providers, and estate agents.

3.2 Special Category Data

In limited circumstances, we may need to process special category data about you. This most commonly relates to health information relevant to protection product applications (such as life insurance or income protection), or information necessary to identify and support customers in vulnerable circumstances in accordance with our Consumer Duty obligations.

Where we process special category data, we will do so only where we have a valid lawful basis and an appropriate condition under Article 9 of the UK GDPR. We will always handle such data with the utmost care and confidentiality.

4. How and Why We Use Your Personal Data

We will only use your personal data when the law allows us to. The table below sets out the purposes for which we process your personal data and the legal basis we rely on in each case:

Activity	Purpose	Lawful Basis
Mortgage advice and arrangement	To assess your circumstances, research suitable products, and submit applications to lenders on your behalf	Performance of a contract; Legal obligation; Legitimate interests
Protection advice and arrangement	To assess your insurance needs and arrange suitable protection products	Performance of a contract; Legitimate interests
Identity verification and anti-money laundering checks	To verify your identity using electronic verification services and comply with AML regulations	Legal obligation
Financial sanctions and PEP screening	To screen against HM Treasury sanctions lists and identify politically exposed persons	Legal obligation
Affordability assessment	To assess your ability to meet mortgage repayments and ensure suitability of advice	Legal obligation (MCOB); Legitimate interests
Communicating with you	To contact you regarding your application, provide updates, and respond to enquiries	Performance of a contract; Legitimate interests
Complaints handling	To investigate and resolve complaints in accordance with FCA requirements	Legal obligation; Legitimate interests
Regulatory compliance	To comply with FCA rules, including record-keeping, reporting, and Consumer Duty obligations	Legal obligation
Website analytics	To analyse website usage patterns and improve our online services	Consent (cookies); Legitimate interests
Marketing communications	To send you information about our services where you have consented or where we have a legitimate interest	Consent; Legitimate interests
Vulnerable customer support	To identify and provide appropriate support to customers in vulnerable circumstances	Legitimate interests; Legal obligation (Consumer Duty)

4.1 Legitimate Interests

Where we rely on legitimate interests as a lawful basis for processing, we have carried out a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms. You may request details of this assessment by contacting us using the details set out in Section 13 of this Statement.

4.2 Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is 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.

5. Who We Share Your Personal Data With

We may share your personal data with the following third parties for the purposes described below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.

Third Party	Purpose of Sharing
Mortgage lenders and building societies	To process your mortgage application and arrange lending on your behalf
Insurance providers and underwriters	To obtain quotations and arrange protection products
Mortgage Brain (sourcing platform)	To research and compare mortgage products across the market
Electronic identity verification provider	To verify your identity in compliance with AML regulations
HubSpot (CRM platform)	To manage our client relationships, communications, and service delivery
Google Analytics	To analyse website usage and improve our online services
Credit reference agencies	Where required by lenders as part of the application process (lender responsibility)
HM Revenue & Customs, regulators, and law enforcement	Where we are legally obliged to share information
The Financial Conduct Authority (FCA)	For regulatory reporting and compliance purposes
The Financial Ombudsman Service (FOS)	In connection with complaint resolution where applicable
The National Crime Agency (NCA)	For suspicious activity reporting where legally required
Professional advisers	Including lawyers, auditors, and compliance consultants where necessary
IT service providers	For secure hosting, maintenance, and support of our systems

We do not sell your personal data to any third party. We do not share your personal data with third parties for their own marketing purposes without your explicit consent.

6. International Transfers

We are based in the United Kingdom and primarily process your personal data within the UK. However, some of our third-party service providers may process your data outside the UK (for example, where cloud-based services use servers located in other jurisdictions).

Where your personal data is transferred outside the UK, we will ensure that appropriate safeguards are in place to protect it, in accordance with the UK GDPR. These safeguards may include:

Transfers to countries which the UK Government has determined provide an adequate level of protection for personal data
Use of specific contracts approved by the UK Information Commissioner’s Office (International Data Transfer Agreement or International Data Transfer Addendum to the EU Standard Contractual Clauses)
Binding corporate rules for transfers within a corporate group

Please contact us using the details in Section 13 if you would like further information about the specific safeguards applied to the international transfer of your personal data.

7. How Long We Retain Your Personal Data

We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In determining the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and applicable legal, regulatory, and professional requirements.

As a general guide, the following retention periods apply:

Mortgage and protection client files: a minimum of six years from the end of the client relationship, or longer where required by specific regulatory obligations.
Anti-money laundering records: five years from the end of the business relationship, in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Complaints records: a minimum of three years from the date of complaint resolution, in accordance with FCA DISP requirements.
Website analytics data: retained for a maximum of 26 months from the date of collection.
Marketing consent records: retained for as long as your consent remains valid, plus a reasonable period thereafter to evidence consent was obtained.

Where we no longer require your personal data, we will securely delete or anonymise it in accordance with our data retention and disposal procedures.

8. Data Security

We have implemented appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised manner. These measures include:

Encryption of data in transit and at rest
Access controls restricting personal data to authorised personnel on a need-to-know basis
Password protection and multi-factor authentication for systems containing personal data
Regular security assessments and testing of our IT systems
Staff training on data protection and information security obligations
Clear desk and clear screen policies for all staff, including those working remotely
Secure disposal procedures for paper and electronic records containing personal data
Data protection impact assessments for high-risk processing activities

We have procedures in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so, in accordance with the UK GDPR and our obligations to the ICO.

9. Your Rights Under the UK GDPR

Under the UK General Data Protection Regulation, you have a number of rights in relation to your personal data. These rights are summarised in the table below:

Your Right	Description
Right of Access	You have the right to request a copy of the personal data we hold about you. This is commonly known as a Subject Access Request (SAR).
Right to Rectification	You have the right to request that we correct any personal data that is inaccurate or incomplete.
Right to Erasure	You have the right to request that we delete your personal data in certain circumstances. Please note this right is not absolute and may be subject to legal or regulatory retention requirements.
Right to Restrict Processing	You have the right to request that we restrict the processing of your personal data in certain circumstances.
Right to Data Portability	You have the right to request that we transfer your personal data to another organisation or directly to you, in a structured, commonly used, and machine-readable format.
Right to Object	You have the right to object to our processing of your personal data where we are relying on legitimate interests as our lawful basis.
Right to Withdraw Consent	Where we rely on your consent as our lawful basis for processing, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing carried out before consent was withdrawn.
Rights Related to Automated Decision-Making	You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects.

9.1 Exercising Your Rights

If you wish to exercise any of the rights set out above, please contact us using the details provided in Section 13 of this Statement. We will respond to your request without undue delay and in any event within one month of receipt. In certain circumstances (for example, where your request is complex or we have received a number of requests), we may extend this period by a further two months, in which case we will notify you of the extension and the reasons for it.

You will not normally be required to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

9.2 Right to Complain

If you are not satisfied with how we have handled your personal data, or if you have a concern about our data protection practices, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: ico.org.uk
Telephone: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance using the details in Section 13.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. Cookies contain information that is transferred to your computer’s hard drive.

We use the following types of cookies:

Cookie Type	Purpose	Consent
Strictly Necessary Cookies	These cookies are essential for the website to function correctly. They enable basic functions such as page navigation and access to secure areas. The website cannot function properly without these cookies.	No consent required
Analytical / Performance Cookies	These cookies allow us to recognise and count the number of visitors and to see how visitors move around our website. This helps us to improve the way our website works. We use Google Analytics for this purpose.	Consent required
Functionality Cookies	These cookies are used to recognise you when you return to our website. They enable us to personalise our content for you and remember your preferences.	Consent required
Marketing / Targeting Cookies	These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and any advertising displayed on it more relevant to your interests.	Consent required

10.1 Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses cookies to help us analyse how visitors use our website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers which may be located outside the UK.

We have implemented IP anonymisation to ensure that your full IP address is never stored by Google. Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity, and providing other services relating to website activity and internet usage.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of our website.

10.2 Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

For further information about cookies and how to manage them, please visit www.allaboutcookies.org.

11. Marketing Communications

We may use your personal data to send you marketing communications about our services where you have consented to receive such communications, or where we have another lawful basis to do so (such as legitimate interests in the context of an existing or recent client relationship).

You have the right to opt out of receiving marketing communications at any time. You can exercise this right by:

Clicking the unsubscribe link in any marketing email we send you
Contacting us using the details set out in Section 13
Updating your marketing preferences through our communication channels

Where you opt out of receiving marketing communications, this will not affect the processing of your personal data for other purposes (for example, in connection with an active mortgage or protection application).

12. 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 statement of every website you visit.

13. Contact Details

If you have any questions about this Privacy Statement, wish to exercise any of your rights, or have a concern about how we process your personal data, please contact us:

Data Protection Contact: Prasath Suntaramoorthy

Firm: Capital Finance Brokers Limited

Address: 81 Rivington Street, London, EC2A 3AY

Email: info@capitalfinance.co.uk

Telephone: 0207 126 8515

ICO Registration Number: ZB288088

FCA Firm Reference Number: 943805

14. Changes to This Privacy Statement

We keep this Privacy Statement under regular review and may update it from time to time to reflect changes in our processing activities, legal requirements, or best practice guidance from the ICO or FCA.

Where we make material changes to this Privacy Statement, we will take reasonable steps to notify you, for example by placing a prominent notice on our website or by contacting you directly where appropriate.

This Privacy Statement was last updated in February 2025.