PRIVACY POLICY

BACKGROUND:

Vesta Mortgage Services Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, vestamortgage.services (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the UK GDPR and the Data Protection Act 2018; and

“We/Us/Our” means Vesta Mortgage Services Limited, a limited company registered in England and Wales under company number 11607725, whose registered office is at KB House, Scott Drive, Altrincham, United Kingdom, WA15 8AB.

2. Information About Us

2.1 Our Site is owned and operated by Vesta Mortgage Services Limited, a limited company registered in England and Wales under company number 11607725, whose registered office is at KB House, Scott Drive, Altrincham, United Kingdom, WA15 8AB.

2.2 Mortgage and protection broking services provided by Us are generally exempt from VAT and We are not currently VAT-registered.

2.3 We are not required to appoint a formal Data Protection Officer. Any questions or requests relating to this Privacy Policy or Our use of your personal data should be directed to Us using the contact details in section 14.

2.4 Vesta Mortgage Services Limited is an Appointed Representative of The Right Mortgage Limited, which is authorised and regulated by the Financial Conduct Authority (FCA). Our FCA firm reference number is 825435. You can check this on the Financial Services Register at register.fca.org.uk.

2.5 We are established, and have traded, since 2018.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites (including those of mortgage lenders, insurers, and other product providers). Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the UK GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6, but if you would like Us to delete it sooner, please contact Us using the details in section 14, subject to Our legal and regulatory record-keeping obligations as an FCA-regulated firm);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision-making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (ICO).

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site and Our services, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):

5.1 name;

5.2 date of birth;

5.3 contact information such as postal address, email address, and telephone number(s);

5.4 employment and income information;

5.5 financial information relevant to a mortgage or protection application, such as bank details, credit history, existing borrowing, assets, and outgoings;

5.6 identification documents (e.g. passport or driving licence) and information used to verify your identity and carry out anti-money-laundering and fraud checks;

5.7 property details relevant to your mortgage application;

5.8 where you apply for protection products (such as life insurance, critical illness cover, or income protection), health and medical information that you or your product provider gives Us as part of that application – this is “special category data” under the UK GDPR, and We only collect and use it with your explicit consent or where necessary to set up and administer your policy;

5.9 demographic information such as postcode, preferences, and interests;

5.10 IP address;

5.11 web browser type and version;

5.12 operating system;

5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK GDPR and the Data Protection Act 2018 at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails, or by consenting to Us processing health information as part of a protection application), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 providing and managing your Account (where applicable);

6.2.2 providing and managing your access to Our Site;

6.2.3 personalising and tailoring your experience on Our Site;

6.2.4 assessing your circumstances and providing mortgage and/or protection advice, and submitting and progressing applications with lenders, insurers, and other product providers on your behalf (We require your personal data in order to enter into a contract with you and to provide these services);

6.2.5 carrying out identity verification, anti-money-laundering, and fraud prevention checks;

6.2.6 meeting Our record-keeping and other obligations as a firm regulated by the Financial Conduct Authority;

6.2.7 replying to enquiries and emails from you;

6.2.8 supplying you with emails or other communications that you have opted into (you may unsubscribe or opt out at any time by contacting Us using the details in section 14);

6.2.9 market research;

6.2.10 analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, or post with information, news, and offers on Our mortgage and protection services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 2018, the UK GDPR, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it, subject to Our legal and regulatory obligations as set out in section 6.5.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. As a firm regulated by the FCA, We are required to retain records relating to mortgage and protection advice and sales for a minimum period set by FCA rules (currently a minimum of 6 years from the date the advice was given, or longer where required by law or by Our regulator). Other personal data, such as website usage data, is retained only for as long as is reasonably necessary for the purposes described in this Policy, after which it is securely deleted or anonymised.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it, and/or as required to meet Our regulatory obligations.

7.2 Your data will only be stored in the United Kingdom.

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4 Steps We take to secure and protect your data include maintaining secure IT systems, restricting access to personal data to staff who need it to carry out their role, and using secure methods to transfer sensitive information such as financial and health data to lenders, insurers, and other product providers.

8. Do We Share Your Data?

8.1 In order to provide Our mortgage and protection advice services, We need to share certain data with third parties. We will not share any other data with third parties for any other purposes without your knowledge, except where set out below.

8.2 We may share your data with the following third parties for the purposes indicated:

mortgage lenders and other product providers, in order to submit and progress your mortgage application;

insurance and protection providers, in order to submit and progress applications for life insurance, critical illness cover, income protection, and other protection products;

The Right Mortgage Limited, as the network of which We are an Appointed Representative, for compliance, oversight, and record-keeping purposes;

credit reference and fraud prevention agencies, in order to verify your identity and assess your application;

professional advisers such as solicitors or surveyors, where relevant to your application, and only with your knowledge;

Our regulator, the Financial Conduct Authority, and other governmental or law enforcement bodies, where We are legally required to do so.

8.3 Where any of your data is shared with a third party as described above, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any personally identifying data, or any data that can be combined with other data and used to identify you.

8.5 We do not currently transfer your personal data outside of the United Kingdom. If this changes, We will update this Privacy Policy and take all reasonable steps to ensure that your data continues to be treated as safely and securely as it would be within the UK.

8.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental or regulatory authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller, subject to Our legal and regulatory record-keeping obligations.

10. How Can You Control Your Data?

10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes, including the ability to opt out of receiving emails from Us, which you may do by unsubscribing using the links provided in Our emails or by contacting Us using the details in section 14.

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: the Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site, and to receive mortgage or protection advice from Us, you will be required to submit certain data, as this is necessary for Us to assess your circumstances and provide Our services.

11.2 You may restrict Our use of Cookies. For more information, see section 13.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the UK GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details in section 14.

13. Our Use of Cookies

13.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so.

13.5 The following first party Cookies may be placed on your computer or device: [insert cookie table – Name of Cookie / Purpose / Strictly Necessary (yes/no), once your website Cookies are finalised].

13.6 Our Site uses analytics services provided by [insert name of analytics service provider, e.g. Google Analytics]. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and Our services. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

13.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

13.8 The analytics service(s) used by Our Site use(s) the following Cookies: [insert cookie table – Name of Cookie / First or Third Party / Provider / Purpose, once finalised].

13.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently, including, but not limited to, login and personalisation settings.

13.11 It is recommended that you keep your internet browser and operating system up to date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [insert email address], by telephone on [insert telephone number], or by post at KB House, Scott Drive, Altrincham, United Kingdom, WA15 8AB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.