Privacy Policy Notice

Liquid Complete Limited trading as Liquid Expat Mortgages

Last updated: 28/04/2025

1. Introduction

At Liquid Complete Limited (trading as Liquid Expat Mortgages), we are committed to protecting your personal data in compliance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, Privacy and Electronic Communications Regulations (PECR), and Financial Conduct Authority (FCA) requirements. As a data controller, this Privacy Policy explains how we collect, use, store, share, and safeguard your personal data, and your rights in relation to that data.

We are registered with the Information Commissioner’s Office (ICO) under registration number ZA110333. Verify our registration at: https://ico.org.uk/ESDWebPages/Entry/ZA110333.

For questions or to exercise your data protection rights, contact:

Name: Stuart Marshall
Email: info@liquidexpatmortgages.com
Telephone: +44 161 871 1216
Address: Suite 4b, Link 665 Business Centre, Todd Hall Road, Rossendale, BB4 5HU, United Kingdom

2. Personal Data We Collect

We collect the following categories of personal data:

Personal Information: Name, contact details (email, phone, address), date of birth, National Insurance number, employment details, financial information (e.g., income, credit history), and identity documents (e.g., passport details) for mortgage or insurance applications and Anti-Money Laundering (AML) checks.

Special Category Data: In limited cases, health data (e.g., for life insurance products), only with your explicit consent.

Communication Data: Information from interactions, such as emails, phone calls, live chat, or chatbot messages (e.g., via Konig Digital).

Usage Data: Website interaction data, including IP address, browser type, pages visited, timestamps, and cookie data (see Section 8).

We do not knowingly collect data from children under 16, as our services are not directed at children. If such data is collected inadvertently, we will delete it promptly.

How We Collect Data:

  • Directly: Through enquiry forms, applications, document submissions, or communications (e.g., phone, email, chatbot).

  • Automated Technologies: Via cookies and analytics tools on our website (see Section 8).

  • Third Parties: From mortgage lenders, credit reference agencies, or public sources, where necessary for our services or AML checks.

3. Purposes and Legal Bases for Processing

We process your personal data for the purposes below, based on the following UK GDPR legal bases:

Purpose Data Used Legal Basis
Process mortgage/insurance applications and provide services Personal Information, Special Category Data Necessary for contract performance (Article 6(1)(b)); explicit consent for special category data (Article 9(2)(a))
Perform Anti-Money Laundering (AML) checks on client documents Personal Information Necessary for contract performance (Article 6(1)(b)) and legal obligation (Article 6(1)(c)), e.g., Money Laundering Regulations 2017
Communicate about applications, services, or updates Personal Information, Communication Data Necessary for contract performance (Article 6(1)(b)) or legitimate interests (Article 6(1)(f)) to keep clients informed, per Legitimate Interests Assessment
Improve website/services via analytics Usage Data Legitimate interests (Article 6(1)(f)) to enhance user experience, per Legitimate Interests Assessment
Send marketing about relevant products, including remarketing to past enquirers Personal Information Consent (Article 6(1)(a)) or legitimate interests (Article 6(1)(f)) for existing contacts under PECR soft opt-in, per Legitimate Interests Assessment
Comply with legal/regulatory obligations Personal Information Necessary for legal obligation (Article 6(1)(c)), e.g., FCA rules, anti-money laundering laws
Support client interactions using AI/chatbot tools Personal Information, Communication Data Necessary for contract performance (Article 6(1)(b)) or legitimate interests (Article 6(1)(f)) to improve service efficiency

Providing data is voluntary, but if you do not provide data required for services (e.g., financial details, identity documents), we may be unable to assist. Providing data for marketing or non-essential purposes (e.g., analytics, remarketing) is optional and does not affect service delivery. For special category data (e.g., health), we obtain explicit consent via a clear opt-in (e.g., signed form or checkbox), which you may withdraw by contacting us.

4. How We Use Your Data

  • Assess eligibility for and arrange mortgage or insurance products.

  • Perform Anti-Money Laundering (AML) checks on personal documents (e.g., passports, financial records) before lender submission, using AI tools (Grok, Adobe AI Assist).

  • Communicate about your application, provide updates, or respond to enquiries.

  • Enhance our website and services using anonymised analytics (e.g., website usage trends).

  • Comply with legal obligations, including FCA regulations and anti-money laundering requirements.

  • Send marketing communications about relevant products, including remarketing to past enquirers who provided contact details, if you’ve consented or under the PECR soft opt-in for existing contacts.

  • Support client interactions using AI and chatbot tools (e.g., Konig Digital for chatbot enquiries, Grok for AML analysis, Adobe AI Assist for document verification).

We do not use automated decision-making or profiling with legal or significant effects.

5. Sharing Your Data

We may share your personal data with:

  • Third-Party Processors: Service providers processing data on our behalf (see below).

  • Affiliates: Companies within the Liquid Expat Mortgages group to deliver seamless services, acting as processors or joint controllers.

  • Regulators: FCA, Financial Ombudsman Service, ICO, or other authorities when legally required or to protect our rights, property, or safety.

  • Other Parties: Mortgage lenders or insurers to fulfil our contract with you, or with your explicit consent.

We do not share your data for third-party marketing. We minimise data shared and anonymise it where possible (e.g., for analytics).

Key Third-Party Processors:

Processor Type of Processing & Data
WordPress WordPress is a trading style of Automattic Inc. and provides website hosting services and uses cookies to enhance your experience.
Let’s Encrypt Provides a secure socket layer to protect the information you provide in our web forms.
Orca Our answering service may collect data including your phone number and your message to us.
Microsoft Provides our email hosting; personal data is processed for calendar, contact and email synchronization and Office 365 software where we may process your personal data.
Xero We use accounting software to process payroll and staff information.
Mortgage Keeper Software we use to maintain records of your information pertinent to our work with you.
Trigold Mortgage sourcing software that helps us to find the best mortgage deal for you.
Twenty7 Tech Mortgage sourcing software that helps us to find the best mortgage deal for you.
AWS Amazon web servers host our remote backup to ensure data is always available for us to provide service continuity in the event of any local IT failure.
YMLP Communications software enabling us to send you relevant information.
Mailchimp Communications software enabling us to send you relevant information.
Commversion Ltd Our Live-Chat service may collect data which you provide, including name, phone number, email address and your message.
Sendgrid Communications software enabling us to send you relevant information.
MongoDB Used for data storage and retrieval for our fact find service.
Heroku Hosting platform for our fact find service.
AI Assist with Adobe AI used for research and checking bank statements for assistance with AML. Designed to process information securely and in real-time without storing, sharing, or retaining any data.
Grok AI AI used for research and checking bank statements for assistance with AML. Designed to process information securely and in real-time without storing, sharing, or retaining any data.
Konig Digital Chatbot services for website enquiries and customer support.

All processors are bound by UK GDPR-compliant data processing agreements.

6. International Data Transfers

Your data is primarily stored on secure UK servers. Some processors may transfer data outside the UK, such as to the United States, South Africa, or other jurisdictions. We ensure compliance with UK GDPR through:

  • Adequacy Decisions

  • UK-US Data Bridge

  • Standard Contractual Clauses (SCCs) with a UK International Data Transfer Agreement (IDTA)

We regularly audit processors to ensure data protection, regardless of location.

7. Data Security

We implement robust technical and organisational measures, including:

  • Encryption of data in transit and at rest

  • Secure access controls and authentication

  • Regular security audits and staff training

  • Secure cloud backups via AWS

In case of a data breach, we will notify the ICO within 72 hours if required and inform affected individuals if there’s a high risk to their rights.

8. Cookies and Tracking

Our website uses cookies to enhance your experience.

Cookie Types:

  • Necessary Cookies: Essential for website operation.

  • Performance Cookies: Collect anonymised data about website usage (e.g., Google Analytics).

  • Functionality Cookies: Remember user choices (e.g., usernames, language, region).

  • Analytics Cookies: Help us understand how visitors interact with the website.

  • Advertisement Cookies: Provide visitors with customised advertisements based on the pages you visited previously and help measure the effectiveness of ad campaigns.

We obtain explicit consent for non-essential cookies via our cookie banner before they are set.

Manage your cookie preferences here: Consent Preferences
For more details, see our Cookie Policy.

IP addresses may be collected for security or analytics but are not linked to non-essential cookies without consent. For chatbot interactions (e.g., via Konig Digital), we notify you of data collection at the start of the chat and obtain consent for non-essential processing (e.g., analytics).

9. Data Retention

  • Enquiry Data: 7 years from last contact.

  • Client Data: 7 years after the end of our relationship.

  • AML Data: 7 years after the end of the business relationship.

  • Marketing Data: Until you withdraw consent or opt out.

  • Usage Data: 2 years for anonymised analytics.

Data is securely deleted or anonymised when no longer needed.

10. Your Rights

Under UK GDPR, you have the following rights:

  • Access: Obtain a copy of your data.

  • Rectification: Correct inaccurate data.

  • Erasure: Request deletion in certain cases.

  • Restrict Processing: Limit data use in specific scenarios.

  • Data Portability: Receive data in a machine-readable format.

  • Object: Oppose processing based on legitimate interests or marketing.

To exercise your rights, email info@liquidexpatmortgages.com. We’ll respond within one month, extendable to three for complex requests.

You may complain to the ICO: www.ico.org.uk | 0303 123 1113

11. Marketing

We may send marketing about mortgage or insurance products, including remarketing to past enquirers whose contact details we hold for up to 7 years, if:

  • You explicitly consent via an opt-in (e.g., form checkbox).

  • You’re an existing contact, and we contact you about similar services under PECR’s soft opt-in, unless you opt out.

You can opt out at any time via email unsubscribe links or by contacting info@liquidexpatmortgages.com. We do not share data for third-party marketing.

12. FCA Compliance

As an FCA-authorised firm (FRN 685425), we process data in line with FCA principles, ensuring communications are clear, fair, and not misleading. Some products (e.g., certain investment mortgages) may be unregulated; we will clearly indicate this.

13. Changes to This Policy

We review this policy annually or after significant changes in processing or regulations. Updates will be posted on our website, with material changes notified via email or a prominent notice.

14. Contact Us

Name: Stuart Marshall
Email: info@liquidexpatmortgages.com
Telephone: +44 161 871 1216
Address: Suite 4b, Link 665 Business Centre, Todd Hall Road, Rossendale, BB4 5HU, United Kingdom

By using our website and services, you acknowledge that your data will be processed as described in this Privacy Policy.