Our Policies

Who We Are

Mortgage Light Ltd in the style of Holbrook Capital Finance

1 Whittle Court,Knowlhill,Milton Keynes, MK5 8FT

Our website address is: holbrookcapitalfinance.co.uk

About our Privacy Policy

This is a notice to tell you our policy about all information that we record about you. It covers both information that could identify you and information that could not.

We are committed to protecting your privacy and confidentiality. We understand that all users of our website need to know that their data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party. Our policy is both specific and strict. It complies with UK law, including the Data Protection Act 1998. If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.

We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.

Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected at this site.

Here is a list of the information we collect from you, either through our website or because you give it to us in some other way, and why it is necessary to collect it:

BASIC IDENTIFICATION AND CONTACT INFORMATION

This information is used:

to provide you with the services which you request

for verifying your identity for security purposes

for marketing our services and products

Information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.

MARKETPLACE INFORMATION

When we obtain information from you specifically to enable you to use or buy a service offered on our website by some other person, we assume that in giving us your information, you are also giving us permission to pass it to the relevant person.

YOUR DOMAIN NAME AND E-MAIL ADDRESS

Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded. We shall not under any circumstances divulge your e-mail address to any person who is not an employee or contractor of ours and who does not need to know, either generally or specifically.

This information is used:

to correspond with you or deal with you as you expect

in a collective way not referable to any individual, for the purpose of quality control and improvement of our site

to send you news about the services to which you have signed up

to tell you about other of our services or services of sister websites

WEBSITE USAGE INFORMATION

We may use software embedded in our website (such as JavaScript) to collect information about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page, and how we perform in providing content to you. This data is not personally identifiable. It is collected by us to improve the service we provide. We do not pass this data to any third party.

BUSINESS AND PERSONAL INFORMATION

This includes all information given to us in the course of your business and ours, such as information you give us in your capacity as our client. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect you to reciprocate this policy.

We keep information which forms part of our business record for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it.

THIRD PARTY ADVERTISING

We may use Third parties to advertise. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on other sites to your browser. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

COOKIES

We use cookies on our website. Please see our Cookies Policy for more information on how cookies work and how we use them.

CALLING OUR OFFICE

When you call our office, we may collect Calling Line Identification (CLI) information and record calls for Training Purposes. We never pass this information to third parties.

EMAILING US

Email is not always a secure mode of communication and we provide no guarantee that confidentiality of the information provided in an email will be maintained during transmission.

We will never send you an email asking you to transfer deposit funds. If you ever receive an email from us which provides bank account details for you to transfer money, please speak to us on our main line number to confirm it is genuine.

COMPLAINING

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

JOB APPLICATION AND EMPLOYMENT

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

MARKETING INFORMATION

With your permission we pass your email address and name to selected associates whom we consider may provide services or products you would find useful. You may opt out of this service at any time by instructing us at enquiries@holbrookcapitalfinance.co.uk

INFORMATION WE OBTAIN FROM THIRD PARTIES

Although we do not disclose your personal information to any third party (except as set out in this notice), we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you, it is anonymous.

DISCLOSURE TO GOVERNMENT AND THEIR AGENCIES

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

REVIEW OR UPDATE PERSONALLY IDENTIFIABLE INFORMATION

At any time, you may review or update the personally identifiable information that we hold about you by contacting us at the address below. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your info

Mortgagelight Ltd, 1 Whittle Court,

Knowhill, Milton Keynes, MK5 8FT

SALE OF YOUR PERSONAL INFORMATION

Except as specified above, we do not rent, sell or otherwise disclose any of your information to any person outside our business.

DATA MAY BE “PROCESSED” OUTSIDE THE UK

Our websites are hosted in the EU. We also use outsourced services in countries outside the EU from time to time in other aspects of our business. Accordingly, data obtained within the UK may be “processed” outside the UK and data obtained in any other country may be processed within or outside that country.

COMPLIANCE WITH THE LAW

This privacy policy has been compiled so as to comply with the law of every jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your country, we should like to hear from you, but ultimately it is your choice as to whether you wish to use our website.

REMOVAL OF YOUR INFORMATION

If you wish us to remove personally identifiable information from our website, you may contact us at enquiries@holbrookcapitalfinance.co.uk. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

JURISDICTION

Disputes relating to the use of our website will be subject to the jurisdiction of the English courts.

COPYRIGHT

All material on our website which has been created by us is subject to copyright under UK law and we reserve all rights associated with that content. Parts of the website may be downloaded for personal use only. You are not entitled to reproduce or modify content subject to copyright, in whole or in part, for any commercial use whatsoever, without our prior written permission.

ACCURACY OF WEBSITE CONTENT

Although we endeavour to ensure that all of the information on our website is accurate and up to date, we do not guarantee that that is the case.

FINANCIAL ADVICE

No information on our website constitutes financial advice. If you require financial advice, please contact us.

Use of I.P. Addresses

An Internet protocol (I.P.) address is a set of numbers that is automatically assigned to your computer whenever you log on to your internet service provider or through your company’s local area network (LAN) or wide area network (WAN). Web servers, the powerful computers that provide web pages for viewing, automatically identify your computer by the IP address assigned to it during your session online.

We may collect I.P. addresses for some purposes. We do not link a users I.P. address to a person’s personal information, which means we will have a record of each users session but the user remains anonymous to us.

Third Party Cookies

Users of the site who wish to share the content socially using Facebook, Twitter, or Google+ (the platforms which are currently enabled on the website to allow this function) may have cookies stored on their computers from these third-party websites.

More cookie Information

HOW GOOGLE USES INFORMATION FROM SITES OR APPS THAT USE OUR SERVICES

Many websites and apps use Google services to improve their content and keep it free. When they integrate our services, these sites and apps share information with Google.

For example, when you visit a website that uses advertising services such as AdSense, including analytics tools such as Google Analytics, or embeds video content from YouTube, your web browser automatically sends certain information to Google. This includes the URL of the page that you’re visiting and your IP address.

We may also set cookies on your browser or read cookies that are already there. Apps that use Google advertising services also share information with Google, such as the name of the app and a unique identifier for advertising.Google uses the information shared by sites and apps to deliver our services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse and personalise content and ads that you see on Google and on our partners’ sites and apps. See our Privacy Policy to learn more about how we process data for each of these purposes, and our Advertising page for more about Google ads, how your information is used in the context of advertising and how long Google stores this information.

Our Privacy Policy explains the legal grounds that Google relies upon to process your information – for example, we may process your information with your consent or to pursue legitimate interests such as providing, maintaining and improving our services to meet the needs of our users.Sometimes, when processing information shared with us by sites and apps, those sites and apps will ask for your consent before allowing Google to process your information. For example, a banner may appear on a site asking for consent for Google to process the information that site collects. When that happens, we will respect the purposes described in the consent that you give to the site or app, rather than the legal grounds described in the Google Privacy Policy. If you want to change or withdraw your consent, you should visit the site or app in question to do so.

About our Services and Costs ‍

1.The Financial Conduct Authority (FCA) ‍ ‍

‍The FCA is the independent watchdog that regulates financial services. This document has been designed by the FCA to be given to consumers considering buying certain financial products. You need to read this important document. It explains the service you are being offered and how you will pay for it.

2.Whose products do we offer?

Mortgages

We offer an unrestricted range of first charge and second charge mortgages. We do not offer bridging finance or mortgage deals which are only available directly from the lender.

Insurance

We offer products from a carefully selected number of insurers to provide a fair analysis of the marker for income protection, Critical illness Insurance and Life Assurance. Please ask if you wish to be given a list of those insurers.

Home

We offer products from a range of insurers for Buildings and Contents Insurance.

3.What will you have to pay us for our services?

There may be a broker fee for mortgage advice. The amount you pay will depend on your individual circumstances and the nature of the loan required. For residential lending, our typical fee is £495. For more complex or commercial lending, the fee may be higher, up to a maximum of £1,999.

In exceptional cases, we may calculate the fee as a percentage of the loan amount, up to a maximum of 1.5%. This approach would only apply if agreed in advance.

We will receive commission from the lender in addition to the fees you pay.

Any fee payable is non-refundable, and the full terms are explained in our fee agreement. The amount of any commission we receive will be disclosed to you before you agree to proceed with an application.

We arrange any protection policy with the insurer on your behalf. You do not pay us a fee for this service. Instead, we receive commission from the insurer, which is a percentage of the premium you pay to them.

4.Which service will we provide you with?

Mortgages

We will advise and make a recommendation for you on first charge mortgages after we have assessed your needs and circumstances.

We will refer you to a master broker (packager) for second charge mortgages. The master broker will be responsible for any advice or arranging given.

Insurance

We will act for you and advise and make a recommendation for you based on a fair analysis of the market after we have assessed your needs for non-investment insurance contracts or general insurance contracts

5.Who regulates us?

Holbrook Capital Finance is a trading style of Mortgage Light Limited, 1 Whittle Court, Knowlhill, Milton Keynes, MK5 8FT which is authorised and regulated by the Financial Conduct Authority. Mortgage Light Limited FCA registration number is 832755

Mortgage Light Limited permitted business is advising on and/or arranging non-investment insurance contracts and regulated mortgage contracts.

Mortgage Light Limited is responsible for your Advisers activities in advising on and/or arranging non-investment insurance contracts and regulated mortgage contracts.

You can check this is on the Financial Services Register by visiting the FCA’s website https://www.fca.org.uk/register or by contacting the FCA on 0800 111 6768 (Freephone) from 8am and 6pm, Monday to Friday (except public holidays) and 9am to 1pm , Saturdays

6.What to do if you have a complaint

If you wish to register a complaint, please contact us…

In Writing

Siobhan Holbrook Mortgage Light Limited,

1 Whittle Court, Knowlhill,

Milton Keynes, MK5 8FT.

Email: siobhan@holbrookcapitalfinance.co.uk

By Telephone

01908 767456

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

7. Are we covered by the Financial Services Compensation Scheme (FSCS)?

We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.

Home Insurance – Insurance advising and arranging is covered for 90% of the claim, with no upper limit.

Mortgages – Mortgage advising and arranging is covered up to a maximum limit of £85,000.

Insurance- Protection is at 100% where claims arise in respect of compulsory insurance (e.g. employer’s liability insurance), professional indemnity insurance and certain claims for injury, sickness or infirmity of the policyholder. Protection is 90% where claims arise under other types of policy with no upper limit.

Further information about compensation scheme arrangements is available from the FSCS.

COMPLAINTS PROCEDURES FOR

Mortgage Light Limited in the style of Holbrook Capital Finance

Complaint

The definition of a ‘Complaint’ is:

‘Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination, which:

• Alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and

• Relates to an activity of our firm, or of any other firm with whom we have some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service’.

A complaint can be made via any reasonable means, including letter, telephone, email, and in person.

01908 767456

Any cost to the complainant will be the simple cost of connection and will not provide our firm with a contribution to our costs or revenues.

No charge will be made for handling a complaint from an eligible complainant.

Procedures

Receiving a complaint

We do not make a charge for filing a complaint.

All complaints, whether oral or written and made by or on behalf of a customer, must be referred immediately to the person responsible for handling complaints, even if the complaint has already been resolved by an apology.

Any oral or written statement made by a client, which might be considered as a complaint, must be referred to Siobhan Holbrook so that it can be determined as to whether is a complaint or not.

Once it has been established if the matter is a complaint, Siobhan Holbrook will notify the Professional Indemnity Insurers in accordance with the terms and conditions of our PII policy.

• The remaining sections apply only to complaints, which meet the following definition:

• The complaint is made by or on behalf of an eligible complainant;

• The complaint relates to a regulated activity of the firm; and

• The complaint involves an allegation that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience;

Any complaint resolved by the firm by the close of the fifth business day following the day it is received must be investigated competently, diligently and impartially; be assessed fairly, consistently and promptly; taking all relevant factors into account.

Where we consider a complaint to be resolved by the close of the fifth business day following the day it is received, the complainant must promptly be issued our ‘Summary Resolution Communication’ in writing.

Our Summary Resolution Communication must:

• Be fair, clear and not misleading;

• Refer to the fact that the complainant has made a complaint and that we consider the complaint to have been resolved;

• If relevant, include any offer of remedial action or the appropriate level of redress (or both);

• Make the complainant aware that if they are dissatisfied with the resolution of the complaint, they may be able to refer it to the Financial Ombudsman Service (FOS);

• Include the contact details of the Financial Ombudsman Service (FOS), their website address and refer them to the availability of further information on the FOS website. Further information can be found in the Financial Ombudsman Service section of this document;

Acknowledging a complaint

If the complaint cannot be resolved by the close of the fifth business day following the day it is received by Siobhan Holbrook will acknowledge the complaint in writing. The written acknowledgement will be issued promptly.

The acknowledgment letter will provide the complainant early reassurances that the complaint has been received and that we are dealing with it. It will also advise the complainant that:

they will be provided with regular progress updates;

if our review has not been completed by the end of eight weeks after its receipt we will send them with a ‘written response’ explaining why we are not in a position to make a ‘final response’ and provide details of their rights to refer the matter to the Financial Ombudsman Service;

On completion of our review that we will provide them with a ‘final response’ in writing.

Investigating a complaint

Any complaint will be investigated competently, diligently and impartially, obtaining additional information as necessary.

Siobhan Holbrook will investigate all complaints and may, where appropriate, consult the adviser / member of staff whose actions or omissions gave rise to the complaint issue(s) raised.

The investigation will include, as a minimum:

• a review of the relevant client file;

• take into account any information and / or documents submitted by the complainant (including any standard questionnaires i.e. the mortgage endowment questionnaire);

• if necessary, a request for any additional information;

• contact with the relevant provider(s), if relevant

FCA / Other Relevant Regulators

When assessing a complaint, Siobhan Holbrook must also analyse and take into account prior to making a decision relevant guidance produced by the FCA / other relevant regulators and former schemes (e.g. the FSA scheme).

When assessing a complaint other factors that may be relevant in the assessment of the complaint must be taken into account. Siobhan Holbrook must analyse and take into account prior to making a decision:

• similarities with other complaints received by the firm

• any issues identified as a result of the firms Root Cause Analysis carried out.

Resolving a complaint

All complaints require resolution.

Following the completion of the investigation, Siobhan Holbrook will issue a written Final Response letter to the complainant.

The Final Response letter will be fair, clear and not misleading and will provide the complainant with:

• details of complaint;

• details of the investigation;

• the outcome of the investigation;

• if relevant, include any offer of remedial action(s) or the appropriate level of redress (or both), and the basis of calculation;

• details of their right to refer the complaint to the Financial Ombudsman Service if they are dissatisfied with the resolution of the complaint;

• the contact details of the Financial Ombudsman Service (FOS), their website address and refer them to the availability of further information on the FOS website. Further information can be found in the Financial Ombudsman Service section of this document;

• confirmation of whether or not we will consent to the ombudsman service considering a complaint if it becomes apparent that the complaint has been made or referred outside the time limits specified under FCA rules by including the appropriate wording set out in DISP 1 Annex 3R

If we believe that their complaint was made outside of these time limits we will notify them of this in the ‘final response’ and notify them that this is a matter for the Ombudsman to decide.

A copy of the Financial Ombudsman Service’s standard explanatory leaflet will be forwarded with the ‘final response’ letter.

Unless specifically agreed with Siobhan Holbrook if it becomes apparent that the complaint has been made or referred outside the relevant time limits specified under FCA rules we will not consent to the Ombudsman to consider the complaint so will only be able to do so in limited circumstances

If the firm receives confirmation from the complainant that they are satisfied with the findings and outcome of the investigation and/or remedial action or redress (or both) being offered, the complaint will be considered to be closed by Siobhan Holbrook.

The firm will comply promptly with any offer of remedial action or redress accepted by the complainant.

Where no confirmation has been received from the complainant within 8 weeks of the firm’s Final Response, the complaint will also be considered closed. However under the concept of ‘TCF’, should the complainant contact the firm after 8 weeks, we will review any further correspondence accordingly.

Financial Ombudsman Service (FOS)

The FOS contact details are as follows:

The Financial Ombudsman Service

Exchange Tower

London E14 9SR

Telephone number: 0800 023 4 567.

Website address of the Ombudsman - http://www.financial-ombudsman.org.uk/

When providing the website address of the Ombudsman to complainants we will also refer them to the availability of further information on the FOS website.

If a complaint is referred to the FOS, the firm will fully co-operate with them and comply promptly with any settlement and awards made by it.

On receipt of a notification from FOS, we will respond promptly to any document / information request, quoting the allocated reference number.

The firm agrees to be bound by any awards made by the Ombudsman. Consideration will be given to any awards made which are above the Ombudsman’s limit at that time.

Any cases where the FOS’s decision disagrees with the firm’s final decision will be summarised and analysed by Siobhan Holbrook

The firm undertakes to pay promptly the fees levied by the FOS.

Referring a complaint to another firm

If a complaint is received whereby we have reasonable grounds to be satisfied that another firm is solely or jointly responsible for the subject matter of a complaint, we will forward the entire complaint / relevant part of the complaint promptly, in writing, to that firm.

The firm will also inform the complainant promptly in a final response of the referral, explain why the complaint has been forwarded to the other firm and provide them with the other firms contact details.

If we are responsible on a joint basis, we will investigate those issue(s) we have not forwarded in line with our normal procedures.

Record Keeping

An entry of each complaint received will be made within the firms Complaints Register, which will be maintained at all times.

The firm will retain a record of each complaint received for at least 3 years from the date the complaint is received, including those resolved by close of the third business day following the day it is received. This will be held in the form of an individual file and will include as a minimum:

• the name of the complainant;

• the substance of the complaint;

• all correspondence between the firm and complainant, including details of any remedial action and/or redress offered by the firm; and

• documentation relating to any cases referred to another firm/provider.

In the event of Siobhan Holbrook being unable to carry out their normal responsibilities for the oversight of the compliance with DISP 1 (Treating complainants fairly) Michelle Simpson will send a holding email until Siobhan returns to business.