This Privacy Policy was last updated in May 2018 and explains how we use the personal information that Competitive Mortgages And Financial Services Ltd (as defined below) collects or generates information in relation to its business activities and Marketing Preference Centre at www.mortgagesandfs.com(the “Preference Centre”).
Competitive Mortgages and Financial Services Ltd, “we or “us” means of 27 Church Road, London, W7 3BD and Company Number 04781360.
We collect and use certain personal data via the Preference Centre or direct contacts and we are responsible for ensuring that we use that personal data in compliance with data protection laws. This Privacy Policy governs the handling of personal data by us in the course of performing our duties.
2. THE TYPES OF PERSONAL DATA WE COLLECT
When you visit the Preference Centre and in the course of our service we may collect personal data whe
you provide it to us, we may collect and process the following personal data about you:
Information that you provide to Competitive Mortgages and Financial Services Ltd. Such information
may include details of your marketing preferences (i.e. the marketing materials that you would like to
receive from Competitive Mortgages and Financial Services Ltd.
Information that we collect or generate about you. When you submit information via the Preference
Centre, we may use this information to help build a better picture of the topics and materials that
interest you or may interest you, and the ways in which you would like to receive them.
If you contact us we may keep a record of that correspondence.
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
Contact information
Identity information
Employment details, Financial or health and medical information
3. HOW WE USE YOUR INFORMATION
Your personal data may be stored and processed by us in the following ways and for the following purposes:
to understand your marketing preferences and keep them up to date;
to communicate with you in order to provide you with information about Competitive Mortgages and
Financial Services Ltd and the products and services offered that might be of interest to you;
for the administration and maintenance of databases and storing your marketing preferences.
However, in using personal data we make sure that the usage complies with the law. The use of your personal data as described in this Privacy Policy is permitted because:
it is necessary for our legitimate business interests, because it allows us to:
o keep a record of what our contacts are interested in hearing about and how they would like to hear about it;
o ensure that we only send our contacts marketing materials that they would like to receive and that may be of interest to them; and conduct more effective business development and marketing activities.
You may have consented for us to use your personal data to send you certain marketing materials
when you submit your marketing preferences to us via the Preference Centre.
Where you have consented to be contacted for such purposes, to provide you with information or
services that you request from us or which we feel may interest you.
To carry out our obligations arising from any contracts entered into between you and us.
To allow you to participate in any interactive features which may offer on our site from time to time,
when you choose to do so.
To notify you about changes to our service.
We will take steps to ensure that the personal data is accessed only by employees of Competitive Mortgages
and Financial Services Ltd that have a need to do so for the purposes described in this Privacy Policy.
Below we describe how we use your personal data, the lawful basis for processing it and if applicable, third
party activity
Stage and reason of
application/processing
What Personal Data
is retained
How long do
we hold it?
Why do we retain
it?
You have made a basic enquiry
but insufficient to do a lender’s
credit search
Personal, contact
information and basic
plan application data
6 months
from the end
of the
enquiry or 3
months if you
request it
To contact you and
attempt to help you
arrange finance
You have made an enquiry
sufficient to do a lender’s credit
search but not yet arranged
finance for you.
Research for investments or
quotes for insurance products,
such as protection and general
insurance
Personal, contact
information full plan
application data
12 months
from the end
of the
enquiry
To contact you and
attempt to help you
arrange finance and
to help resolve
misunderstanding
and complaints that
may arise
We have provided mortgage or
investment or insurance advice
Personal, contact
information full plan
application data and
plan information and
records of mortgage,
investment or
insurance advice
provided
3 years from
the end of
the enquiry
To meet our
regulatory and legal
obligations to keep
accurate records
We have successfully arranged
finance, investment or general
insurance for you
Personal, contact
information full plan
application data, plan
information and
records of mortgage,
investment and
insurance advice
provided
6 years from
the end of
the enquiry
To provide you
further advice or to
investigate and
resolve
complaints/defend
legal claims and
If applicable, completing due
diligence checks on behalf of a
provider or reporting suspicious
activity
Evidence of proof of
identity,
income and address
(where we
have arranged
finance). Records
of suspicious activity
Investigations and
external
reports to fraud
prevention agencies
6 years from
end of
enquiry or
from date of
suspicious
activity
report
To comply with our
legal obligations
obligations to
prevent
financial crime.
Investigating and
responding to
complaints.
Records of complaint
investigation notes,
supporting
evidence including
loan
application data,
copies of
documents and
records of
communications
6 years after
end of
contractual
loan term.
To comply with our
regulatory
obligations and
to able to identify
and
respond to
duplicated
claims or
complaints made
against us
Sending
promotional
information and
updates regarding
our service and
products
Personal contact
details.
While we
have your
consent and
you are
happy to
continue to
receive
updates.
To keep you
informed of
our services and
changes
to products that
may be of
interest to you
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We may share your personal data within Competitive Mortgages and Financial Services Ltd for the purposes described above.
We may also share your personal data outside of Competitive Mortgages and Financial Services Ltd as
further described below:
with our business partners whose products and services you have indicated that you would be
interested in hearing about;
with third party service providers for the purposes of providing services to us that enable or support
our fulfilment of the purposes described in this Privacy Policy. These third parties will be subject to
appropriate data protection obligations;
to the extent required by law, for example if we are under a duty to disclose your personal data in
order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
if we sell our business or assets, in which case we may need to disclose your personal data to the
prospective buyer for due diligence purposes; and
if we are acquired by a third party, in which case the personal data held by us about you will be
disclosed to the third party buyer.
5. HOW LONG WE KEEP YOUR PERSONAL DATA
How long we will hold your personal data for will vary and will be determined by the following criteria:
the purpose for which we are using it (as further described in this policy) – we will need to keep the
data for as long as is necessary for that purpose; and
legal obligations – laws or regulation may set a minimum period for which we have to keep your
personal data
6. YOUR RIGHTS
In all the above cases in which we collect, use or store your personal data, you may have the following rights
and, in most cases, you can exercise them free of charge. These rights include:
The right to obtain information regarding the processing of your personal data and access to the
personal data which we hold about you;
The right to withdraw your consent to the processing of your personal data at any time. Please note,
however, that we may still be entitled to process your personal data if we have another legitimate
reason for doing so;
In some circumstances, the right to receive some personal data in a structured, commonly used and
machine-readable format and/or request that we transmit those data to a third party where this is
technically feasible. Please note that this right only applies to personal data which you have provided
directly to Competitive Mortgages and Financial Services Ltd;
The right to request that we rectify your personal data if it is inaccurate or incomplete;
The right to request that we erase your personal data in certain circumstances. Please note that
there may be circumstances where you ask us to erase your personal data but we are legally entitled
to retain it;
The right to object to, or request that we restrict, our processing of your personal data in certain
circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our
processing of your personal data but we are legally entitled to refuse that request; and the right to
lodge a complaint with the relevant data protection regulator if you think that any of your rights have
been infringed by us.
To exercise your right, we will not ask for any fees, unless it is felt to be repetitive or excessive. If
applicable, you will be advised of how much it will be before applying the fees.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example;
o where you think the information is inaccurate and we need to verify it;
o where our use of your personal data is not lawful but you do not want us to erase it;
o where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims;
To object to use of personal data
You can object to any use of your personal data which we have justified on the basis of our
legitimate interest, if you believe your fundamental rights and freedoms to data protection
outweigh our legitimate interest in using the information. If you raise an objection, we may continue
to use the personal data if we can demonstrate that we have compelling legitimate interests to use
the information.
To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-
readable format, or you can ask to have it transferred directly to another data controller (e.g. another
company).
You may only exercise this right where we use your personal data in order to perform a contract with
you, or where we asked for your consent to use your personal data. This right does not apply to any
personal data which we hold or process by non- automated means.
You can exercise your rights by contacting us using the details provided at clause 10 below.
7. OTHER WEBSITES
If you follow a link to another website (including a website operated by Competitive Mortgages and Financial
Services Ltd), different privacy policies may apply. You should read these policies before you submit any
personal data to these websites and agree that use of your personal data by those websites will be subject
to those privacy policies
9. CHANGES TO THIS PRIVACY POLICY
Any changes we make to our Privacy Policy in the future will be posted on this page and where appropriate,
notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
10. QUESTIONS AND CONCERNS
If you have any questions or concerns about our handling of your personal data, or about this Privacy Policy,
please contact us using the following contact information:
Address: Competitive Mortgages and Financial Services Ltd. 27 Church Road, London W7 3BD
Email Address: info@mortgagesandfs.com or martmohamed@cmandfs.co.uk
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied
with the response you receive, you may escalate concerns to the applicable data protection regulator in your
jurisdiction. Upon request, we will provide you with the contact information for that regulator.
