Bristol Mortgages Online Cookie & Privacy Policy
Introduction
This Privacy Policy outlines Bristol Mortgages Online practices with respect to information collected from users who access our website at www.bristolmortgagesonline.com ("Site"), or otherwise share personal information with us (collectively: "Users").
Grounds for data collection
Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.
When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.
We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.
What information we collect?
We collect two types of data and information from Users.
The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information Personal Information
which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
- Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
How do we receive information about you?
We receive your Personal Information from various sources:
- When you voluntarily provide us your personal details in order to register on our Site;
- When you use or access our Site in connection with your use of our services;
- From third party providers, services and public registers (for example, traffic analytics vendors).
What information we collect?
We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.
We may use the information for the following:
- Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
- To communicate with you and to keep you informed of our latest updates and services;
- To serve you advertisements when you use our Site (see more under "Advertisements");
- To market our websites and products (see more under "Marketing");
- Conducting statistical and analytical purposes, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:
- Hosting and operating our Site;
- Providing you with our services, including providing a personalized display of our Site;
- Storing and processing such information on our behalf;
- Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
- Providing you with marketing offers and promotional materials related to our Site and services;
- Performing research, technical diagnostics or analytics;
User Rights
You may request to:
- Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
- Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your personal information that is in our control.
- Request erasure of your personal information.
- Object to the processing of personal information by us.
- Request to restrict processing of your personal information by us.
- Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:
Caz Blake-Symes
Group Marketing and Operations Manager
Retention
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. 'session cookies'
which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. 'third party cookies'
which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use
and the Google Privacy Policy.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.
This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy, please refer further down this page to more details to our Privacy Policy.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Advertisements
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
Marketing
We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Minors
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@swmortgages.com
Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
Customer Privacy Notice
Worldwide Investment Corporation Limited, trading as Bristol Mortgages Online and Exeter Mortgages Online, is an
Appointed Representative of Owen & Associates (Our Network)
Why are we asking you to read this document?
During the course of dealing with us we will ask you to provide us with detailed personal information relating to your
existing circumstances, your financial situation and, in some cases, your health and family health history
(Your Information). We would like to explain to you what we will need to do with Your Information, and the various rights
you have in relation to Your Information.
What do we mean by ‘Your Information’?
Your Information means any information describing or relating to you. Your Information may identify you directly,
for example, your name, address, date of birth and National Insurance number. Your Information may also identify
you indirectly, for example, your employment situation, your physical and mental health history or any other
information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your mortgage and/or insurance requirements, your
information may include:
• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that
are necessary to verify your identity
• Employment and remuneration information (including salary/bonus schemes, overtime/sick pay, other benefits)
and employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income
and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below
specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing mortgage and/or insurance products and the terms and conditions relating to these.
The basis upon which our firm will deal with Your Information
When we speak with you about your mortgage and/or insurance requirements, we do so on the basis that a
contract for the supply of services
is in place between us. In order to perform that contract, and to arrange the products you
require, we have the right to use Your Information for the purposes we set out below.
Alternatively, either in the course of initial discussions with you or
when the contract between us has come to an end
for whatever reason, we have the right to use Your Information provided it is in our legitimate business interest to do so and
your rights are not affected.
For example, we may need to respond to requests from mortgage lenders, insurance providers and our Network relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Information to enable us to meet any contractual responsibilities we may owe our Network, or for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance or other regulatory obligation
to which we are subject.
The basis upon which we will process certain parts of Your Information
Where you ask us to assist you with your insurance needs, in particular life insurance and insurance that may assist
you in the event of an accident or illness, we will ask you for information about your ethnic origin, your health and
your medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of
insurance providers in relation to insurance products that may meet your needs and to provide you with advice
regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently our
Network) will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic
or current criminal convictions or offences (Criminal Disclosures). This is relevant to insurance related activities such
as underwriting claims and fraud management.
Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as
set out in this Customer Privacy Notice.
When we process your Special Data and any Criminal Disclosures, we do so on the basis that it is in the substantial
public interest to be able to provide vital insurance products, and as permitted by UK data protection related laws and
regulations from time to time. Information on Special Category Data and Criminal Disclosures must be capable of being
exchanged freely between insurance intermediaries such as our firm and insurance providers, to enable customers to
secure the important insurance protection that their needs require.
How do we collect Your Information?
We will collect and record Your Information from a variety of sources, but mainly directly from you. You will usually
provide information during the course of our initial meetings or conversations with you to establish your
circumstances, needs and preferences in relation to mortgages and insurance. You will provide information to us
verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer,
and searches of information in the public domain such as the electoral roll. If we use technology solutions to assist in
the collection of Your Information, such as software that is able to verify your identity on-line or to access your credit
status and/or bank account entries, then you will be required to provide your consent for us or our nominated
processor to access your information in this manner. Details of how such software operates will be provided to you
prior to the activation of the service.
What happens to Your Information when it is disclosed to us?
In the course of handling Your Information we shall:
• Record and store Your Information in our paper files, mobile devices and on our computer systems (websites,
email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors
engaged by our Firm, as necessary, to provide our service to you and to perform any administration tasks
associated with or incidental to that service
• Submit Your Information to mortgage lenders and/or insurance product providers, both in paper form and online,
via mortgage lender/insurance provider systems, in order to progress any enquiry or application made on
your behalf and to deal with any additional questions or administrative issues that mortgage lenders and
insurance providers may raise
• Input Your Information, along with full details of the mortgage and/or insurance discussed with you or which you
have taken out, to the computer systems of our Network
• Use Your Information for the purposes of responding to any queries you may have in relation to any mortgage
product or insurance policy you may take out, or to inform you of any developments in relation to those products
and/or polices of which we might become aware.
Sharing and transferring Your Information
From time to time Your Information will be shared with or transferred to:
• Our Network
• Mortgage lenders and insurance providers
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to
support your needs as identified; such third parties will include but may not be limited to, product specialists
(including those within our Network and other Appointed Representatives of the Network), estate agents,
providers of legal services such as conveyancing, surveyors and valuers (in each case where we believe this
to be required due to your particular circumstances).
In each case for the purposes set out in this customer privacy notice, i.e. to progress your mortgage and/or insurance
enquiry and to provide you with our professional services.
Please note that this sharing of Your Information does not entitle such third parties to send you marketing or
promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you,
and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Information being transferred
outside of the European Economic Area.
The basis upon which our Network will deal with Your Information, Your Special Data and Criminal
Disclosures
Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for
the quality of the advice that we provide to you in relation to your mortgage and/or insurance products, where
those products are regulated by the FCA. In the course of doing so, our Network will also process Your Information
generally, including Your Special Data and Criminal Disclosures.
In the course of handling Your Information and Your Special Data/Criminal Disclosures our Network will:
• Record and store Your Information and Your Special Data/Criminal Disclosures on Network systems run on
secure servers. Your Information and Your Special Data/Criminal Disclosures will be accessed by authorised
employees and consultants within, or engaged by the Network, as necessary, for the purposes of supervision,
training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or
regulatory obligation the Network may have
• Use, and where appropriate transmit, Your Information and Your Special Data/Criminal Disclosures to respond
to any request from the FCA, the Financial Ombudsman Service, HMRC, the Office of the Information
Commissioner or any other regulatory, law enforcement or governmental body
• Need to access and process Your Information and Your Special Data/Criminal Disclosures to deal with enquiries
received from mortgage lenders and insurance providers that relate to the service this Firm has provided to
you, including the payment of any commission or fees to us that may be linked to the product you have taken
out.
Your Information and Your Special Data/Criminal Disclosures will be retained by our Network either electronically or
in paper format for a minimum of six years and possibly for a longer period where this is required to enable the
Network to fulfil its legal and regulatory obligations.
Please note that the above information is a summary of the Network Privacy Policy for customers. If you wish to
understand in more detail what the Network will do with Your Information and Special Data/Criminal Disclosures
then please visit the Network Privacy Policy for customers located at http://owen.group-office.co.uk
Security and retention of Your Information
Your privacy is important to us and we will keep Your Information secure in accordance with our legal
responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or
maliciously by a third party, accidentally lost, destroyed or damaged.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us,
such as not sending confidential information over unprotected email, ensuring email attachments are password
protected or encrypted and only using secure methods of postage when original documentation is sent to us.
Your Information will be retained by us either electronically or in paper format for a minimum of six years, or if
longer than six years, the duration of this Firm’s relationship with you.
Your rights in relation to Your Information
THE RIGHTS MARKED WITH AN * ARE EFFECTIVE FROM 25 MAY 2018
You can:
• Request copies of Your Information that is under our control
• Ask us to further explain how we use Your Information
• Ask us to correct or delete*, or require us to restrict or stop using Your Information (details as to the extent
to which we can do this will be provided at the time of any such request)
• Ask us to send an electronic copy of Your Information to another organisation should you wish*
• Change the basis of any consent you may have provided to enable us to market to you in the future
(including withdrawing any consent in its entirety).
How to make contact with our firm in relation to the use of Your Information
If you have any questions or comments about this document, or wish to make contact in order to exercise any of
your rights set out within it please contact:
Bristol Mortgages Online or Exeter Mortgages Online
Henleaze House,
13 Harbury Road
Henleaze
BS9 4PN
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have
requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on becoming aware of any unauthorised disclosure of Your
Information, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Information or Your Special Data/Criminal
Disclosures you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted
through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at info@swmortgages.com
Bristol Mortgages Online
Last Modified 30/07/2019