Combined Client Privacy Notice

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Mortgage Advice Bureau and Freedom Mortgages are trading names of Freedom 365 Mortgage Solutions Limited, who are Appointed Representatives of Mortgage Advice Bureau.


Freedom 365 Mortgage Solutions Limited registered Office: 2nd Floor, Gresley House, Ten Pound Walk, Doncaster, DN4 5HX. Registered in England number. 10247549 Mortgage Advice Bureau (Derby) Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 6003803 Mortgage Advice Bureau Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 3368205

All companies known together in this document as “we”, “our” and “us”

As joint data controllers of your data, Mortgage Advice Bureau and Freedom 365 Mortgage Solutions Limited comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how Mortgage Advice Bureau Limited & Freedom 365 Mortgage Solutions Limited processes your personal data.

The personal data we collect about you

Personal data collected, used, stored and transferred by us may include:

How do we collect your personal data?

Personal data is collected by us using the following methods:

How do we use your personal data?

We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Purpose/Activity Type(s) of data Lawful basis for processing
To initially engage with you to discuss your requirements
  • Identity
  • Contact
Consent
To process and deliver your application for a mortgage or protection product
  • Identity
  • Contact
  • Financial
  • Special Category
  • Transaction
  • Marketing & Comms

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include
  • Notifying you about changes to our terms or privacy policy
  • Customer reviews / surveys
  • Re-engagement when existing products nears expiry / review protection needs
  • Identity
  • Contact
  • Profile & Usage
  • Marketing & Comms

Performance of a contract with you

To comply with a legal obligation

Necessary for our legitimate interests (to re-engage with you to review your existing mortgage / protection needs, and to maintain and improve customer service standards)

To respond to case enquiries and input to & defend against complaints
  • Identity
  • Contact
  • Profile & Usage
  • Transaction
  • Marketing & Comms

To comply with a legal obligation

Necessary for our legitimate interests (to ensure that complaints can be responded to accurately)

To perform an affordability check for a property
  • Identity
  • Contact
  • Financial
  • Profile & Usage
Consent
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Identity
  • Contact
  • Technical

To comply with a legal obligation

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity
  • Contact
  • Profile & Usage
  • Marketing & Comms
  • Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Profile & Usage
Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our marketing strategy)

Change of purpose

We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and 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.

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on the Freedom Mortgage web page. This Privacy Notice was last updated on 14th January 2019. Historic versions can be obtained by contacting us.

Please also refer to the websites of Mortgage Advice Bureau and Freedom Mortgages for additional information and our ‘Terms & Conditions’ which outlines the services we provide.

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by contacting our Compliance team at compliancehelpdesk@freedom-finance.com or by clicking on the relevant link in email communications you receive from us.

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Data Security

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. We also limit access to your personal data to only those staff, appointed representatives, advisers, business partners and suppliers 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.

Cookies

When using the Freedom website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For further information about the cookies MAB use, please see the MAB website.

Website Third-party links

Our 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.

Sharing of personal data outside of the European Economic Area

Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

We may also use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.

Who we disclose personal data to

Your personal data may be shared with third parties for the following purposes:

Type of recipient Reason
Within Mortgage Advice Bureau Depending on your requirements, it may be necessary to share your personal data with Mortgage Advice Bureau’s specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients
Within the Freedom Finance Group - Freedom Finance Group consists of Freedom Finance & Freedom 365 Mortgage Solutions For accounting, statistical and analytical purposes.
With your consent your data may be shared in order to promote other financial services offered within Freedom Finance Group
Lenders and protection product suppliers To source and submit applications in order to conclude the contract for the mortgage / protection application and the ongoing servicing of these contracts.
External suppliers Specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Mortgage Advice Bureau.
Estate agents / new home builders We may share information about the progress of your application with the firm of mortgage / protection advisers, estate agents and home builders with whom you are interacting.
Licensed Credit Agencies For the purposes of confirming your identity for fraud prevention; to perform a credit assessment to assess your eligibility; and as part of an application request for a Lenders Decision In Principle.
Regulators Sharing of information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.
Others Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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.

These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.

How long is your personal data retained?

We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

Purpose of processing Retention
Successful mortgage / protection applications For the full mortgage or protection policy term plus a further 6 years, or for a period of 30 years for historical cases if the original term is not recorded
Withdrawn, stalled, incomplete and failed mortgage / protection applications 2 years from the date the latest application was started
Affordability assessments for new build property 2 years from Decision In Principle if affordability check does not proceed to a full mortgage application
Enquiry data obtained from third parties (Estate Agents, websites) that do not result in an application for a mortgage / protection product 2 years from the date the lead was received from the Introducer
Future marketing of customer data – where consent has been given to keep customers informed of other products and services within the Freedom Finance Group that may be of interest Freedom Finance Group - Indefinitely unless customer withdraws their consent and/or requests data be removed

After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

Your legal rights regarding your personal data

You have the right to:

Questions

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing compliancehelpdesk@freedom-finance.com or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

What if I am still not satisfied?

If you are not satisfied with how we have responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.