PECR Policy

Cuffe Mortgage and Protection Brokers (“we”, “us”, “our”) are committed to respecting and protecting your privacy in accordance with the UK Privacy and Electronic Communications Regulations (PECR), the UK General Data Protection Regulation (UK GDPR), and the standards set by the Financial Conduct Authority (FCA).

This policy outlines how we comply with PECR, particularly in relation to electronic communications, use of cookies, and direct marketing practices.

1. Who We Are

Cuffe Mortgage and Protection Brokers Ltd is an Appointed Representative of HL Partnership Limited who are authorised and regulated by the Financial Conduct Authority (FCA). Our FCA registration number is 1034936 and HL Partnership Limited’s FCA registration number is 303397.

2. Scope of This Policy

This policy covers:

• The use of cookies and similar technologies on our website.
• Our approach to electronic communications, including emails, SMS, and online advertising.
• Direct marketing practices in compliance with PECR and FCA expectations.

3. Cookies and Tracking Technologies

We use cookies on our website to:

• Ensure functionality and performance.
• Collect analytics to improve user experience.
• Enable targeted marketing (with your consent).

Consent
We only place non-essential cookies (e.g. those used for analytics or advertising) with your explicit consent. On your first visit, you will be presented with a cookie banner to manage your preferences.

For more details, please refer to our Cookie Policy.

4. Electronic Communications

We send electronic communications (such as emails and SMS) for the following purposes:

• Service-related messages (e.g. updates about your application).
• Regulatory or compliance notifications.
• Direct marketing (only with prior consent or where an existing relationship allows).

Legal Basis:
We rely on either:

• Your explicit consent (opt-in), or
• The “soft opt-in” exemption under PECR where you are an existing customer, and the communication relates to similar products or services.

You can opt out of marketing communications at any time by clicking the “unsubscribe” link in our emails or by contacting us directly.

5. Consent Management

We follow best practices for obtaining, recording, and managing consent:

• Consent is freely given, specific, informed, and unambiguous.
• We maintain records of consent.
• You may withdraw consent at any time without detriment.

We ensure that consent mechanisms are compliant with FCA expectations around clarity, fairness, and consumer understanding.

6. Third-Party Communications

We do not share your personal information with third parties for their own marketing purposes.

Where we use third-party services (e.g., email delivery platforms or cookie analytics tools), we ensure contracts are in place that require compliance with PECR, UK GDPR, and FCA standards.

7. Your Rights

You have the right to:

• Object to the use of your data for direct marketing.
• Access, update, or delete your personal information.
• Withdraw your consent at any time.

Please see our Privacy Policy for further information on your data rights and how to exercise them.

8. Contact Us

If you have any questions or concerns about this policy or your privacy rights, please contact:

Cuffe Mortgage and Protection Brokers Ltd.
17 Barmore Drive,
Bishopton,
PA7 5QW
Email: nick@cuffemortgages.co.uk
Telephone: 01505 436 336

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.