Privacy Policy

1. Who We Are

MarketMedia Ltd is the data controller. Mortgage advice is provided by Hayden Richards, CeMAP-qualified, as a Registered Individual of Marklay Mortgages Ltd, which is authorised and regulated by the Financial Conduct Authority (FRN 930490). Richards & Logic is a trading style of Marklay Mortgages Ltd. Our registered office is 86-90 Paul Street, London, EC2A 4NE.

You can verify Marklay Mortgages Ltd on the FCA Financial Services Register at register.fca.org.uk.

2. The Data We Collect

We collect information necessary to handle your enquiry and, where appropriate, provide you with regulated mortgage advice through our authorised adviser, including:

• Contact details (name, address, email, phone)
• Financial information (income, bank statements, tax returns, liabilities)
• Employment details (retained profits, dividends, day rates)
• Identity verification documents (passport/driving license)
• Special category data (health information if relevant to protection policies)
• How you found us, if you choose to tell us: the wording of a question you asked an AI assistant or search engine, and where you saw us. Both are optional free-text fields and you can leave them blank.

The "how you found us" fields are the only ones written in your own words rather than selected or measured. Please do not include personal, financial or health details about yourself or anyone else in them — we only need the wording that led you to us. If you do include such details we will hold them under this notice, but the fields are not intended for that purpose and we do not ask you to complete them.

3. Why We Need Your Data

We process your data on the following legal bases:

• Contractual Necessity: To respond to your enquiry and provide the service you request.
• Legal Obligation: To meet applicable legal, regulatory and record-keeping requirements.
• Legitimate Interests: To improve our services and manage our business relationships.
• Legitimate Interests (how you found us): To understand which questions and channels bring people to us, so we can answer them better. This is optional information you choose to give, it is used for our own analysis only, and it plays no part in any mortgage assessment or in the advice you receive. You can ask us to delete it at any time without affecting your enquiry.

4. Sharing Your Data

We may share your information with:

• Marklay Mortgages Ltd: The FCA authorised principal firm (FRN 930490) under which regulated mortgage advice is provided.
• Mortgage Lenders: Where needed by the regulated adviser as part of your mortgage enquiry or application.
• Credit Reference Agencies: To assess your creditworthiness.
• Twenty (CRM): Our lead management system.
• Regulatory Bodies: The FCA or Information Commissioner's Office (ICO).

5. Data Retention

We may keep enquiry records for up to 7 years to handle future queries, complaints or legal requirements. Marklay Mortgages Ltd will explain its own retention periods where it provides regulated advice.

The optional "how you found us" information is kept for up to 24 months and then deleted, because its only purpose is to show us which questions and channels bring people to us. It is not part of your advice or application record, and deleting it does not affect your enquiry. You can ask us to remove it sooner at any time.

6. Your Rights

Under GDPR, you have the right to:

• Access the data we hold about you.
• Request correction of inaccurate data.
• Request deletion of data (where legal obligations don't require retention).
• Object to processing based on legitimate interests.

To exercise these rights, please contact us at hello@complexincome.mortgage.

7. How to Complain

If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk.