Privacy Policy – The Equity Release Network (TERN)

1. Introduction

The Equity Release Network (“TERN”, “we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store and share personal data when you interact with our website, services and platforms.

TERN operates as a later-life lending network and introducer. We support authorised adviser firms and, where applicable, introduce consumers to regulated advisers for the purpose of receiving advice. TERN does not provide regulated financial advice directly to consumers via this website.

2. Who We Are (Data Controller)

The Equity Release Network Ltd (TERN) is the data controller responsible for your personal data.

Authorised and regulated by the Financial Conduct Authority
FCA Firm Reference Number: 1036279
Registered in England & Wales. Company Number: 16148969

TERN works alongside other companies within the Equity Release Group and its technology provider, Equitec, under appropriate data-sharing arrangements.

3. What Personal Data We Collect

Personal data means any information that identifies you as an individual. It does not include data that has been anonymised.

Depending on how you interact with TERN, we may collect, use, store and share the following categories of personal data:

Identity Data – such as name, title, date of birth and gender

Contact Data – such as address, email address and telephone number

Property and Mortgage Data – such as property value and high-level mortgage information

Financial Data – limited financial information relevant to your enquiry (TERN does not collect bank or card details from consumers)

Technical Data – including IP address, browser type, device information, operating system and usage data

Usage Data – information about how you use our website, tools and services

Profile Data – such as preferences, feedback and enquiry details

Marketing and Communications Data – your preferences in receiving communications from us

In some circumstances, we may collect special category data, such as information relating to health or vulnerability, where this is voluntarily provided and relevant to supporting appropriate adviser introductions.

We may also collect and use aggregated data for analytical and reporting purposes. Aggregated data does not identify individuals and is not treated as personal data unless combined with identifiable information.

TERN does not collect information relating to criminal convictions or offences.

4. How We Use Your Data

We collect personal data using a variety of methods, depending on how you interact with TERN.

We collect personal data using the following methods:

Direct interactions

You may provide personal data directly to TERN when you:

• submit an enquiry via our Find an Adviser service
• complete online forms or use tools on our website
• request information about our services
• communicate with us by email, telephone or other means
• register interest in becoming an adviser or firm within the TERN network
• subscribe to communications, updates or events

Automated technologies

When you use our website, we automatically collect certain technical and usage data through cookies and similar technologies. This includes information about how you navigate the site, pages visited and device information. These technologies help us improve website functionality, performance and user experience. Further details are set out in our Cookie Policy.

Third parties

Where appropriate, we may receive personal data from third parties, including:

• authorised adviser firms, where a consumer has requested an introduction
• technology and verification providers supporting our services
• publicly available sources, such as the FCA Register

We only collect personal data from third parties where it is lawful to do so and relevant to the services we provide.

5. Lawful Basis for Processing

We will only process your personal data where we have a lawful basis to do so under data protection legislation.

Depending on the nature of your interaction with TERN, we rely on one or more of the following lawful bases:

Legitimate interests

Where processing is necessary to operate our website, manage our network, introduce consumers to authorised advisers, support adviser onboarding, maintain oversight, improve our services and ensure effective, compliant consumer journeys. We ensure our legitimate interests do not override your rights and freedoms.

Contractual necessity

Where processing is required to enter into, or perform, a contract with adviser firms, appointed representatives or other business partners engaging with TERN.

Legal or regulatory obligation

Where processing is necessary for us to comply with legal or regulatory requirements, including obligations imposed by the Financial Conduct Authority and other regulators.

Consent

Where required, for example in relation to marketing communications or optional website features. You may withdraw your consent at any time.

We do not process personal data for purposes that are incompatible with those set out in this Privacy Policy.

6. Sharing Your Data

Sharing data within our group

TERN is part of the Equity Release Group and works closely with its technology provider,

Equitec Limited (company number 11425582), which supplies certain digital platforms, systems and infrastructure used by TERN to support its website, introducer services, adviser onboarding and network oversight.

Where personal data is processed through TERN systems, this may be shared with Equitec for the purposes of:

• operating and maintaining TERN’s digital platforms
• providing technical support and system administration
• enabling reporting, oversight and regulatory compliance

TERN and Equitec act under appropriate data-processing and confidentiality arrangements and will process personal data in accordance with this Privacy Policy and applicable data protection legislation.

Sharing data with authorised advisers

Where consumers submit enquiries via TERN’s Find an Adviser service, personal data will be shared with one or more authorised adviser firms for the purpose of providing regulated financial advice.

Once an enquiry is passed to an adviser:

• responsibility for regulated advice rests with the adviser or firm
• the adviser becomes the data controller for personal data processed in connection with that advice
• the adviser’s own privacy policy will apply

TERN does not provide regulated advice and does not control how advisers deliver advice.

Sharing data with third-party service providers

We may also share personal data with trusted third parties who support the operation of our business, including:

IT and technology service providers

These third parties act as data processors and are only permitted to process personal data in accordance with our instructions and applicable law.

Aggregated and anonymised data

We may use aggregated or anonymised data for reporting, analysis and business improvement purposes. This data does not identify individuals and is not considered personal data under data protection law.

Legal and business disclosures

We may disclose personal data where required to:

• comply with a legal or regulatory obligation
• respond to lawful requests from regulators or authorities
• protect the rights, property or safety of TERN, adviser firms or users
• support fraud prevention and risk management

In the event of a business sale, merger or restructuring, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

Third-party obligations

All third parties with whom we share personal data are required to:

• respect the security of personal data
• process it lawfully and fairly
• use it only for specified purposes

We do not permit third parties to use personal data for their own marketing or unrelated purposes.

7. Data Storage

TERN primarily stores and processes personal data within the United Kingdom. However, some of the third-party service providers we use may process personal data outside the UK or European Economic Area (EEA).

Where personal data is transferred outside the UK or EEA, we ensure that an appropriate level of protection is in place, including:

• transfers to countries deemed to provide adequate protection; or
• the use of approved contractual safeguards, such as standard contractual clauses.

We take steps to ensure that all personal data is protected in accordance with applicable data protection laws, regardless of where it is processed.

If you would like further information about the safeguards used when transferring personal data internationally, please contact us using the details set out in this Privacy Policy.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy and to meet our legal and regulatory obligations. Retention periods vary depending on the nature of the data and the context in which it is processed.

9. Third-Party Links

The TERN website may contain links to third-party websites, including authorised adviser firms and other external resources. These links are provided for information and convenience only.

TERN does not control, endorse or accept responsibility for the content, privacy practices or services provided by third-party websites. When you follow a link to another website, that organisation’s own terms, conditions and privacy policy will apply.

Where consumers are introduced to authorised advisers via TERN’s Find an Adviser service, responsibility for regulated advice, recommendations and the handling of personal data in connection with that advice rests with the adviser or firm providing the service.

10. Your Rights

Under data protection laws, you have certain rights in relation to your personal data. These rights may apply depending on the circumstances and how we process your information.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”).
• Request correction of any personal data we hold about you that is inaccurate or incomplete.
• Request erasure of your personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data where we are relying on a legitimate interest and you believe your rights override those interests.
• Request restriction of processing of your personal data in certain circumstances.
• Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact us using the details set out in this Privacy Policy.

No Fee is Usually Required

You will not usually have to pay a fee to access your personal data or to exercise your rights. However, we may charge a reasonable fee, or refuse to act on a request, if it is clearly unfounded, repetitive or excessive.

What We Require From You

We may need to request specific information from you to help us confirm your identity before responding to your request. This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it. We may also contact you to request further information where necessary to help us respond more efficiently.

Response Time Limit

We aim to respond to all legitimate requests within one month. Where a request is particularly complex or multiple requests are received, it may take longer. If this happens, we will notify you and keep you informed.

11. Cookies

We use cookies and similar technologies to distinguish you from other users of our website. This helps us to provide a better browsing experience and allows us to improve how our website functions.

Cookies may be used to:

• enable core website functionality
• analyse how visitors use our website
• improve performance and user experience

You can set your browser to refuse all or some cookies, or to alert you when cookies are being set. Please note that disabling or refusing cookies may affect the availability or functionality of certain parts of the website.

For more detailed information about the cookies we use and how to manage your preferences, please see our Cookie Policy.

12. Security

TERN has implemented appropriate technical and organisational security measures to protect personal data against accidental loss, unauthorised access, misuse, alteration or disclosure.

Access to personal data is restricted to employees, officers, agents, contractors and approved third parties who have a legitimate business need to know. All such individuals are required to process personal data only in accordance with TERN’s instructions and are subject to confidentiality obligations.

We use a combination of physical, technical and administrative controls to safeguard data, including secure systems, access controls and monitoring. Where we use third-party service providers or technology partners, we ensure that appropriate security standards and contractual protections are in place.

TERN has established procedures to identify, assess and manage any suspected personal data breaches. Where required by law, we will notify affected individuals and the relevant regulatory authorities in accordance with applicable data protection requirements.

While no system can guarantee absolute security, TERN is committed to maintaining a robust security framework and regularly reviewing its measures to reflect changes in technology, risk and regulatory expectations.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, regulatory requirements or how we process personal data. This version was last updated in January 2026. The most current version will always be available on our website.

It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal details change so we can keep our records current.

14. Contact Details

If you have any questions about the TERN privacy policy, please contact us in any of the following ways:

Full name of legal entity: The Equity Release Network Ltd

In writing: 304 Bridgewater Place, Birchwood Park, Birchwood, Warrington, Cheshire, WA3 6GX

By Email: mail@theequityreleasenetwork.com

By Telephone: 01925 738288

You also have the right to complain to the Information Commissioner’s Office (ICO).