Privacy Policy

1. Who We Are

TFS Mortgages is a trading name of Anderson Reed Financial Services Ltd, a company registered in England and Wales under company number 13190705.

Our correspondence address is:

Anderson Reed Financial Services Ltd

Director General's House

15 Rockstone Place

Southampton

SO15 2EP

Anderson Reed Financial Services Ltd is the data controller responsible for personal information collected through the TFS Mortgages website. We are registered with the Information Commissioner's Office under registration number ZA921459.

Anderson Reed Financial Services Ltd is an Appointed Representative of Connect IFA Ltd, which is authorised and regulated by the Financial Conduct Authority. Anderson Reed Financial Services Ltd is entered on the Financial Services Register under reference number 947349.

In this policy, references to "TFS Mortgages", "we", "us" or "our" mean Anderson Reed Financial Services Ltd when operating the TFS Mortgages website and lead-generation service.

2. The Role of TFS Mortgages

The TFS Mortgages website operates solely as a lead-generation service.

TFS Mortgages does not:

• provide mortgage, equity release, protection, investment, tax or legal advice;
• assess or determine your eligibility for a mortgage or other product;
• recommend a particular lender, provider or product;
• make lending or underwriting decisions;
• submit applications to lenders; or
• guarantee that an adviser will be able to assist you or that an application will be accepted.

When you submit an enquiry, your information is received and administered by Anderson Reed Financial Services Ltd. An appropriately qualified adviser acting through Anderson Reed Financial Services Ltd may contact you to discuss your enquiry.

Any regulated advice is provided separately by Anderson Reed Financial Services Ltd after the appropriate regulatory disclosures and engagement process have been completed.

3. The Information We Collect

The information we collect depends on how you use the website and the type of enquiry you make.

Contact information

This may include:

• your full name;
• email address;
• telephone number; and
• any other contact information you choose to provide.

Enquiry information

This may include:

• the type of mortgage or service you are interested in;
• the subject and content of a message you send us;
• the date and source of your enquiry;
• records of correspondence and contact concerning your enquiry;
• the status and outcome of the enquiry; and
• internal administrative records relevant to handling it.

Property and financial information

For certain enquiries, particularly equity release enquiries, this may include:

• your age;
• property type;
• estimated property value;
• whether there is an outstanding mortgage;
• the approximate outstanding mortgage amount; and
• the general reason for your enquiry.

The initial TFS Mortgages enquiry forms are not intended for detailed financial records. Please do not send us passwords, bank-account details, payment-card information, identity documents, full credit reports, medical records or other unnecessary sensitive information through a website message or ordinary email.

If detailed information is required after an adviser contacts you, the adviser will explain the appropriate and secure way to provide it.

Marketing information

This may include:

• whether you have agreed to receive marketing;
• the marketing methods to which you agreed;
• when and how your preference was recorded;
• the version of the consent wording presented to you;
• your subsequent marketing preferences; and
• records of an unsubscribe request or objection.

Technical and website-use information

When you visit the website, we or our service providers may collect:

• your IP address;
• browser and device type;
• operating system;
• approximate location derived from your IP address;
• pages visited and actions taken;
• referral source;
• dates and times of visits;
• website security and diagnostic information; and
• cookie or similar-technology identifiers, where applicable.

Further information is available in our Cookie Policy.

4. How We Collect Your Information

We may collect information:

• directly from you when you complete a form;
• when you contact us by telephone, email or another communication method;
• when you respond to correspondence from us;
• automatically through essential website technologies and server logs;
• through analytics technologies where these are permitted and enabled;
• from a person acting on your behalf, where they are authorised to do so; and
• from Anderson Reed Financial Services Ltd staff when they update the administrative status of your enquiry.

Calls may be recorded for training, monitoring, security and compliance purposes. You will be informed when call recording applies.

5. How and Why We Use Your Information

We only process personal information where we have a lawful basis for doing so.

Where we rely on legitimate interests, those interests include:

• responding to enquiries people have chosen to submit;
• administering and improving the lead-generation service;
• maintaining accurate business records;
• protecting our systems and preventing fraud or misuse; and
• understanding the general effectiveness of the website.

We consider the effect of this processing on your rights and do not rely on legitimate interests where our interests are overridden by your rights and freedoms.

6. What Happens When You Submit an Enquiry

TFS Mortgages is not a separate legal entity from Anderson Reed Financial Services Ltd. Your information is therefore not sold or transferred to an unrelated company called Anderson Reed.

Your enquiry is received by Anderson Reed Financial Services Ltd through its TFS Mortgages trading name. Authorised members of the Anderson Reed Financial Services Ltd team may access it to:

• administer your enquiry;
• contact you using the details you supplied;
• understand the general nature of your request;
• determine which appropriately qualified team member should respond; and
• keep an administrative record of what happened to the enquiry.

Submitting an initial enquiry is not a mortgage application and does not guarantee eligibility, acceptance, contact by a particular adviser or any particular outcome.

If, after speaking with an adviser, you choose to receive advice or proceed with an application, additional information will be collected. That subsequent regulated-advice and application process is also covered by the Anderson Reed Financial Services Privacy Notice and the service documentation supplied to you.

7. Who We Share Information With

We do not sell personal information.

Where necessary and appropriate, we may share information with:

Anderson Reed personnel

Authorised employees, advisers, contractors and administrative personnel working for or on behalf of Anderson Reed Financial Services Ltd may access information where required for their role.

Connect IFA Ltd

Anderson Reed Financial Services Ltd is an Appointed Representative of Connect IFA Ltd. Information may be made available to Connect IFA Ltd where necessary for regulatory oversight, compliance, monitoring, complaint handling or the subsequent provision of regulated services.

Technology and professional service providers

We may use organisations that provide:

• website hosting;
• database and cloud storage;
• business email;
• enquiry-management or CRM systems;
• IT maintenance and cybersecurity;
• analytics and cookie-management services;
• professional legal, accounting or compliance services; and
• data backup and recovery services.

Where these organisations process information on our behalf, they must only use it in accordance with our instructions, contractual requirements and applicable data-protection law.

Lenders, providers and parties involved in an application

TFS Mortgages does not submit information directly to lenders as part of the initial lead-generation enquiry.

If you subsequently engage with an Anderson Reed adviser and choose to proceed, Anderson Reed Financial Services Ltd may share relevant information with lenders, product providers, Connect IFA Ltd, solicitors, surveyors, valuers and other parties involved in the requested service or application.

The adviser will explain the relevant processing and disclosures before that stage.

Legal and regulatory recipients

We may disclose information where reasonably necessary to:

• comply with a legal or regulatory obligation;
• respond to a court order or lawful request;
• cooperate with the Financial Conduct Authority, Information Commissioner's Office or another competent authority;
• establish, exercise or defend legal claims;
• prevent or investigate suspected fraud or misuse; or
• protect the rights, property or safety of our organisation, users or others.

8. International Transfers

Some of our technology or service providers may process information outside the United Kingdom.

Where personal information is transferred to a country that does not have an applicable UK adequacy regulation, we will use an appropriate lawful safeguard. This may include the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses or another safeguard permitted by UK data-protection law.

You may contact us if you would like further information about the safeguards applying to a particular transfer.

9. Marketing

Submitting an enquiry does not automatically subscribe you to marketing.

We will only send optional marketing where we have an appropriate lawful basis and have complied with the Privacy and Electronic Communications Regulations.

Where we rely on consent:

• the request will be separate from the enquiry submission;
• the organisation sending the marketing will be identified;
• the communication method will be specified;
• the choice will not be preselected; and
• refusing marketing will not prevent you from submitting an enquiry.

You may withdraw your consent or unsubscribe at any time by:

• using the unsubscribe facility provided in a marketing email; or
• contacting us at info@tfs-mortgages.co.uk.

Withdrawing marketing consent does not affect the lawfulness of processing carried out before withdrawal.

We may retain the minimum information necessary to maintain a suppression record so that we can respect an unsubscribe request.

10. Cookies and Similar Technologies

The website uses cookies, local storage and similar technologies.

Some technologies are necessary for security, form operation, session management or remembering your privacy choices. Other technologies may be used for analytics or website improvement.

Where consent is required, non-essential technologies will not be activated until you have made an affirmative choice. Rejecting non-essential technologies will not prevent you from making an enquiry.

You can accept, reject or change your choices using the website's Cookie Settings facility.

Our Cookie Policy explains:

• the technologies used;
• their providers;
• their purposes;
• how long they remain active;
• whether information is shared with another organisation; and
• how to change or withdraw your choice.

11. How Long We Retain Information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, regulatory and record-keeping requirements.

Unless a longer period is required because of a complaint, legal claim, fraud investigation or regulatory requirement, our intended retention periods are:

• Initial enquiries that do not proceed: normally up to 24 months after the last meaningful contact.
• Enquiries that result in an Anderson Reed client relationship or application: retained under the Anderson Reed Financial Services retention schedule and relevant regulatory requirements, which may require records to be kept for six years or longer depending on the service and circumstances.
• Contact-form correspondence: normally up to 24 months after the matter is closed, unless it forms part of another retained record.
• Marketing-consent records: while consent remains active and for a reasonable period afterwards to demonstrate how the preference was obtained.
• Marketing suppression records: the minimum information necessary may be retained for as long as needed to respect an unsubscribe or objection.
• Complaints and associated compliance records: normally six years after the complaint is resolved, unless a different period is required.
• Website security and operational logs: for the period reasonably required for security, diagnostics and incident investigation.
• Analytics information: as described in the Cookie Policy and the relevant provider settings.

When information is no longer required, it will be securely deleted or irreversibly anonymised.

12. Security

We use appropriate technical and organisational measures intended to protect personal information against:

• unauthorised or unlawful access;
• accidental loss;
• misuse;
• alteration;
• disclosure; and
• destruction.

These measures include access restrictions, account security, encrypted connections, secure hosting, backups and controls over the service providers that process information for us.

No internet transmission or storage system can be guaranteed to be completely secure. You should therefore avoid sending unnecessary sensitive information through ordinary email or free-text website fields.

13. Your Data-Protection Rights

Depending on the circumstances and the lawful basis being used, you may have the right to:

• request access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to erase information where there is no lawful reason for us to retain it;
• ask us to restrict how information is used;
• object to processing based on legitimate interests;
• object at any time to the use of your information for direct marketing;
• receive certain information in a structured, commonly used and machine-readable format;
• ask for certain information to be transferred to another controller; and
• withdraw consent where processing is based on consent.

These rights are not absolute and may not apply in every situation. If we cannot fulfil a request, we will explain the applicable reason.

Your right to object

You have the right to object to processing based on our legitimate interests. We will stop that processing unless we have compelling legitimate grounds to continue or the processing is required for legal claims.

You have an absolute right to object to direct marketing. If you object, we will stop using your personal information for that marketing.

We will not normally charge a fee for exercising your rights. We may need to request information to verify your identity before responding.

To exercise your rights, contact us using the details in section 17.

14. Automated Decision-Making

TFS Mortgages does not use solely automated decision-making that produces legal effects or similarly significant effects about you.

The website may use basic form rules — for example, displaying relevant questions or checking whether required information has been entered. These rules do not determine whether you are eligible for a mortgage or other financial product.

Eligibility, advice, underwriting and lending decisions are not made by the TFS Mortgages website.

15. Children

The TFS Mortgages enquiry service is intended for people aged 18 or over.

We do not knowingly seek to collect personal information from children through this website. If you believe a child has submitted information, please contact us so that we can review and, where appropriate, remove it.

16. Changes to This Policy

We may update this policy when our services, suppliers or legal obligations change.

The "Last updated" date at the beginning of the policy will show when it was most recently revised. Where a change materially affects how we use personal information, we will take reasonable steps to bring it to the attention of affected individuals where appropriate.

17. Contacting Us

Questions, requests or concerns about this policy or our use of personal information should be directed to:

Anderson Reed Financial Services Ltd

Trading as TFS Mortgages

Director General's House

15 Rockstone Place

Southampton

SO15 2EP

Email: info@tfs-mortgages.co.uk

Telephone: 02382 127779

ICO registration number: ZA921459

18. Complaining to the Information Commissioner

We would appreciate the opportunity to address your concern first. However, you also have the right to complain to the Information Commissioner's Office.

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113

Website: ico.org.uk/make-a-complaint