Privacy Policy

Introduction

It’s important to know who’s handling your data and what they are doing with it.

In this document, we aim to set out who we are, what data we collect and how we process and share your data through your use of our website, including when you create an account, communicate with us, sign up to our newsletter, use our brokerage or mortgage monitoring services or take part in promotion or product feedback.

Your personal and sensitive personal data - what is it?

Personal Data relates to a living individual who can be identified from that data; Sensitive Personal Data covers specific information such as health details, origins and opinions. Identification can be by the information alone or in conjunction with any other information in the Data Controller’s possession or likely to come into such possession. The processing of Personal Data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).

If you are the person who has created the online account with us, then you are deemed to be the Lead Applicant.

Where a mortgage application consists of further applicants (up to a maximum of 3), other than the Lead Applicant, and, you are one of those applicants, then you are deemed to be an Additional Applicant.

Who are we?

Holiday Cottage Mortgages Limited (“we”, “us”) is the data controller responsible for your personal data and this website. You can get in touch with us if you have any questions about this policy (or any other policy) including any requests to exercise your legal rights.

What information do we collect

Through our website we collect the following information for all applicants:

  • Name, address and contact details;
  • Employment details;
  • Financial information such as banking details, salary, savings, and financial commitments;
  • Any other personally identifiable information necessary for the completion of a mortgage application.
  • In addition to the above, we collect information from you via document uploads and through communications with us, including items such as:
    • Identification and address verification;
    • Payslips and contracts of employment;
    • Self-assessment tax returns and tax year overviews;
    • Bank statements;
    • Credit reports.

We also collect technical information about your computer, including your browser type, your operating system, your device type and your IP address. We collect this information for site optimisation, security and product and service improvements. For more information on this please refer to our Cookie Policy.

We may also collect personal information from you over the telephone for mortgage or insurance purposes and we may record telephone calls for training and monitoring purposes.

If you are the Lead Applicant, then you confirm to us that:

  • you have obtained the permission from each Additional Applicant for you to add them to the online mortgage application and you have sought permission for us to contact them directly (usually by email) to request that they review and agree to our Terms of Use, this Privacy Policy and our Cookie Notice.

If you are an Additional Applicant, then you confirm to us that:

  • you give your permission to the Lead Applicant to supply, handle, review and input your personal data into our systems on your behalf.
  • we may use your personal information as part of the mortgage application process, in accordance with this Privacy Policy and our Terms of Use.
  • where we have questions or queries about your personal information (for example: if we wish to query a transaction on one of your bank statements), that you give permission for such queries to be directed to, or via, the Lead Applicant.

Do we use (or process, in technical jargon) your information

The information we collect about you will be mainly used for the purpose of applying for a holiday let mortgage or any other product or service we offer, such as arranging a solicitor or obtaining holiday let insurance.

In addition to the above, we will also use your information to:

  • Operate and manage the account you hold with us and any mortgage application(s) you consent to us making on your behalf.
  • Manage any insurance application(s) you ask us to make on your behalf.
  • To inform people of our business and its activities, carry out market research, profiling and business and statistical analysis.
  • Test our systems and develop our products (or any other similar purpose).
  • Comply with any legal or regulatory obligation we are obliged to.
  • If you have consented, to contact you by any medium you have agreed to with details of our goods and services which we believe may be of value to you.
  • Support our legitimate interests (or those of a third party) so long as your interests and fundamental rights do not override such.

Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw consent to marketing at any time by contacting us.

Some of the information you provide us with may become ‘Special Category’ personal data when collated as part of your application. As this data is sensitive, we ask you to let us know during the sign up process that you agree this data being processed, as set out here in our Privacy Notice. We wouldn’t be able to provide the service you have asked us to provide without this processing. We will only ever process ‘Special Category’ personal data where this is necessary to provide the service to you.

What is the legal basis for processing your information?

Below is a description of the main methods for which we plan to use your personal data, and which of the legal bases we rely on to do so.

The following are automatically consented to when you agree to this Privacy Policy and we have also identified what our legitimate interests are where appropriate.

 

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo process and deliver your mortgage and/or insurance product(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Special CategoryConsent
Performance of a contract with you
Necessary to comply with a legal obligation

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To monitor your mortgage and let you know when a better deal becomes available (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Consent
Performance of a contract with you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Asking you to leave a review or take a survey
(c) Notifying you when your product is near expiry or when changes occur that would merit our re-engagement
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Consent
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
Consent
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) Necessary to comply with a legal obligation
To keep your referring holiday letting agent informed of your application progress (a) Identity
(b) Application Status
Consent
Necessary for our legitimate interests (to assist your referring holiday letting agent in the preparation and timing of the launch of your holiday let)

 

The following is an optional consent, given during the account creation process:

 

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Consent
Necessary for our legitimate interests (to develop our products/services and grow our business)

Sharing your information

To perform the service you have requested of us, we may share your personal data with the following parties:

  • Any Group company or with our network, Julian Harris Networks, and its associates.
  • Any regulatory/governmental body, ombudsman or law enforcement agency who has jurisdiction.
  • Any electronic identification firm we use for identification and address verification purposes only.
  • A mortgage lender; to allow us to make a mortgage application on your behalf.
  • An insurance company, to allow us to make a insurance application or referral on your behalf.
  • Any third parties that participate in the entire mortgage journey (e.g. solicitors, valuers, conveyancers and mortgage clubs).
  • Any holiday letting agent who referred you to us, sharing only your application status (as per the Application Status screen), to enable that agent to plan for the efficient launch of your holiday let.
  • Credit checking agencies, where required.
  • Suppliers who process your data on our behalf; we will have written contracts in place with such entities which require them to process your data only in accordance with our instructions.
  • Support and analytics services to help with technical issues.
  • Any person or legal entity to whom we sell or transfer (or initiate discussions with to sell or transfer) our business or any part of it or any of our rights or obligations under any agreement we may have with you. If the transfer goes ahead, you agree that the purchaser can use your data in the same way as us.

As noted above, when we share your details with third party lenders as part of providing our service to you, those lenders will become data controllers of any of your personal data in order that they can process any mortgage application you wish to make. Each lender will have its own privacy policy and practices on what data it collects from you and what it does with it, which you should ensure that you read, understand and are happy with.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We don’t allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes as part of providing the service to you, and in accordance with our instructions.

Your rights and your personal data

Unless subject to an exemption under the GDPR, as a consumer, you have the right to be informed about the collection and use of your personal data, and to have a say in how it’s handled. To ensure you understand the details, we have laid them out below.

We will always try to reply to legitimate requests within one month but sometimes, it may take us longer than a month if your request is particularly complex or you have made several requests.

Rest assured that you won’t have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee (for example £50 per additional request) if your request is vexatious, unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We will need to check your security PIN number and memorable question to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

In summary, you have the right to:

  • Request access: to and a copy of your personal data held on our systems, to enable you to see the personal data we hold about you and to check that we’re processing it lawfully.
  • Request correction: of the personal data that we hold about you, if you believe it to be incomplete, inaccurate or out of date.
  • Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we’re required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request the porting or transfer: of your personal data, allowing you to move your personally identifiable data from one Data Controller to another. We’ll provide your personal data in a machine-readable format.
  • Withdraw consent at any time: where we’re relying on consent to process your personal data. However, this won’t 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’ll advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data where there is a dispute in relation to the accuracy, processing or use of your data.
  • Object to processing: of your personal data where we’re relying on a legitimate interest (or those of a third party) and you feel it impacts on your fundamental rights and freedoms.
  • Lodge a complaint: with the Information Commissioners Office (see contact details below).

If you wish to exercise any of the rights set out above, please contact us to be informed about the collection and use of your personally identifiable data.

Holding your personal data

  • All data pertaining to a completed mortgage application will be kept on our systems for 6 years after completion in line with our regulatory requirements.
  • If you have not completed on a mortgage application yet we will keep your data on file as long as you have an account with us. It is your responsibility to ensure the information we hold is up to date.
  • All data relating to any insurance products you take out.
    We may also use your data for internal statistical analysis purposes, although we will anonymise this data.

Amendments and further processing

This Privacy Policy is regularly reviewed to make sure that we continue to serve your privacy interests. We reserve the right to update this privacy policy as we deem necessary. Any changes will be posted on our site and if you have an account with us we will email you directly if we deem it necessary.

If we wish to use your Personal and Sensitive Data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your consent prior to the new processing.

Cybercrime warning

Please be aware that there is a significant risk posed by cyber fraud, specifically affecting emails enclosing bank account details. If you receive an email from Holiday Cottage Mortgages Limited requesting or providing bank details, please contact your Adviser immediately for clarification. All payment requests should be verbally validated.

Contact details

W: www.holidaycottagemortgages.co.uk

E: contact@holidaycottagemortgages.co.uk

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.