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Privacy Policy

Introduction

Your privacy is really important, which is why protecting your personal data is our top priority. This Privacy Policy explains how we look after your personal data when you visit our website (regardless of where you visit it from), your privacy rights, and how the law protects you.

1. Important information and who we are

It's important to know who's handling your data. Here we set out who we are, why we have this policy in place, and how you can get in touch with us if you have any questions or would like to talk to us about your data.

Personal data we hold about you may be processed by Mortgage Advice Bureau, and where necessary shared with third parties, such as product providers, for the purpose of processing your application, assessing the risk to grant credit and for regulatory purposes.

Purpose of this Privacy Policy

This Privacy Policy lets you know how we collect and process your personal data through your use of this website, including when you create an account, sign up to our newsletter, use our brokerage or mortgage monitoring services or take part in promotion or product feedback.

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

It's important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you're fully aware of how and why we're using your data.

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 ). 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

Our FCA principal Mortgage Advice Bureau Limited (company no. 3368205) and Mortgage Advice (Derby) Limited (company no. 6003803) (MAB) is also a data controller as part of our services. MAB's registered office is located at Capital House, Pride Place, Derby DE24 8QR. You can find more details about how we're regulated in our Terms of Business.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK independent supervisory authority for data protection issues (www.ico.org.uk). We'd always appreciate the chance to deal with your concerns before you approach the ICO however, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 4 December 2018, 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

We're transparent about the sorts of information we're collecting and how it enables us to provide you with the best possible service, while protecting your interests as a customer.

Personal data, or personal information, is any information about you from which you can be identified. It doesn't include data where your identity has been removed (anonymous data).

As a mortgage broker, we want to tailor the best recommendations for your personal circumstances. We therefore ask you for a variety of information to be able to provide this personalised service. Your responses to the questions you provide have a direct impact on what further details we may need from you, as different lenders require different information. This helps us ensure we can select from the widest range of products to provide you with the most appropriate recommendation. We'll always explain this to you, and you can ask us any questions about the data we're collecting at any time.

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

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

Contact Data includes address, email address and telephone numbers.

Financial Data includes bank account details, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, mortgages held, and, if the lender requires, direct debit details, for instance if your chosen mortgage product requires any payment for things such as valuation.

Transaction Data includes details about 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.

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 third parties and your communication preferences.

As part of our online fact find, we don't actively collect any information about criminal convictions and offences or any specific Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, it's important to note that some of the information you provide us with may become Special Category data when collated to form part of your application. We need your consent to process this data, and this is why we ask you to let us know that you agree to our Privacy Policy. This means we can continue to process your application with Special Category Personal Data included (as we wouldn't be able to provide our service without it).

We collect data relating to 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. We'll only request this data if absolutely necessary. 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

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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.

Updating your details

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 always check that these details are accurate and up to date.

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

You'll communicate with us at a variety of points on your Trussle journey, so it's important to understand what happens to your personal information along the way.

We use different methods to collect data from and about you including through:

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;
  • create an account on our website;
  • subscribe to our newsletter;
  • request marketing to be sent to you;
  • give us some feedback.

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.

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 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 CallML (as part of the anti-money laundering checks we're required to undertake).

How we use your personal data

We'll only 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.

Click here to find out more about the types of lawful basis that we'll rely on to process your personal data.

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.

What we use your personal data for

We've set out below a description of all the ways we plan to 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. Please Contact us if you need details about the specific legal ground we're relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

Consent

Performance of a contract with you

To process and deliver your mortgage product

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(f) Special Category

Consent

Performance of a contract with you

Necessary to comply with a legal obligation

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 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

Consent

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

(a) Technical

(b) Usage

Consent

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to 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

Consent

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

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

Consent

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

Indirect

To protect against money laundering, we're required to conduct customer identity screening. As part of this process, we'll try to verify your name and address by checking your details against databases held by credit reference agencies and the electoral roll. If we can't verify your name and address, we may ask you to provide us with other documents to confirm these details. This does not affect you credit history or status.

If you're a joint mortgage applicant we'll record any information you give us about any other persons who are joined to the application.

Marketing and feedback

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

In addition, we value all feedback our customers provide to help us build our business and improve our product. If you leave us a review, we may contact you to ask you if you would like to publicise your review, or to offer you follow up assistance with any difficulties encountered. We may also follow up to for feedback or to ask if you are willing to contribute to marketing material.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You'll receive marketing communications from us if you've requested information from us or used our services, or if you provided us with your details when you created an account and, in each case, you've opted to receiving that marketing.

Third-party marketing

We'll get your express opt-in consent before we share your personal data with any company outside Trussle for the third party's marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this won't apply to personal data provided to us as a result of a product transaction.

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.

Change of purpose

We'll only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we'll notify you and we'll 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.

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.

External third parties

To perform the activities set out above, we may have to share your personal data with the following parties:

  • Mortgage lenders
  • Lead suppliers (if you were introduced to us by a third party)
  • Vita to provide you with buyer protection insurance (where applicable)
  • Call Credit for identity checking
  • United Legal Services where you wish to proceed with a conveyancing quote.
  • Mailchimp and advertising and distribution providers for marketing campaigns
  • Trustpilot, Delighted, Facebook, SurveyMonkey and Google for customer feedback and reviews.
  • Social media platforms such as Facebook for marketing
  • Support and analytics services to help with technical issues

It's important to note that mortgage lenders and other third parties are also data controllers in their own right, and have their own privacy notices.

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'll also share your personal data with the following data processors where necessary to fulfil our services and regulatory obligations:

  • Zendesk, SendGrid, RingCentral, SnapEngage and Intercom to communicate with you
  • Restore Datashred to destroy our confidential waste
  • Amazon Web Services to provide our web services
  • Mortgage Advice Bureau as our FCA principal (acting as a data controller)
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK in instances where such professional services are required.

We may disclose information to either the Financial Service Ombudsman or the Financial Conduct Authority where they request this to resolve complaints, or our auditors in connection with their duties.

International transfers

As a UK based company, all the personal information we process is protected by European data protection standards. And, if we ever have to send data overseas, we take care that it's covered by the same high standards.

Certain of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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

More information on how we work hard to keep your data secure.

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 personal data to those employees, agents, contractors and other third parties 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're legally required to do so.

5. 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 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 our service offers lifetime mortgage monitoring, we'll keep a full record of your interactions for the lifetime of your mortgage after you complete a mortgage transaction with us or sign up for mortgage monitoring. 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 gave 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.

By law we have to keep basic information about our customers who receive advice from us (including Contact, Identity, Financial and Transaction Data) for six years after the transaction for UK Money Laundering regulatory purposes.

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.

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. It's important to be aware of these rights and when you can exercise them, so we've set them out here.

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 comply with your request in these circumstances.

What we may need from you

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, if applicable, at the time of your request.

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.

If you wish to exercise any of the rights set out above, please Contact us.