Take Time to Read Our Privacy Notice

Beneco Finance Ltd (our Firm, we, our, us) is authorised and regulated by the Financial Conduct Authority
(FCA No. 987938)

You are reading this document because you are a prospective appointed representative or existing appointed representative of Beneco Finance Ltd. We would like to explain to you what we will need to do with Your Information, and the various rights you have in relation to Your Information.
What do we mean by “Your Information”?

Your Information means any information describing or relating to you and your business. This information will generally be collected through our recruitment forms, face to face, over the internet, email or telephone conversation with you.
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Beneco Finance will process your information:
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1. When enquiring to join Beneco Finance
2. Your application to join Beneco Finance
3. The period with which you may be associated with us by any contract we have and after any such contract has terminated.
   The types of information we may collect, this list is a typical representation and not limited to:
   • Personal details such as (Name(/s), date of birth, address, residential status, nationality, NI Number
   • Employment details including previous employment
   • Credit commitments, such as personal and business debt details, personal expenditure and household income
   • Solicitor and Accountant details
   • Criminal offences/convictions
   • qualifications
   • assets/liabilities
   • Data protection license details
   • personal business conduct
   • Partner/spouse details
   • Visa details
   • Business and certificates of incorporation/ structure details.
   • Details of your business/sales performance, both actual and projected
   • Details of any gaps in employment

Specifically, Roles with Regulatory Status will require us to process:

• a report detailing your individual credit history; and
• information relevant to enable the Network to appropriately assess your honesty and integrity including information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”) and to enable the Network to undertake all relevant searches in relation to your conduct generally.

Where applicable, we will request documents to support the above list. Beneco Finance will collect information from you to meet our regulatory responsibilities as the principal firm from:

• You
• Business associated
• Social and business networks (such as Facebook and Linked-In)
• On-line engine results (such as Google)
• Employers
• “Trusted Sources” including:
• Government / Land / Police Registers​
• Credit reference agencies
• financial Institutions
• Insurance companies
• Law firms
• Accountants
• Third parties (where consent has been given to collect information)

Our Responsibilities:
Beneco Finance Ltd is authorised and regulated by the Financial Conduct Authority. The network has responsibilities in respect of authorisation and ongoing fitness and propriety along with the quality of advice that its appointed representatives provide to customers. Being regulated by the Financial Conduct Authority means that we are subject to a number of detailed rules and regulations that operate to ensure that we undertake appropriate due diligence measures on any applications we receive to join us and Appointed Representatives, advisers and introducers following appointment by Beneco Finance.
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Beneco Finance Ltd is obliged to assess those applicants to Cityplus Network who will perform regulated activities on our behalf, perform certain roles within an appointed representative or otherwise make introducers or referrals to an appointed representative, persons appointed by the network to carry out any of these roles and to meet the regulatory requirements that apply to each relevant role.
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These checks cover the following three areas of assessment:

• Honesty and integrity
• Competence and capability; and
• Financial soundness

The Financial Conduct Authority rules also require the Network to operate systems and controls to manage general business risks. This means that we may assess business plans, marketing, product and proposition models, methods of customer acquisition, remuneration and incentive arrangements, business structures, data security, introducer and referral arrangements and anything else we consider relevant to be able to discharge our responsibility to effectively and appropriately manage risk in our business. These assessments could be carried out on application or at any point during your association with us.
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Lawful basis of processing and other purposes that we will generally collect and hold your information for:

• Electronic ID&V checks
• Conducting business, developing relationships with business partners
• Providing clients with a product or service via lender and providers
• Processing payments including accounting, auditing, billing, commission reconciliation, collection, complaints, enquiries and dispute resolution.
• Mitigation acts of fraud through money laundering, tax evasion, claims, other liabilities and managing risk exposure and Appointed Representative quality, integrity and compliance.
• Creating log in details for Network systems and tools.
• Complying with Beneco Finance Ltd policies
• Public interest: some information is processed in accordance with public interest
• Consent: where we process information under consent we will seek your clear and unambiguous consent prior to processing your data
• Performance of a contract: where you enter into a contract with us and we need to process your information as part of this contract

When you apply for a Role or carry out a Role, you will establish a contractual relationship with us in the relevant capacity. The Network will process Your Information, Your Special Data and/or Criminal Disclosures in order to give effect to and to carry out its obligations under any such contract that is entered into between us.

We also have the right to use Your Information, Your Special Data and/or Criminal Disclosures at any time provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders and product providers relating to your connection with the Network and the business you may place with them, including the processing of any procuration fees or commission. You will also receive information in relation to product innovation, features and terms and conditions either from the Network or directly from mortgage lenders and/or product providers.

We may at any time, use Your Information, your Special Data and/or Criminal Disclosures to enable us to meet any contractual responsibilities we may owe lenders or providers or for wider compliance with any legal or regulatory obligation to which we might be subject, including any obligations we may have to you. This includes sharing Your Information and Your Special Data and/or Criminal Disclosures with all applicable regulators such as the FCA and the Information Commissioner.

When we process your Special Data and any Criminal Disclosures we do so on the basis you have provided your prior explicit consent, so that we may continue to meet our own obligations as set out generally in this Privacy Notice.

If you visit our websites we may use IP addresses, URLs of requested resources, timestamps and HTTP user agents to analyse trends, administer the system and gather broad demographic information for aggregate use. Details of our cookie policy are available and can be found on our website or by requesting from us.

What happens to your information when it is disclosed to us?

In the course of handling Your Information, Your Special Data and/or Criminal Disclosures we will:
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record and store Your Information, Your Special Data and/or Criminal Disclosures on our systems run on secure servers
provide duly authorised employees and consultants within, or engaged, by us with access to Your Information, Your Special Data and/or Criminal Disclosures as necessary for the purposes of carrying out our Due Diligence either prior to your appointment to a Role and then subsequently to give effect to any contract that has been entered into between you and the Network, including, but not limited to, the carrying out of supervision and monitoring of the service you may provide to customers, the payment of commissions, to provide you with access to systems necessary to perform your Role and to operate any business development or sales support initiatives we may consider to be in our legitimate interests to operate, such as conferences and recognition and reward initiatives
use, and where appropriate transmit, Your Information, Your Special Data and/or Criminal Disclosures to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the Office of the Information Commissioner or any other regulatory, law enforcement or governmental body; and
need to access and process Your Information, Your Special Data and/or Criminal Disclosures to deal with enquiries received from mortgage lenders and product providers that relate to the service that you may provide to customers, including the payment of any commission or fees to us that may be linked to the product you have arranged and that may be due to you.

Security and retention of your information:

Your privacy is important to us and we will keep Your Information, Your Special Data and/or Criminal Disclosures secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.

We will keep information for a reasonable amount of time in order to perform the purposes listed in this privacy statement. We can confirm that we will only keep your information for as long as necessary. Typically, this is for 7 years after the last contact with you, however Beneco Finance reserve the right to keep information for a longer period of time if we feel it is in out legitimate interests.

The Network has responsibility to ensure the suitability of advice or recommendations provided by you to customers, and to respond to and investigate any complaint that may be made against you. The rules and regulations of the FCA do not generally provide for any automatic time bar after which customers would be prevented from making a complaint to us (the exception being payment protection insurance). We will therefore keep a record of products and services that have been provided to customers by you for as long as we consider reasonably necessary to be able to discharge our obligations to customers.

Your Rights:

You can:
request copies of Your Information, Your Special Data and/or Criminal Disclosures that is under our control
ask us to further explain how we use Your Information, Your Special Data and/or Criminal Disclosures
ask us to correct, delete or require us to restrict or stop using Your Information, Your Special Data and/or Criminal Disclosures (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Information, Your Special Data and/or Criminal Disclosures to another organisation should you wish
withdraw any consent you may have provided to us processing Your Special Data and/or Criminal Disclosures (and any implication of you exercising this right will be explained to you at the time of any such request)
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Sharing and Transferring of your information:

Beneco Finance Ltd does not sell or otherwise disclose personal information we collect about you, except what is references in this privacy notice. We share the information with, but not limited to:

Lenders and providers to business facilitation to provide required services
Contracted services providers to perform services on our behalf
Hosting datacentres, Cloud services
Law firms
Auditors
The regulator – The Financial Conduct Authority
Credit agencies
HMRC
Other regulatory bodies
Third party venue, catering and/or event management providers who assist us with the delivery of network events.
our professional indemnity insurers, brokers, claims handlers and legal advisers and another person who may provide professional services in connection with the handling of a complaint, litigation or investigation or in connection with the interpretation or enforcement of the terms of any contract we may have entered into with you
To comply with reference requests from prospective future employers

We may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities

These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.

Request for information to be blocked, objected, anonymised or deleted:

If you would like to object to any processing of your information by Beneco Finance, you can contact us outlining what processing of information you would like to object to.
If you would like Beneco Finance to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised.

To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us.

If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
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How to withdraw consent of your information:

If we obtain your information by consent you have the right to withdraw any consent you previously provided .

If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information. Doing so will mean that you cannot take advantage of certain Beneco Finance and affiliate products, services and promotions from time to time.

The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.
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How to contact us / how to complain:
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If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

Compliance Manager
E-mail: compliance@cityplusnetwork.co.uk

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Information, Your Special Data and/or Criminal Disclosures, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Information, Your Special Data and/or Criminal Disclosures you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

This privacy notice may be updated from time to time and you should review it regularly.

Version: 2.0
Last updated: 25/07/2023