Privacy Policy

Introduction

Your privacy is really important, which is why protecting your personal data is our top priority. This Privacy Policy explains what personal data Trussle collects, what we use it for and who we share it with. It also sets out how we look after your personal data, your privacy rights, and how the law protects you.

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy lets you know how we collect and process your personal data when you interact with Trussle.

The Trussle website is not intended for children and we do not knowingly collect data relating to children, unless explicitly requested by a lender or protection provider in a very limited number of cases.

Get in touch

Trussle Lab Ltd is the controller and responsible for your personal data and this website (we use "Trussle", "we", "us" or "our" in this Privacy Policy ). Trussle is a wholly owned subsidiary of Better HoldCo.

We are registered with the ICO under number ZA124882. You can get in touch with us if you have any questions about this Privacy Policy , including any requests to exercise your legal rights, at:

Trussle Lab Ltd, 1-3 Dufferin Street, London, EC1Y 8NA

Email address: [email protected]

Telephone number: 020 3884 1660

We are Trussle Lab Ltd, a company registered in England and Wales under company number 09459339. We are authorised and regulated by the Financial Conduct Authority (FCA), under firm reference number 924229. You can check this on the Financial Services Register by visiting the FCA website. You can find more details about how we're regulated in our Terms of Business.

Keeping information up-to-date

This document was last updated in April 2022, and historic versions can be obtained by contacting us. It's important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. What information we collect

Personal data is any information which can (or could be used to) identify you. It doesn't include data which is not possible to relate to a specific person (anonymous data).

As a mortgage and protection broker, we tailor the right recommendations for your personal circumstances. We therefore ask you for a variety of information to be able to provide a personalised service. This helps us ensure we can select from the widest range of products to provide you with the most appropriate recommendation.

We may collect, use, store and transfer different kinds of personal data about you which are grouped follows:

Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, address and employment history, and citizenship.

Contact Data includes address, email address and telephone numbers.

Financial Data includes bank account details and bank statements, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, mortgages and protection products held, and payment/ direct debit details.

Special Category/Sensitive Data which includes physical and mental health conditions, racial / ethnic origin, criminal offences and convictions. Special category data is collected, where relevant, for the purposes of preventing fraud, arranging a mortgage and/or protection policy for you.

Transaction Data includes details about the products and services you may have benefitted from by using Trussle.

Technical Data includes internet protocol (IP) address, your login data, 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 you use to access this website.

Profile Data includes your username and password.

Job Application Data includes data submitted throughout the recruitment process i.e. name, email address etc.

Employment Data includes any personal information you provide to Trussle as part of the recruitment process or throughout your employment at Trussle should you be a permanent employee, contractor, or 3rd party provider

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us, and our business partners and your communication preferences.

As part of our fact find, we may require information about criminal convictions and offences that you may have, for example for fraud detection. We also collect specific Special Categories of Personal Data about you to provide you with advice for your protection needs (i.e. details about your ethnicity and information about your health).

Other Data

As part of our fact find, we may require information about criminal convictions and offences that you may have, for example for fraud detection. We also collect specific Special Categories of Personal Data about you to provide you with advice for your protection needs (i.e. details about your ethnicity and information about your health).

We collect data relating to the number of dependents as this affects our affordability calculations to provide you with the most appropriate recommendation. However, we'll only ask for further data relating to dependents if specifically requested as part of an application to be submitted to a lender. This data will be treated sensitively and we won't use this data for marketing purposes or creating personality or user profiles.

Apart from the information customers provide to us directly, we may also record information about potential vulnerabilities where we think this is appropriate to meet the obligations placed on us by the Financial Conduct Authority (FCA) with regard to vulnerable customers. You can find out more about our obligations to potentially vulnerable customers here. For more information, visit our accessibility page here.

Aggregated Data

Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Pre-filled, historic data

If you are an existing customer we may use the information we have on you to pre-fill forms when you apply for a new product, but we'll check that these details are accurate as part of the process.

3. How is your personal data collected and what is it used for?

We collect data using different methods, which include;

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, SMS, phone, email or otherwise. This includes personal data you provide when you:

  • sign up for our services;
  • speak to an adviser or any other Trussle team member, (whether through email, live chat or telephone);
  • speak to an adviser;
  • create an account on our website;
  • subscribe to our newsletter;
  • request marketing to be sent to you;
  • give us some feedback;
  • submit a job application;
  • commence work with Trussle as an employee, contractor or 3rd party provider

Information received from a joint applicant. If you are included on an application, but are not the main applicant Trussle receive information about you which has been provided in the application. You will receive a notification from us when the main applicant submits the online form and at key milestones in your application.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Information submitted via a job application. If you submit a job application to us, we will collect all the data submitted in the application form to process your application successfully. The data we will collect will include information shared in a CV, covering letter, job application questions and/or notes made by the hiring manager during the interview process. We will also use 3rd parties to complete the necessary background checks, passing required information to them in accordance with our regulatory requirements. Previous employers will be contacted to request references as appropriate.

Employment Data. Additional information will be collected from you at the start of, and throughout your employment term, for example your next of kin details. Trussle may request additional information from you throughout your employment in line with any changes to applicable laws and regulations.

In some instances we may collect data about you from third parties, such as employment agencies etc.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from: analytics providers and website experience recording services such as Google and FullStory based inside and outside the EU; advertising networks or providers based inside the EU; and search information providers based in the EU.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  • Identity and Contact Data from Hooyu (as part of the anti-money laundering checks we're required to undertake).
  • Estate agents with whom you may be interacting, but with your consent;
  • New home builders, as a legitimate interest of the builder in order to assess affordability for the property;
  • Enquiries you perform on third-party mortgage sourcing websites.
  • Your financial information from your bank available via Open Banking with your consent

How we use your personal data

We'll use your personal data when the law allows us to. Most commonly, we'll use your personal data in the following circumstances:

  • Where we need to perform the contract we're about to enter into or have entered into with you.
  • Where it's necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have provided your consent

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

We've set out below a description of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we're using your data.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To initially engage with you to discuss your requirements

(a) Identity

(b) Contact

Performance of a contract with you

Necessary for our legitimate interests

Consent

Processing of a job application i.e. Carry out vetting and background and right to work checks

Ongoing employment

(a) Identity

(b) Contact

Legitimate Interest for Trussle to assess and validate a candidate suitability and capability to carry out the duties assigned to the prospective role

Necessary for our legitimate interests

Consent

To source products, provide indicative quotes, and process & deliver your application for a mortgage and / or protection product and / or ancillary services i.e. general insurance and conveyancing 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(f) Special Category/ Sensitive Data

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests 

(to recover debts due to us)

To monitor your mortgage, let you know when a better deal becomes available, and let you know if relevant products are available through Trussle.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Performance of a contract with you


Consent

To manage our relationship with you, which will include:


(a) Create and maintain access to your customer portal account


Notifying you about changes to our terms or Privacy Policy or Terms of Business


(c) Asking you to leave a review or take a survey


(d) 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

Performance of a contract with you (including to re-engage with you to review your existing mortgage / protection needs, and to maintain and improve customer service standards)

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)

Consent 

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

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 respond to case enquiries & support any complaints

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(f) Special Category/ Sensitive Data

Necessary to comply with a legal obligation and for our legitimate interests (to ensure that complaints can be responded to accurately)


Regulatory requirements such as; the FCA Mortgage Conduct of Business (MCOB), Systems and Controls (SYSC), Dispute Resolution (DISP), Supervision requirements (SUP), EU AML Directives, UK GDPR

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) 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)


Consent

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to understand how our customers use our platform)


Consent (for cookies which provide insight into how visitors use our website, so we can keep our content relevant and inform our marketing strategy)

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

Necessary for our legitimate interests (to meet your customer needs and inform you about key areas of the mortgage process)


Consent

To request feedback or to ask you to participate in user testing or surveys to improve our website, products/services, marketing, customer relationships and experiences

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To set up payment for financial product providers

To facilitate the payment of services provided by an employee, contractor or 3rd party.

  1. Identity
  2. Financial

Performance of a contract with you

Eligibility scanning

In order to find the most suitable product for you we may use information provided by a third party, HD Decisions, who rely on information held at Credit Reference Agencies (CRAs). A CRA is a company that collects personal information from various sources and provides that personal information for a variety of uses (including to prospective lenders for the purposes of making credit decisions). By signing up to Trussle, you confirm that Trussle and HD Decisions may each use your information as outlined in the ‘Use of Personal Information’ section below.

When requested by Trussle, HD Decisions will search CRAs who provide them with publicly held data, including the electoral roll and shared credit performance data. If you have a financial associate their data may also be provided. We will use the information provided to us by HD Decisions to help decide which products may be best for you. It is important to note that there may be other products available from lenders who are not represented by this service.

When a search is completed, a ‘quotation search’ footprint will appear on your credit report, whether or not you decide to apply for the product. This search will not affect your ability to gain credit.

The information which we provide to the CRA, via HD Decisions, may be supplied to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. In certain instances, your data will be shared with lender(s) to validate if you are an existing customer or for fraud prevention purposes.

The identities of the CRAs used, and further data management details are available through the links below;

  • Experian: www.experian.co.uk/crain
  • Equifax: www.equifax.co.uk/crain

Additionally, you can contact any of the CRAs as follows, if you wish to obtain a copy of your credit report.

Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.

Equifax PLC, Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US or call 0844 335 0550 or log on to www.equifax.co.uk

Marketing communications

You will have the choice to opt-in in the sign up process, to receive marketing information and related products and services. You can opt-out of receiving these types of communications at any time by contacting our team at [email protected] or by clicking on the relevant link in email communications you receive from us.

Please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, have a look at our Cookie Policy.

Pixels

When we send you an email it may contain a small snippet of code called a tracking pixel which allows us to collect certain information about your interaction with the email.

Through this tracking we may record your IP address, the date & time that you opened the email and any links you may click. We use this to understand what emails or services were of interest to you and if the campaigns are effective. We also do this to better tailor our messages to you and optimise your Trussle experience.

By setting your email client to display HTML emails as text only, you may be able to prevent the use of some email tracking. Please consult the "Help" section of your email client for more information

Change of purpose

We will 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 note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

4. Disclosures of your personal data

We'll always treat your data and privacy with respect. This applies where we need to share this to provide you with the best possible service. More details are set out below.

Who we disclose personal data to

Type of recipient

Reason

Mortgage Advice Bureau

It may be necessary to share your personal data with the Mortgage Advice Bureau to review details of your application as part of the due diligence and oversight conducted.

Lenders and protection product suppliers and other ancillary services

To source and submit applications in order to conclude the contract for the mortgage and/or protection application and the ongoing servicing of these contracts.

To send your details to an ancillary service to fulfil services for you in relation to your application. For example; general insurance providers, conveyancers, valuers, and others.

It's important to note that mortgage lenders, protection providers and other third parties are also data controllers in their own right, and have their own privacy notices. You may be required to agree to their privacy notices upon application, if applicable.

External suppliers

We use specialist system and data providers to;

- Advertise and market our services on social media platforms and introduce customers to Trussle for mortgages, protection and ancillary services;

- Send us information on customers that are interested in a mortgage, protection or ancillary services;

- Facilitate the sourcing of mortgage, protection, insurance and ancillary services and products by using specialist IT system providers and transferring your data appropriately

- Enable the delivery of mortgage, protection, insurance and ancillary quotes and services by sending your data to mortgage lenders and insurance providers, and any 3rd parties they may rely on to provide the required service

- Provide our web services, support technical issues;

- Manage our promotions or incentives offered to customers i.e. refer a friend;

- Communicate with you throughout the process i.e. through live chat, email and text messaging;

- Track and review the performance of the website (including user interactions), and promotional activities;

- Track the website and user interactions;

- Complete due diligence and oversight;

- Request feedback and reviews on customer service standards; and,

- Complete vetting processes and background checks (applies if you are applying for a job at Trussle).

It may also be necessary to share your personal data with companies who perform support services on our behalf including those that provide professional, compliance, legal or accounting advice to Trussle. External suppliers are all reviewed as part of our internal due diligence processes.

Solicitors / Conveyancers

To update the firm of solicitors / conveyancers with whom you are interacting about the progress of your application and confirm your identity / proof of deposit.

Estate agents / new home builders

To update the estate agents and home builders with whom you are interacting about the results of affordability checks and progress of your application.

Licensed Credit Agencies

We use Credit Agencies to complete a soft credit search to assess your eligibility (Experian through Castlight). This enables Trussle to review your credit position which is needed as part of the mortgage suitability assessment, and comply with regulatory requirements regarding due diligence.

Regulators

In order to uphold our obligations as an FCA regulated firm, we may need to share information with the regulator on an ad hoc basis or as part of regular reporting.

Referencing and pre-employment vetting

Your documents and information may be shared internally within the company for the purposes of the recruitment process. This includes; People teams that are part of the Better Group (both in the UK and in the US), interviewers conducting the recruitment process and managers within Better group.

Others

Better Holdco (Trussle’s parent company) including their subsidiaries and other third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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 and in accordance with our instructions.

We will communicate primarily with the main applicant on joint applications. However we can communicate with either of the applicants regarding the application where necessary. By using our service you agree to Trussle disclosing application data to all applicants without restriction or prejudice. If you do not wish to be included on an application or you believe information about you has been incorrectly entered, please contact us by emailing [email protected], or your adviser.

International transfers

We abide by the UK data protection laws. And, if we ever have to send data outside the UK , we take care that it's covered by the same high standards.

Some of the businesses we work with are based outside the UK so we need to transfer your personal data to them. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We'll only transfer your personal data to countries that have been deemed to provide an adequate level of protection
  • Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the UK and Europe.
  • Where we use third parties based anywhere else in the world, we use specific contracts and conduct a due diligence check to ensure that the country provides adequate protection to personal data ,

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5. Data security

We understand how important it is to keep your personal data secure, and 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. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will 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're legally required to do so.

Trussle will attempt to deliver emails on the highest encryption level that your email provider can accept. However, if your email provider does not support encryption using TLS, we will be unable to encrypt the email we send you during transit. Therefore, we suggest you check with your email provider that they support SMTP-SSL, or SMTP with StartTLS.

6. Data retention

We won't hold your data for any longer than we need to to make sure you're getting maximum benefit from our services. Find out more here:

How long will you use my personal data for?

We'll only retain your personal data including call recordings for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As well as making sure you're always on the most suitable deal for your circumstances, this enables us to adhere to our regulatory requirements, ensure we provide suitable advice, and to answer any questions you may have later down the line. If you don't transact with us, depending on the stage of your application, we may delete your information sooner in accordance with our data retention policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Purpose of processing

Retention

Successful mortgage / protection applications 

For the full mortgage or protection policy term plus a further 6 years, or for a period of 30 years for historical cases if the original term is not recorded 

Withdrawn, stalled, incomplete and failed mortgage / protection applications

6 years from the date the latest application was started, or 6 years from the application submitted date if application was submitted and subsequently rejected or from creation date if advice has been provided but not pursued

Customer Profile Data

6 years from date of last login if not proceeded to full application

Affordability checks

6 years from Decision In Principle if affordability check does not proceed to a full mortgage application

Job Application

Successful applicant: life of employment plus 6 years after the employment terminates.

Unsuccessful candidate: up to one year

In some circumstances you can ask us to delete your data: see request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We'll be happy to discuss these and how they might apply to you. If you wish to exercise any of the rights set out below, please contact us.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we'll notify you and keep you updated.

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to uphold your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 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 your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we're lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you 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 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.

Object to processing of your personal data where we're 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're 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 don't 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'll 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'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.

What if I am still not satisfied?

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 the Data Protection Manager by emailing [email protected] We will respond to you as soon as 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.

If you are not satisfied with how Trussle 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.