JSFCS Limited is responsible for the personal information it collects and uses as part of operating the Jayhawk Capital website and providing its services.

JSFCS Limited is an appointed representative of Altura Mortgage Finance Limited, which is authorised and regulated by the Financial Conduct Authority under firm reference number 827849. To provide regulated services and meet our regulatory responsibilities, personal information may be shared with Altura Mortgage Finance Limited. Altura may process that information in accordance with its own legal and regulatory responsibilities and its privacy policy.

Jayhawk Capital, a trading style of JSFCS Limited

• Company number: 12117837
• FCA reference number: 1057293
• Contact address: Broxhead House, 60 Barbados Road, Bordon, GU35 0FX
• Telephone: 020 4604 8220
• Email: john@jayhawkcapital.co.uk

If you have a question about this policy, wish to exercise a data protection right or want to make a data protection complaint, please contact us using the email address above.

The information we collect depends on how you interact with us and the services you ask us to provide. It may include:

• Identity information, such as your name, date of birth, marital status and identification documents.
• Contact information, such as your home address, email address and telephone number.
• Enquiry information, including the details you submit through our website, such as the amount you wish to borrow, property value and an overview of your circumstances.
• Financial information, such as income, expenditure, assets, liabilities, bank information, credit commitments and the source of funds or wealth.
• Employment and business information, including your employment status, occupation, income history, company information and accounts.
• Property and transaction information, including property details, ownership, valuation, proposed works, development costs, intended use, timescales and funding requirements.
• Mortgage, lending and insurance information, including existing arrangements, product requirements, applications, offers and correspondence with lenders or providers.
• Identification, verification and financial-crime information, including information required to verify your identity, establish the source of funds and meet anti-money-laundering, fraud-prevention and other legal obligations.
• Special-category information, where relevant to the service, such as information about health or circumstances that may indicate vulnerability or a need for additional support.
• Information about connected people, such as a joint applicant, dependant, family member, director, shareholder, beneficial owner, guarantor, trustee or other person connected with a transaction.
• Communication records, including emails, letters, call notes, meeting notes, preferences, complaints and feedback.
• Technical and usage information, such as IP address, browser and device information, pages viewed, referring website and interaction with the website.
• Marketing preferences, including whether you have asked to receive or stop receiving particular communications.

We do not normally make decisions about lending. Decisions on whether to offer finance, and on what terms, are made by lenders or providers using their own criteria and privacy practices.

If you provide personal information about another person, you should ensure that you are entitled to do so and that they understand how their information will be used. Where appropriate, please give them a copy of this privacy policy. We may also provide privacy information to them directly.

We may collect information:

• directly from you when you use a website form, email, telephone us, meet with us or provide documents;
• from a joint applicant, representative, introducer or another person involved in your transaction;
• from Altura Mortgage Finance Limited;
• from lenders, finance providers, insurers, valuers, solicitors and other professional advisers;
• from credit-reference, identity-verification, fraud-prevention and anti-money-laundering services;
• from public sources, including Companies House, HM Land Registry, the electoral register and other public records;
• through cookies and similar technologies used on our website; and
• from third-party systems used to manage enquiries, client records or applications.

We will only use personal information where data protection law allows us to do so.

To Respond to Enquiries and Take Steps at Your Request

We use identity, contact, enquiry and transaction information to respond to you, understand what you are trying to achieve and discuss whether we may be able to assist.

Our lawful bases are taking steps at your request before entering into a contract and our legitimate interests in responding to enquiries and operating our business.

To Provide Advice and Arrange Finance

We use the information needed to assess your circumstances, research suitable options, provide advice, prepare and submit applications, communicate with lenders or providers and support a transaction through to completion.

Our lawful bases are taking steps before entering into a contract, performing our contract with you, complying with legal and regulatory obligations, and our legitimate interests in providing and administering our services.

To Verify Identity and Prevent Financial Crime

We use identity, financial and verification information to meet anti-money-laundering and other legal or regulatory requirements, verify information, prevent fraud and protect clients, lenders and our business.

Our lawful bases are compliance with legal obligations and our legitimate interests in preventing fraud and financial crime.

To Meet Regulatory, Legal and Record-Keeping Duties

We may use and retain information to maintain suitable records, demonstrate compliance, respond to regulators, handle complaints, establish or defend legal claims and cooperate with lawful requests.

Our lawful bases are compliance with legal obligations and our legitimate interests in protecting our legal position and maintaining appropriate business records.

To Support Clients Who Need Additional Help

If you tell us about a health condition or another circumstance that affects how you would like us to communicate with or support you, we may use that information to make reasonable adjustments and provide an appropriate service.

Where this involves special-category information, we will identify an additional lawful condition, such as your explicit consent or another condition permitted by law. We will only use this information where it is relevant and necessary.

To Operate, Secure and Improve Our Website and Services

We may use technical, usage, enquiry and communication information to maintain security, diagnose faults, understand how the website and services are used, improve them and protect against misuse.

Our lawful bases are our legitimate interests in running a secure, effective and relevant website and complying with legal obligations where applicable. Non-essential cookies and similar technologies will only be used in accordance with the choices available through our cookie controls.

To Communicate About Relevant Services

Where permitted, we may contact you about services or information that may be relevant to your relationship with us. We may rely on consent where required or on our legitimate interests where the law permits. You can ask us to stop direct marketing at any time by contacting us or using the unsubscribe option in a marketing email.

We will not sell your personal information.

Where necessary and lawful, we may share information with:

• Altura Mortgage Finance Limited, as our principal firm;
• mortgage lenders, banks, specialist lenders, finance providers and insurers;
• credit-reference agencies, identity-verification services, fraud-prevention agencies and anti-money-laundering service providers;
• valuers, surveyors, solicitors, conveyancers, accountants, tax advisers and other professionals involved in a transaction;
• product sourcing, client-management, application, communication, document-storage, hosting, security and other technology providers;
• service providers that support our business, acting under appropriate contractual and confidentiality obligations;
• introducers or other parties involved in your case, where appropriate and lawful;
• regulators, ombudsman services, law-enforcement bodies, courts, government bodies and other authorities where required or permitted by law; and
• a buyer, investor, adviser or successor if our business or assets are reorganised, sold or transferred, subject to appropriate safeguards.

Some lenders, providers and professional firms will act as independent data controllers and will provide their own privacy information.

Where relevant to your enquiry or application, a lender, provider or authorised service may search your records with credit-reference or fraud-prevention agencies. Searches may leave a record on your credit file and information may be shared with other organisations for identity verification, credit assessment and fraud prevention. We will explain the relevant checks during the application process, and the organisation carrying out the check should provide its own privacy information.

Some organisations that process information for us, or for a lender or provider involved in your case, may store or access information outside the United Kingdom.

Where we are responsible for an international transfer, we will ensure that an appropriate legal safeguard is used. This may include transfer to a country covered by UK adequacy regulations, use of approved contractual safeguards such as the UK International Data Transfer Agreement or UK Addendum, or another lawful mechanism. You may contact us for more information about the safeguards relevant to your information.

We use appropriate organisational and technical measures designed to protect personal information against accidental or unlawful loss, misuse, alteration, access or disclosure. Access is limited to people and service providers who need the information for a legitimate purpose and who are subject to suitable duties of confidentiality and security.

No internet transmission or storage system can be guaranteed to be completely secure. If a personal data breach occurs, we will assess it and notify affected individuals and the Information Commissioner’s Office where the law requires us to do so.

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet legal, regulatory, accounting, reporting and complaints-handling requirements.

The period will depend on the type of service, whether a transaction proceeds, the nature of the information and any applicable limitation or regulatory period. Mortgage and financial-services records may need to be retained for specified minimum periods after our work or relationship ends. We may retain information for longer where necessary to respond to a complaint, establish or defend a legal claim, comply with a legal hold or meet another lawful requirement.

When information is no longer required, we will delete it securely or anonymise it so it can no longer be linked to you.

Depending on the circumstances, you may have the right to:

• ask for access to the 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 to keep 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 you provided in a structured, commonly used and machine-readable format, or ask for it to be sent to another organisation;
• withdraw consent where processing relies on consent, without affecting earlier lawful processing; and
• complain about how your information has been handled.

These rights are not absolute and may be limited by legal or regulatory requirements. We may ask for information to confirm your identity before dealing with a request. There is normally no fee, although the law permits a reasonable fee or refusal in limited circumstances involving requests that are manifestly unfounded or excessive.

We will respond within the period required by data protection law and will let you know if we need more time in a permitted case.

Please contact us first if you have concerns about how we use your personal information. Email john@jayhawkcapital.co.uk and make clear that your message is a data protection complaint. We will acknowledge a data protection complaint within 30 days, investigate it appropriately, keep you informed and tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office:

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113

Our website uses cookies and similar technologies. Please read our Cookie Policy for details and to learn how to manage your choices.

Our website may link to websites operated by lenders, providers, a client-portal provider or other third parties. Those organisations control their own websites and privacy practices. We encourage you to read their privacy information before providing personal information.

We may update this policy when our services, systems, legal obligations or use of personal information change. The date at the top of the page shows when it was last updated. Where a change materially affects how we use information already collected, we will take reasonable steps to bring it to the attention of affected individuals before the new use begins.