Independent Mortgage Solutions (Hampshire) Ltd
Unit 2 Newington Court
Emsworth Road
Lymington
Hampshire
SO41 9AW
Registered in England 05813951.
Independent Mortgage Solutions (Hampshire) Ltd is authorised and regulated by the Financial Conduct Authority.
Independent Mortgage Solutions (Hampshire) Ltd is known in this document as ‘Independent Mortgage Solutions’, ‘we’ and ‘us’.
As the controller of your data, Independent Mortgage Solutions complies with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how Independent Mortgage Solutions processes your personal data.
The personal data we collect about you
Personal data collected, used, stored and transferred by us may include:
- Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
- Contact Data including home address, email address and telephone numbers
- Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
- Special Category Data specifically medical history
- Transaction Data including payments made for products and services you have purchased from us
- Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Independent Mortgage Solutions website
- Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
- Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences
How do we use your personal data?
We use your personal data in the following circumstances and relying on the following lawful basis for processing:
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
| To initially engage with you to discuss your requirements | • Identity
• Contact |
Consent |
| To process and deliver your application for a mortgage or protection product | • Identity
• Contact • Financial • Special Category • Transaction • Marketing & Comms |
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
• Notifying you about changes to our terms or privacy policy • Customer reviews/surveys • Re-engagement when existing products near expiry/review protection needs |
• Identity
• Contact • Profile & Usage • Marketing & Comms |
Performance of a contract with you
To comply with a legal obligation Necessary for our legitimate interests (to re-engage with you to review your existing mortgage/protection needs, and to maintain and improve customer service standards |
| To respond to case enquiries and input to & defend against complaints | • Identity
• Contact • Profile & Usage • Transaction • Marketing & Comms |
To comply with a legal obligation
Necessary for our legitimate interests (to ensure that complaints can be responded to accurately) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | • Identity
• Contact • Technical |
To comply with a legal obligation
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | • Identity
• Contact • Profile & Usage • Marketing & Comms • Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | • Technical
• Profile & Usage |
Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our marketing strategy |
Change of purpose
We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 23rd May 2018. Historic versions can be obtained by contacting us.
Marketing communications
You will also have the choice to opt-in to receiving other related marketing information and related products and services.
You can opt-out of receiving these types of communications at any time by contacting enquiries@imortgagesolutions.co.uk or by clicking on the relevant link in email communications you receive from us.
However please note that your personal information will not be passed to any third-party organisation for marketing purposes.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those Independent Mortgage Solutions staff, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Website Third-party links
Independent Mortgage Solution’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Who we disclose personal data to
Your personal data may be shared with third parties for the following purposes:
| Type of Recipient | Reason |
| Within Independent Mortgage Solutions | Depending on your requirements, it may be necessary to share your personal data with specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients. |
| Lenders and protection product suppliers | To source and submit applications in order to conclude the contract for the mortgage/protection application and the ongoing servicing of these contracts. |
| External Suppliers | Specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Independent Mortgage Solutions. |
| Estate Agents/new home builders | We may share information about the progress of your application with estate agents and home builders with whom you are interacting. Please note that this is only if you have provided prior consent. |
| Regulators | Sharing information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities. |
These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Independent Mortgage Solutions instructions.
How long is your personal data retained?
Your personal data will not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
You have the right to request deletion of your personal data by writing to us at our office address. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above, within 30 days.
Your legal rights regarding your personal data
After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Questions
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact Simon Upton, by emailing enquiries@imortgagesolutions.co.uk or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
What if I am still not satisfied?
If you are not satisfied with how Independent Mortgage Solutions has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.