This privacy policy outlines how Black Swan Financial Services Ltd uses and protects any information that
you provide when you use this website. Black Swan Financial Services Ltd is a controller of your personal
data under the Data Protection Act 2018 and the General Data Protection Regulation. We are
committed to ensuring that your privacy is protected. Should we ask you to provide certain
information by which you can be identified when using this website, this information will only be
used in accordance with this privacy statement.
Who We Are
Name: Black Swan Financial Services Ltd
Address: Bramble Lodge, The Green, Horns Drove, Rownhams, Southampton SO16 8AJ
Contact Email Address: hello@blackswan.uk.com
What information is being collected?
We are collecting information that is provided through the contact form on this website, as well as
data collected from cookies on our website.
This data comprises of your name, email address, phone number and product interests. It could also
comprise of your financial and medical history.
How will we use the information about you?
We process personal information for certain legitimate business purposes, which include some or all
of the following:
• By providing this data, you have registered interest in us contacting you using the contact details
provided to discuss the products and services listed on our website
• To update and maintain our internal records.
• To track website usage in order to make improvements to the website.
• We may periodically send promotional emails containing information which we feel may be of
interest to you using the email address which you have provided. All promotional emails will include
an unsubscribe link should you wish to opt out of receiving email marketing. If you have any
concerns regarding the opt out process, please contact the data controller using the contact details
available at the bottom of this privacy policy.
It should be noted that you have no legal or contractual obligation to provide your personal data for
the purposes listed above, and there are no consequences to you for this data not being provided
outside of the purposes of the processing listed above not being fulfilled.
This data will not be used for any automated decision making or profiling purposes.
Data Retention
We will retain this data for an indefinite period for use in the legitimate business purposes listed
above.
You may choose to opt out of the processing of your data at any time by contacting us on the details
listed in the ‘Who We Are’ section of this policy. We may retain some of your information to ensure
that we can keep a record to identify that you wish no further processing of your data to take place,
and to comply with any legal and/or regulatory responsibilities we hold.If any business is transacted with the company, the new data retention period that supersedes any
previously agreed retention period will be outlined to you as part of this process, and we will also
supply you with the reasoning for this new retention period.
Who will have access to this data
This data can be accessed by members of Black Swan Financial Services Ltd, our lender and
provider partners and also by staff members at our Principal Firm The Right Mortgage Ltd, as we
may store customer records on our shared back office system.
Your rights to our processing of your data
Under the General Data Protection Regulation, you have the following rights:
The right to know if we are processing your personal data, what data we are processing and why we
are processing it- which we have detailed above.
The right to access confirmation that we are processing your data and access the personal data we
hold for you. The way to request this information is detailed in the ‘Subject Access Requests’ section
of this policy.
The right to request correction of any inaccurate personal data that we process relating to yourself.
This can be requested in writing using the contact details listed in the ‘Who We Are’ section of this
policy.
The right to obtain and reuse your personal data for your own purposes across different services.
The right to object to:
• processing based on legitimate interests or the performance of a task in the public
interest/exercise of official authority (including profiling);
• direct marketing (including profiling)
The right to request that we delete personal data that we process relating to you if:
• We no longer need the data
• If you withdraw your consent for us to process your personal data and we don’t have
another legal basis to hold this data
• If you object to our processing and we don’t have a legitimate ground to process it
• If we are processing your personal data unlawfully
• If we must delete the data due to a legal obligation
The right to request that we restrict our processing of your personal data if:
• You contest the accuracy of the data
• Our processing is unlawful but you don’t want us to delete the data
• We don’t need to process your personal data anymore but you need it for a legal claim
• You object to our processing of your personal data on the basis of our legitimate interestIf you wish to enact any of these rights, please contact us using the details in the ‘who we are’
section. For further information on these rights, please visit the ICO website.
Subject Access Requests
You may request a copy of the information we hold for you through a subject access request. This
can be done by contacting us using the details listed in the ‘who we are’ section, detailing which
information you would like access to. There is usually no cost, and which will be complied with
within 1 month. Where the request is considered to be manifestly unfounded or excessive, we may
charge administrative costs or refuse the request. If you are unhappy with the response from FIRM
NAME, and this cannot be resolved directly by contacting us, please contact the Information
Commissioners Office.
Complaints related to data processing
If you are unhappy with the way in which we are processing your data, please contact us directly in
the first instance to resolve this issue. If this issue cannot be resolved directly by contacting us,
please contact the Information Commissioners Office.
Our Use of Cookies
Our Site may place and access certain first party Cookies on your computer or device. First party
Cookies are those placed directly by us for our use only. We use Cookies to facilitate and improve
your experience of our Site and to provide and improve our products AND services. We have
carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is
protected and respected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt e.g. cookie pop
up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies
you are enabling us to provide the best possible experience and service to you. You may, if you wish,
deny consent to the placing of Cookies; however certain features of Our Site may not function fully
as a result.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be
“strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought
to place these Cookies, but it is still important that you are aware of them. You may still block these
Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be
aware that Our Site may not work properly if you do so. We have taken great care to ensure that
your privacy is not at risk by allowing them.
The following first party Cookies may be placed on your computer or device:
Name of Cookie Purpose Strictly Necessary
<<insert file name>> <<insert description>> <<yes / no>>
<<insert file name>> <<insert description>> <<yes / no>>
<<insert file name>> <<insert description>> <<yes / no>><<insert file name>> <<insert description>> <<yes / no>>
<<insert file name>> <<insert description>> <<yes / no>>
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of
tools used to collect and analyse anonymous usage information, enabling us to better understand
how Our Site is used. This, in turn, enables us to improve Our Site and the products AND/OR services
offered through it. You do not have to allow us to use these Cookies, however whilst our use of them
does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually
improve Our Site, enhancing your user experience.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie First / Third
Party
Provider Purpose
<<insert file name>> <<first /
third>>
<<insert name>> <<insert description>>
<<insert file name>> <<first /
third>>
<<insert name>> <<insert description>>
<<insert file name>> <<first /
third>>
<<insert name>> <<insert description>>
<<insert file name>> <<first /
third>>
<<insert name>> <<insert description>>
<<insert file name>> <<first /
third>>
<<insert name>> <<insert description>>
In addition to the controls that we provide, you can choose to enable or disable Cookies in your
internet browser. Most internet browsers also enable you to choose whether you wish to disable all
cookies or only third-party cookies. By default, most internet browsers accept cookies but this can
be changed. For further details, please consult the help menu in your internet browser or the
documentation that came with your device.
You can choose to delete cookies on your computer or device at any time, however you may lose
any information that enables you to access our site more quickly and efficiently including, but not
limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that
you consult the help and guidance provided by the developer of your internet browser and
manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Know Your CookiesAll Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use
some or all of the following types of Cookie:
Strictly Necessary Cookies
A cookie falls into this category if it is essential to the operation of our website. Strictly necessary
cookies may, for example, be required for functions such as logging in, storing items in a shopping
basket, or enabling payment transactions.
Analytics Cookies
Understanding how users use our website can be extremely valuable. Analytics cookies provide
insights into many factors such as how users are navigating around the site and what features they
are using. Analytics cookies may often be set by third parties, but not always.
Functionality Cookies
Many websites offer some level of personalisation and functionality cookies play a key role here. For
auditing purposes, however, it is important not to confuse these with the strictly necessary variety. If
the site can be used properly without the cookie, it isn’t strictly necessary.
Targeting Cookies
It is important to know when and how often someone visits our website, and which parts of it they
have used (including which pages they have visited and which links they have followed). As with
analytics cookies, targeting cookies allow us to better understand our users, enabling us to make our
site and, more importantly, the advertising on it more relevant to those users’ interests. Targeting
cookies may often be set by third parties.
First-Party Cookies
As the name suggests, these cookies are placed directly by our website (as opposed to those placed
by third-party services, for which see below). Most, if not all, of your strictly necessary and
functionality cookies will likely be first-party cookies.
Third-Party Cookies
These cookies are placed by third parties providing services such as advertising and analytics.
Analytics and targeting cookies are common types of third-party cookie as such work is often not
undertaken in-house.
Persistent Cookies
Any of the cookies listed above may be a persistent cookie. Persistent cookies are those which
remain active on a user’s computer or device for a predetermined period of time and are activated
when that user visits your website.
Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only
remain on your computer or device from the point at which you visit Our Site until you close your
browser. Session Cookies are deleted when you close your browser.
Cookies on Our Site are not permanent and will expire [after <<insert period>>] OR [as indicated in
the table above].For more details of the personal data that We collect and use, the measures we have in place to
protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy.
For more specific details of the Cookies that We use, please refer to the table provided above.
Links to other websites
Our website may contain links to third party websites. It should be noted that we do not have any
control over these websites and so we are not responsible for the protection and privacy of any
information which you provide whilst visiting such sites, which are not governed by this privacy
statement. For this information, please consult the privacy statement applicable to the website in
question.
What to do if you have a complaint about our service:
If you wish to register a complaint, please contact:
…in writing The Right Mortgage, St Johns Court, 70 St Johns Close, Knowle, B93 0NH
…by phone 01564 732744
A summary of our internal complaints handling procedure is available on request. If we cannot settle
your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.