Privacy & Cookies

1.       Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5    In this policy, "we", "us" and "our" refer to Mortgage Advice Hub Ltd. For more information about us, see Section 19.

2.       How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google analytics tracking system and our server logs. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process information included in your account on our website ("account data"). The account data may include your name, email address, telephone number, address, login and password, related financial and employment details relevant to your enquiry. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4    We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, gender, date of birth, relationship status, financial and employment details relevant to your enquiry. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, record keeping and personalizing our website and services to you. The legal basis for this processing is for our legitimate interests, namely the proper administration of our website and business plus the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5    We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may your name, address, telephone number, email address, gender, date of birth, relationship status, financial and employment details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business as well as the performance of a contract between you and us and taking steps, at your request, to enter into such a contract.

2.6    We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business as well as the performance of a contract between you and us.

2.7    We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and providing relevant services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business as well as the performance of a contract between you and us and the taking steps, at your request, to enter into such a contract.

2.8    We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, address, telephone number, email address, gender, date of birth, relationship status, financial and employment details relevant to your enquiry plus any information contained in communications between us and you relevant. The source of the customer relationship data is you.] The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.9    We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is you and our payment services provider. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.10  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters from time to time. The legal basis for this processing is your consent and our legitimate interests, namely communications with our website visitors and service users as well as the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.11  We may process information contained in or relating to any communication that you send to us ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users and the proper administration of our website and business.

2.12  We may process general data that you have entered on our website relevant to your enquiry. This data may include your name, address, telephone number, email address, gender, date of birth, relationship status, financial and employment details or any additional data relevant to your enquiry. The source of this data is you. This data may be processed for the legitimate purposes of your enquiry or potential future enquiry and/or contact/contract. The legal basis for this processing is our legitimate interests as well as the performance of a contract between you and us and taking steps, at your request, to enter into such a contract.

2.13  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.14  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.

2.15  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.16  Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.       Automated decision-making

3.1    We will use your personal data for the purposes of automated decision-making in relation to provide you with the service of your enquiry.

3.2    This automated decision-making may/will involve processing your data with the relevant 3rd parties such as email service providers Banks/Building Societies and other service providers to help assist with getting the service you enquired about.

3.3    There may be significance and possible consequences of this automated decision-making that may be out of our control such as hacking to name just one but we will endeavour to use the most secure methods of communicating/processing as possible to us.

4.       Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies/intermediary partners this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at www.mortgageadvicehub.com  and also www.stonebridgegroup.co.uk   

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    Your personal data held in our website database and client management system will be stored on the servers of our hosting services providers identified at www.names.co.uk 

4.4    We may disclose relevant personal data to our service partners/intermediaries insofar as reasonably necessary for providing you with the service to suit your enquiry.

4.5    Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.fisglobal.com/privacy 

4.6    We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

4.7    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.       International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].

5.2    We and our other group companies have offices and facilities in various locations. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these locations will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the source.

5.3    The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an "adequacy decision" with respect to the data protection laws of each country with the United Kingdom. Transfers to each country with the United Kingdom will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.4    Mortgage Advice Hub is situated in England.[ The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to any other country within or outside the United Kingdon will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the source.

5.5    You acknowledge that yours/any personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.       Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)    Successful mortgage / protection application - 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

(b)    Withdrawn, stalled, incomplete and failed mortgage/ protection applications - 2 years from the date the latest application was started, or 6 years from the application submitted date if application was submitted and subsequently rejected

(c)    Client Portal accounts - 2 years from the date of last login if not proceeded to full application

(d)    Affordability assessments for new build property - 2 years from Decision In Principle if affordability check does not proceed to a full mortgage application

(e)    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

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of the specific personal will be determined based on the closest logged date to the event/service carried out.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.       Security of personal data

7.1    We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2    We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3    The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

7.4    Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.5    You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.6    You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

8.       Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access - you can ask for copies of your personal data;

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)    the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

        and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by written notice to us.

9.       Third party websites

9.1    Our website includes hyperlinks to, and details of, third party websites.

9.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.    Personal data of children

10.1  Our website and services are targeted at persons over the age of 18 years old.

10.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.    Updating information

11.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.    Acting as a data processor

12.1  In respect of , we do not act as a data controller; instead, we act as a data processor.

12.2  Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13.    About cookies

13.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3  Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

14.    Cookies that we use

14.1  We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: PHPSESSID, WHMCSDomRenewRes, WHMCSFD, WHMCSFWq6kSSrxOYz, and WHMCSSD);

(b) status - we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: PHPSESSID, WHMCSDomRenewRes, WHMCSFD, WHMCSFWq6kSSrxOYz, and WHMCSSD);

(c) shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: PHPSESSID, WHMCSDomRenewRes, WHMCSFD, WHMCSFWq6kSSrxOYz, and WHMCSSD);

(d) personalisation - we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: PHPSESSID, WHMCSDomRenewRes, WHMCSFD, WHMCSFWq6kSSrxOYz, and WHMCSSD);

(e) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: PHPSESSID, WHMCSDomRenewRes, WHMCSFD, WHMCSFWq6kSSrxOYz, and WHMCSSD);

(g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: cookies).

15.    Cookies used by our service providers

15.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: __utma, __utmb, __utmc, __utmt, __utmz, _ga, _gat, and _gid.

15.3  We use Zendesk Chat to provide a live chat facility on our website. Zendesk chat maintains the chat across website pages by means of cookies. The information gathered is used to provide a seamless chat even if clicking between different pages on our website. Zendesk Chat’s privacy policy is available at: https://www.zendesk.co.uk/company/customers-partners/privacy-policy/. The relevant cookies are: ADATA, ajs_group_id, ajs_user_id, _biz_flagsA, _biz_nA, _biz_pendingA, _biz_sid, _biz_uid, __cfduid, _uetsid , __zlcmid, cp_zopim_visited, optimizelyBuckets, optimizelyEndUserId, optimizelySegments, wsid.

16.    Managing cookies

16.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2  Blocking all cookies will have a negative impact upon the usability of many websites.

16.3  If you block cookies, you will not be able to use all the features on our website.

17.    Amendments

17.1  We may update this policy from time to time by publishing a new version on our website.

17.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

17.3  We may notify you of significant changes to this policy by email.

18.    Our details

18.1  This website is owned and operated by Mortgage Advice Hub Ltd.

18.2  We are registered in England and Wales under registration number 10945864, and our registered office is at 22 Ruby Lane, Sheffield, S20 5FJ.

18.3  Our principal place of business is at Unit H1 Staniforth Works, Main Street, Sheffield, S12 4LB.

18.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website; or

(d)    by email, using the email address published on our website.

19.    Data protection registration

19.1  We are registered as a data controller with the UK Information Commissioner's Office.

19.2  Our data protection registration number is ZA177792.

20.    Representative within the European Union

21.    Data protection officer

21.1  Our data protection officer can be contacted on the number published on our website.