Butler Mortgages Ltd Privacy Notice
This privacy notice provides information on how we and any of our subsidiaries and any 3rd party providers collect, use, secure, transfer and share your information. Butler Mortgages are a mortgage and insurance intermediary firm and we will collect information directly from you. It should be noted that, as part of the Financial Conduct Authority’s (FCA’s) regulatory process, we are Appointed Representatives of Mortgage Intelligence and we are required to enter your details onto their systems. Details of their privacy notice can be found at www.experiencemi.co.uk.
Butler Mortgages has it’s office at: 12 Maristow Street, Westbury, Wiltshire. BA13 3DN.
Types of Information Collected
Butler Mortgages will typically collect but are not limited to: First name, middle name, surname, previous names, date of birth, present address, previous addresses, landlord details, nationality, national insurance number, nationality, gender, how many dependants, dependants names, dependants dates of birth, photographic identification, documents to prove your address (and any previous addresses), bank statements, credit card statements, mortgage statements, proof of the source of your deposit funds, payslips, self employed accounts, employers name, address and phone munber, details of any criminal convictions, personal loan details, personal debt details, personal expenditure, existing mortgage details, existing insurance details, email address, phone numbers, new property details, solicitor details, estate agent details, new mortgage details, new insurance details, doctors details, marital status, salary, accountants details, previous employers details, details regarding your health, ethnicity, credit card details, bank details.
Methods of Collection
In conducting our business we will collect information relevant to the provision of mortgage and insurance intermediary advice from: Yourself, your next of kin, your spouse/partner/family member(s), business associates, employers. “Trusted sources” such as Government/land/police registers, credit/default agencies, financial institutions (such as banks, building Societies, loan agencies, credit card companies), insurance companies, law firms, doctors and through consent to third parties disclosing information about you to us that they have collected.
Such information will generally be collected by us via the use of any of our standard forms, over the internet, via email or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers. In addition you may also choose to submit information directly to us via several methods including: In response to marketing or other communications, through social media, by signing up for a product or service, through participation in an offer or promotion or in connection with an actual or potential business or employment relationship with us.
You may also agree to third parties disclosing information about you to us that those third parties have collected.
We and our service providers and partners collect certain information by using automated means such as cookies and web beacons when you interact with our advertisements, mobile applications or visit our web site (or other digital assets). The information we collect in this manner may include IP address, browser type, operating system, referring URL’s, information on actions taken and interaction with our digital assets. We may use third party web analytics on our web site and mobile apps. The analytics providers that administer these services use technologies such as cookies and web beacons to help analyse how visitors use or web site and apps.
“Your Rights and Choices” section of this privacy notice specifies your ability to limit the usage of the information collected.
Purposes of Collection
Generally we will collect, use and hold your information for the purposes of: Undertaking our regulatory responsibility for assessing the suitability of advice, dealing with lenders and providers to assist in providing a product or service, providing relevant information on mortgage and insurance products and related services that may be of interest, processing payments/transactions (including accounting, authorisation, clearing, chargebacks, auditing, billing, reconciliation, collection, complaints, enquiries, credit checks, and related dispute resolution activities), Carrying out electronic checks, including checks of your identity, using data from third parties, protecting against and preventing fraud/money laundering/tax evasion/claims/other liabilities, managing risk exposure, agent/franchise quality, integrity, compliance (and security of business process), Operating monitoring evaluating and improving our products (including our website and mobile applications), Developing new products and services, managing communications (assessing effectiveness and optimising advertising), Enforcing our “terms of use” (or other legal rights as may be required by applicable laws and regulations or requested by any judicial process or government agency having or claiming jurisdiction over us or our affiliates), complying with industry standards and Butler Mortgages policies.
Lawful Basis of Processing
Butler Mortgages processes your information under the following basis: Performance of a contract (where you enter into a contract with us and we need to process your information as a part of this contract, legitimate interests (some information is processed by us as part of our legitimate interests (which will include fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitering , web analytics, cloud storage, acquisitions, updating customer details, and other core products and services provided by the date controller), public interest (some information is processed in accordance with public interest, consent (where we process information under consent we will seek your clear and unambiguous consent prior to processing your data.
Information We Share
We do not sell or otherwise disclose personal information we collect about you except as described in this privacy notice or as indicated via a consent process at the time the data is collected. We share the information we collect with (but not limited to): vetted affiliates (financial institutions, insurance companies, mortgage companies to provide the required services), vetted affiliates for the purpose of conducting consumer research, formally contracted service providers to perform services on our behalf (hosting data centres, helpdesks, call centres and we contractually require these service providers to safeguard the privacy and security of the personal information they process on our behalf and authorise them to disclose the information only as necessary to perform services on our behalf or to comply with legal requirements), law firms, auditors, our network principle (Mortgage Intelligence), credit agencies, land registry office, Her Majesty’s Revenue and Customs, Financial Conduct Authority and other relevant regulatory bodies. Additionally we may share information about you if required legally to prevent harm or financial/reputation loss or for investigation of suspected or actual fraudulent or illegal activities.
Our website features can be accessed where we partner with other entities that are not affiliated with us. These include social networking, geo location tools etc are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies if you use the relevant features.
We reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets with reasonable requirement for the acquirer to protect/use your information consistent with our global privacy policy. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.
How Long Do We Keep Information For?
We will keep information for a reasonable amount of time in order to perform the purposes previously detailed in this notice. We only keep your information for as long as necessary. We generally keep information for 7 years after our last contact with you. However, we reserve the right to keep information for longer if we feel that this is in the legitimate interests of Butler Mortgages.
International Data Transfers
We and/or associated third parties may transfer the personal information collected about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you originally provided the information. When we transfer your information to other countries we will protect that information as described in this privacy notice or as otherwise disclosed to you at the time the data is collected (eg via a program specific privacy notice).
Profiling
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential unauthorised activities, we may engage in profiling activities via direct use or anonymisation of sensitive personal information.
Direct Profiling
Direct profiling is engaged for fair and lawful purposes to provide us with the ability to enforce Butler Mortgages “terms of use”, legal reporting as may be required by applicable laws, regulations, policies/ standards or as requested by any judicial process or government agency having or claiming jurisdiction over us or our affiliates including (but not limited to): background checks for customers, financial viability analysis, business partner/ customer portfolio position/ performance/ risk positions, anti money laundering, tax reporting and credit defaulting/exposure.
Indirect Profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information including (but not limited to) the following: compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purposes of advising our partners /affiliates and servicing institustions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud and other insights that may be extracted from this data, compiling and communicating promotional and marketing information about other products and services that we have affiliations with and that we feel may be of interest to you, conducting market research and facilitating our internal business operations including the fulfilment of any legal requirements.
Your Rights and Choices
Your rights regarding the sensitive and personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information and how we communicate with you.
Access and Correction
You may have the right to: obtain confirmation that we hold personal information about you, request access to and receive information about the personal information we maintain about you and receive copies of the personal information we maintain about you. The right to access personal information may be limited in some circumstances by local law requirements. The exercise these rights please see the following details regarding the requirements.
Update and Correct Inaccuracies in Your Personal Information
If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information that you feel is incorrect or inaccurate. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint. We will provide you with access to information we hold about you.
Object to The Processing of Your Personal Information.
If you would like to object to any processing of your information by us you can contact us outlining what processing of information you would like to object to.
Have the Information Blocked, Anonymised or Deleted
If you would like us to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised. To update your preferences, ask us to remove information from our mailing lists or submit a request to access, update, correct or delete your personal information please contact us as specified in the “how to contact us” section which follows.
Opting Out of Processing
You can opt out of collection of personal information by automated means eg—when visiting our web site, or visiting third party websites and interacting with our adverts, by using the cookie control tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However, without cookies you may not be able to use all of the website features and online services. Butler Mortgages operates a cookie policy. Some of our service providers and partners may collect information about your on line activities over time and across third party web sites to customise and target our adverts. You can at any time tell us not to send you marketing communications by : email to mortgages@butlermortgages.co.uk, unsubscribing via any unsubscribe link which may be within any marketing emails you receive from us or any of our affiliates or contacting us as detailed later in this notice.
Withdrawal of Consent
If we obtain information by consent you have the right to withdraw any consent you previously provided to us. If we process your information under legitimate interest you can object at any time on legitimate grounds to the processing of your personal information. Butler Mortgages will apply these preferences in the future. Doing so will mean that you cannot take advantage of certain Butler Mortgages products, services and promotions. The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.
How to Contact Us—Complaints and Feedback
If you: believe we fall short of your expectations in processing your personal information, wish to make a complaint about a breach of your personal information, or have a concern about our privacy policies or would like to access or update your information or preferences you provided to us then please either email us at mortgages@butlermortgages.co.uk or write to us at Butler Mortgages, 12 Maristow Street, Westbury, Wiltshire. BA13 3DN. To assist us in responding to your request please give full details of the issue. We attempt to review and correspond to all complaints within a reasonable time scale. If we cannot, for lawful reasons, complete your request we will explain this to you to the extent that the law will allow.
How we protect Personal Information
The security of your personal information is very important and we are committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. We use SSL encryption on our web site from which we transfer certain personal information. We store personal information only for as long as it is necessary for the fulfilment of the purpose for which the information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it. Review and Update This privacy notice may be updated from time to time and you should review it on a regular basis
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