Privacy Policy – HERITAGE MORTGAGES

Our Privacy and Data Protection Policy

This privacy and data protection policy explains how we collect, use, secure, transfer and share any information we collect about you in the course of our business and using this website.

What information do we collect about you

How will we use the information about you

Marketing

Access to your information and correction

Other websites

Changes to our privacy policy

How to contact us

What information do we collect about you

We collect information about you when you request a quotation or advice for products or services. The type of information will vary depending on the service we are providing. For example:

We may collect the following information:

Your contact details, such as your name, address, telephone number and email address

Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number)

Passport details, driving licence, utility bills, payslips, bank and credit card statements, financial accounts

Details of the services you request from us

Details of your financial dependents and partner(s)

Any records held by financial crime prevention agencies

Information held on your credit report & the Electoral Register and by providers of utility services

Details of your employment or self-employment status, including existing and previous employer details, income and source(s) of wealth

Commitments, debts and mortgages

Medical information (for insurance purposes where required)

We only request information required for the service or product you are interested in. We have to ask a lot of information for mortgages and protection insurance (e.g. Life Assurance, Critical Illness Cover and Income Protection), and for general insurances we will require information relevant to the risk being insured.

Historically, Heritage Mortgages has rarely engaged in data requests unrelated to providing you with a service. Nonetheless, there are other ways we may collect your information such as when you voluntarily complete customer surveys, provide feedback and participate in competitions. Further, website usage information can be collected using cookies.

If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalised marketing messages about our products or services, events and promotions.

In some instances, we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how clients and customers use our products and services. This is necessary for the purposes of our legitimate interests in analysing our brand and determining how to improve our services.

How will we use the information about you?

We collect information about you to process your mortgage and insurance enquiries and instructions, undertake research and advise / arrange suitable mortgages and insurances. In addition:

Improving our products and services: we will use your personal information to build a profile on you in order to understand your requirements, to improve our Website, as well as to personalise the properties and services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate interests in providing better products and services for you and our other customers.

Processing your transaction: we use relevant personal information described above (including your name, address and financial details) to enable us to complete a transaction with you, such as buying, selling, renting or letting a property through us. This information may require to be passed on to third parties, including solicitors, surveyors, financial advisors etc.

Preventing fraud: we will also use your personal information to assess your creditworthiness (in the case of buying or renting a property) and to prevent fraud. For this purpose, we may need to share your personal information with our referencing providers and/or solicitors (see “how we share your personal information” below). This is necessary for the purposes of our legitimate interests in ensuring we are not the victim of fraud and to protect our legal rights.

With Legal and Law Enforcement: Heritage Mortgages will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Heritage Mortgages property and legal rights, to protect the personal safety of our website users or by order of a valid injunction from a court or law enforcement agency.

To provide customer support: if you contact our team (or vice versa), we will use personal information such as your email address, phone number and residential address as well as your contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons we will process it as it is necessary for the purposes of our legitimate interests in ensuring we can provide the best service possible.

Where required we may share limited personal information you provide when you register with us or enter in to a transaction with us, as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf (Data Processors).

With Service Providers e.g. Lenders / Insurers / Connected 3rd Parties – such as Solicitors / Surveyors / Doctor (for Insurance Medical Assessment purposes) . Where required we may share limited personal information you provide when you register with us or enter in to a transaction with us, as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf (Data Processors).

Marketing: when you sign up to receive our newsletters, register as an applicant, enter in to a transaction with us, provide feedback on our service online or use our Website; we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.

Website user experience: if you are logged in to your Account on our Website we may alter the way the website works to improve and/or enhance the information displayed to you, or to optimise the way you interact with the Website. We may show personalised content based upon your previous interactions with the website.

Heritage Mortgages will not share your information for marketing purposes with other companies or firms. In processing your instructions, we may send your details to, and also use information from credit reference agencies and fraud prevention agencies. By the nature of our profession and where requested, we will be passing on your data to be able us to obtain insurance quotations, insurance policies, mortgages and any other financial services we provide. Any financial institution or insurance company we recommend or with whom you eventually take out a product with, will also be subject to the General Data Protection Regulations and you will need to consider your options with them directly.

Personal information of others

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this privacy policy.

What kind of channels

We will send direct marketing communications to you via the channel you choose, such as post, email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalised marketing communications.

What kind of messages

The messages we will send you will be personalised and tailored to your individual preferences and requirements. We use analytics in order to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our products and services, events or promotions and other company news. We personalise these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with Heritage Mortgages, including by sending you personalised messages.

Marketing

There may be occasion by knowing you that we would like to recommend some other contract, service or product that we feel is important and in relation to what we have discussed in the past. There is provision in the new laws as we understand them for us to contact you outside of the performance of the contract for services being legitimate interests.

Using legitimate interests we would have to:

Identify a legitimate interest;

Show that the processing of your data we hold is necessary to achieve it; and

Balance it against your interests, rights and freedoms.

Please note, Heritage Mortgages do not have a track record for unrelated marketing. Nor would we pass on your details to any entity purely for marketing purposes. So we would urge you to opt in with us for general marketing and continue to allow us to use your data responsibly in connection with the work we do for you.

You have a right at any time to stop us from contacting you for marketing purposes.

Please note you will have to opt in if you would like us to continue contacting you with products and services which may be remote from the contract we have with you, but nonetheless could well be things you would want to hear.

Analysing our business

We will use your personal information (including by anonymising and aggregating it with other customers’ personal information) for sales and financial analysis purposes, to determine how Heritage Mortgages is performing and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.

We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.

Access to your information and correction

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. In addition, you may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information (The Right to Erasure/The Right to be Forgotten).

You may also write to us at any time to object to our use of your personal information or request that we provide your personal information in a usable electronic format and transmit to a third party (Right to Data Portability). We will comply with these requests in relation to your personal information in line with applicable law.

Personal data breaches

In order to comply with applicable law, Heritage Mortgages has implemented procedures to detect, report and investigate personal data breaches. A data breach is defined by the Information Commissioner’s Office (ICO) as: “A breach of security leading to the destruction, loss, alteration, unauthorised disclosure or, or access to, personal data.

”The ICO will be informed of all data breaches which present a high risk to our clients and customer’s rights and freedoms and in line with applicable law, a notifiable breach will be reported within 72 hours of us becoming aware of it. The individual(s) involved will also be informed.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.

How Long Do We Store Your Information For?

The length of time we hold your information for will vary dependent on lawful basis for collecting and processing the data. Heritage Mortgages will hold data supplied with consent, where there is a legitimate interest in doing so, there is a contractual necessity to do so, or where there is a requirement to comply with legal obligations. For example in order to comply with the requirement of the FCA, to maintain clear and full written records of transactions for a period of six years and to comply with the Money Laundering Regulations 2017 requirement to hold records for a period of 5 years.

Storage

All digital information you provide to us is stored in the UK on our secure (password and firewall protected) servers and all paper based information is also securely stored in the UK. Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of any data sent over the internet between your Device and our Website. Any such data transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, as part of our secure backups and data disaster recovery procedures.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

By submitting your personal data to us, you agree to this transfer, storing or processing.

Your Rights

You have the right to ask us not to process your personal data for marketing purposes, to alter your preferences for the type of marketing content you receive (such as properties for sale, information about related services etc) or to alter the methods via which you receive marketing correspondence from us (i.e. via email, text, post or phone call). We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You can also exercise the right to prevent such processing of your data at any time by contacting us at [email protected] or by writing to us. Our Website may, from time to time, contain links to and from the websites of our partners and third party service providers. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Use of third party websites is at your own risk.

Your Rights

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to our privacy policy

Heritage Mortgages has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our privacy statement in order to ensure that it is free of errors and clearly visible on our Website, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites along with an updated version of the privacy statement. This privacy policy was last updated on 4th April 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

By email:

info@[email protected]

By letter:

Heritage Mortgages, 15 Queen Square, Leeds LS2 8AJ

Heritage Mortgages is a trading style of Heritage Mortgage Advice Ltd which is authorised and regulated by the Financial Conduct Authority. Heritage Mortgage Advice Ltd is entered on the Financial Services register (www.fca.org.uk/firms/systems-reporting/register) under reference 794556. Please note that Commercial Mortgages and some forms of Buy to Let Mortgages are NOT regulated by the Financial Conduct Authority. The guidance and/or advice contained within this website are subject to the UK regulatory regime, and are therefore targeted at consumers based in the UK.

Think carefully before securing other debts against your home. Your home may be repossessed if you do not keep up repayments on your mortgage or any other debt secured on it.

There may be a £195 administration fee payable on application. There may also be a fee for mortgage advice, the charging of such a fee will depend on your circumstances but we estimate that it will be £300.

If you wish to register a complaint, please write to [email protected] or telephone 0113 8000 365. A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at https://www.financial-ombudsman.org.uk or by contacting them on 0800 0234 567.