Last updated: 25 May 2018
This is the privacy notice or policy (notice) of PropertyPal Mortgages Limited (we, us or our).
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you come to us for advice on mortgage or protection products or services, generally interact with us as one of our customers, or visit and use our website (regardless of where you visit it from) https://www.propertypalmortgages.com (our website), as an interested party seeking to gather information, or otherwise.
It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any website you have used to access our website or any website that you access from it.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Who we are
Under the General Data Protection Regulation 2016 (GDPR), we act as a data controller (make decisions) for your personal data that we collect and a data processor (process your data) or data controller for any of your data shared with us by a third-party.
If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact us using the details set out below.
Our full details are:
Full Name of Legal Entity: PropertyPal Mortgages Limited, a company incorporated in Northern Ireland under company number NI632933
Email Address: firstname.lastname@example.org
Postal Address: Unit 2D Jennymount Business Park, North Derby Street, Belfast, BT15 3HN
ICO Registration Number: ZA136459 (this is the number under which we are registered with the ICO for the processing of personal data)
PropertyPal Mortgages Ltd is an Appointed Representative of PRIMIS Mortgage Network (Primis Network). PRIMIS Mortgage Network is a trading name of First Complete Ltd which is authorised and regulated by the Financial Conduct Authority for mortgages, protection insurance and general insurance products under reference number 435779.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you would like to make a complaint to the ICO, their contact details are:
By phone - 0303 123 1113
Online - https://ico.org.uk/concerns
Changes to the Privacy Notice and your Duty to Inform us of Changes
This version of this Policy was last updated on 25 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as set out below.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data that you Supply to Us
General Personal Data - This is personal information about you that you share with us through filling in online or offline forms, by email, through the post, on the telephone or by any other means.
Typically, when you visit or use the services on our website, you will be asked to provide certain information about yourself, including your full name, home address, business address, personal and/or business email address and telephone and/or mobile phone number and other contact details.
You may also provide financial details to us to allow us to advise you in relation to mortgage products and services, either over the phone or in person, or by entering details into any of the calculators or forms included on our website.
If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.
If you apply for a role with our organisation, other personal data shared is likely to include your employment history, proof of identity, qualification checks, health information, or whatever other information you volunteer to us.
You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
Where you are sharing personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this Notice with that person/those people.
Data that we collect
- Telephone Recordings - Telephone conversations may be recorded to improve training and to ensure a high level of consistent customer service.
- Technical Data - We may use the following technical services to gather technical data in the following ways:
To view user behaviour and identify user experience issues on the site in order to improve our products and services. HotJar suppress all keystroke data and therefore do not expose any information that can be linked to an individual.
To record 'log files' containing information about the volume and characteristics of our website traffic e.g. IP address, numbers of pages viewed, length of time spent on site. Log files are used to build pictures of how the website is used that help us to monitor and improve the service. You cannot be identified from your log files.
You are not personally identifiable from any of the above data.
Information we receive from third-parties
Business Partners – where we have formal relationships with business partners who may introduce new customers or sales opportunities to us, data would include personal contact details, information on the areas of interest and data required to fulfil a request, product or service. This would include referrals from estate agents, personal referrals, and referrals from our partner company, PropertyPal.com Limited.
Social Media – where you have responded to a promotional item or offer from us through social media facilities such as Facebook, LinkedIn etc., we can receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.
Publicly Available Information – we may collect personal information about you from publicly available sources. This can include your name, address and other publicly available information. As far as passible, we ensure that where any third-parties are involved in suppling such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register, or other electronic identification verification portals such as Smartsearch (http://www.smartsearchuk.com/), who may undertake ID checks on applicants where applying for products or services from a company that requires or accepts these forms of ID checks.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data), other than health or medical information where required to provide protection products and services.
Any such medical data or health information will be carefully safeguarded and only shared with selected and screened third party providers of protection products where required in order to allow such providers to quote for or provide such products or services which you have requested to you. More information is set out in the Disclosures of Your Data section below.
We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
A Cookie is a small text file that is added to your device's hard drive by a web server within our domain. Cookies cannot used to run software programs or add a virus to your device. They are unique to you and avoid you having to input the same information and preferences each time you visit our web site(s). For more information on the cookies used by our website, please see our Cookies Policy which is available at: https://www.propertypalmortgages.com/cookie-policy.
Our website's servers automatically record 'log files' containing information about the volume and characteristics of our website's website traffic (e.g. IP address, numbers of pages viewed, length of time spent on our website). Log files are used to build pictures of how our website is used that help to monitor and improve the service provided by our website. You cannot be identified from your log files.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Our Standard Business Operations:
- To provide the services that we contract to do so with you;
- To provide you with information that you request from us;
- To confirm your identity as a natural living person; and
- As part of our billing, payments and recovery processes.
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will only receive marketing communications from us if you have opted to receive it. This includes where you have consented to being contacted by PropertyPal Mortgages by email or telephone to discuss mortgage or protection quotes and related information.
We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use MailChimp to manage our email correspondence. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.
Children Under Thirteen
Our website and services are not intended to be used by children under 13 years old. We will never knowingly collect data from children below 13 years old. If you become aware of such a child (or another person) supplying data to us, please contact us.
Please note that we may collect data on children aged under 13 years of age from their parents or guardians where this is relevant for the purposes of the products or services that are being requested by such parents or guardians (for example, names and dates of birth of dependent children for the purposes of protection or assurance products).
We will take care when processing such data and only do so where one of the legal grounds set out above applies.
Disclosures of your personal data
We may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in the How We Use Your Personal Data section above or otherwise below:
with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
with third party purchasers, if our website is acquired by a third-party, and data is transferred as part of the purchased assets;
with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above;
with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.);
with service providers acting as processors based in the European Union or United Kingdom who provide IT and system administration services, as set out below:
with email marketing services i.e. Mailchimp to send news articles and marketing emails about new products and services where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails;
with processors offering software products provided by the Primis Network for the purposes of compliance and the provision of financial advice within the bounds of the law and in order to provide quotes for Protection products and services;
with analytical service providers in order to analyse our website traffic to improve products and services;
with processors offering software products that are used to schedule and host meetings with you, review & sign documents and to explain our recommendations. We remove any personal data from these products after the purpose for which they have been used, has been satisfied;
with processors offering software tools that are used to store personal information provided by you for the purposes of managing your mortgage and protection product applications e.g. proofs of income and identify; and
with processors offering software tools that are used to manage our communications with you whether you are mortgage and protection client, considering becoming a client or have completed your mortgage and protection product journey with us;
with various mortgage lenders. These lenders have been carefully selected by the Primis Network, and are all authorised and regulated by the Financial Conduct Authority (FCA). A full list of lenders is available on request; or
with introducers in order to track general progress of your mortgage journey in order to satisfy part of our contractual agreement with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes and in accordance with our instructions.
Any medical data you provide to us may be shared with companies we have recommended to you for the purposes of allowing them and us to provide you with or recommend suitable protection products. These providers have been carefully selected by the Primis Network, and are all regulated by the FCA. A full list of providers to whom this data may be disclosed is available from us on request. We will only share your medical data where you have expressly consented to us doing so. Your medical data will not be shared with any other third parties.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing purposes.
The data you provide to us will be securely stored and backed up within the EEA. We do not transfer your personal data outside the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our website, and before it reaches us, such data is transmitted at your own risk.
How long will you use my Personal Data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will keep your data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures, i.e. the term of your mortgage or protection policy.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Notice
We may change this notice from time to time. Any material changes to this notice will be notified to you.
Choice of Law and Jurisdiction
This notice shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this notice.
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to
means any personal information we hold on you;
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
means European Economic Area;
means the General Data Protection Regulation (2016);
means the Information Commissioner's Office - the UK data protection regulatory body;
means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
refers to external suppliers who your personal data may be shared with;
Means PropertyPal Mortgages Limited;
relates to you as a natural living person;
means someone or some people who legally acting on your behalf.