Client Privacy Notice
Clear Mortgage Solutions Limited. Registered Office: 114 Centrum House, Dundas Street, Edinburgh EH3 5DQ. Registered in Scotland Number: SC463175
Mortgage Advice Bureau Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 3368205
Mortgage Advice Bureau (Derby) Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 6003803
Companies known together in this document as “Mortgage Advice Bureau”, “we” and “us”
Clear Mortgage Solutions Limited is an Appointed Representative of Mortgage Advice Bureau and Mortgage Advice Bureau (Derby) Ltd. As joint controllers of your data, we comply with Data Protection laws in the United Kingdom. This Privacy Policy details how we process your personal data.
The personal data we collect about you
Personal data collected, used, stored and transferred by us may include:
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Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
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Contact Data including home address, email address and telephone numbers
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Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
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Special Category Data inc. medical history and trade union / political party membership costs
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Transaction Data including payments made for products and services you have purchased from us
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Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access our website
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Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
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Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences
How do we collect your personal data?
Personal data is collected by us using the following methods:
• Direct interactions with an adviser in person, by post, phone (including call recordings and voicemail), email, videoconferencing or otherwise when sourcing and applying for mortgage or protection products, processing Identity, Contact and Financial categories of personal data.
• Automated technologies or technical interactions with our website, via the My Mortgage Account portal, web enquiry form or the Find A Mortgage function, processing Identity, Contact, Financial and Technical categories of personal data.
• Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:
• Estate agents with whom you may be interacting, but only with your consent;
• New home builders, as a legitimate interest in order to assess affordability for the property;
• Enquiries you may perform on third-party mortgage sourcing websites;
• Your financial information from your bank available via Open Banking with your consent.
| How do we use your personal data? Purpose/Activity | Type(s) of data | Lawful basis for processing | |
| To initially engage with you to discuss your requirements |
• Identity • Contact
|
Consent | |
| To source products, provide indicative quotes, and process & deliver your application for a mortgage or protection product |
• Identity • Contact • Financial • Transaction • Marketing & Comms • Special Category
|
Performance of a contract with you to provide advice services
Special Category data – Explicit Consent (Medical information for protection policies) |
|
| To comply with FCA rules including record keeping, consumer duty, vulnerable customers,and to meet Anti Money Laundering legislation, and notifying you about changes to our terms or privacy policy |
• Identity • Contact • Financial • Transaction • Special Category
|
To comply with a legal obligation
Special Category data – Substantial Public Interest (Statutory & Government Purposes) supported by Vulnerable Customer policy |
|
| To recover debts due to us |
• Identity • Contact • Transaction
|
Necessary for our legitimate interests | |
| To create and maintain access to the My Mortgage Account portal account |
• Identity • Contact • Profile & Usage • Marketing & Comms
|
Performance of a contract with you | |
| To manage our client relationship with you which will include:
• Customer reviews / surveys • On-going communications until you are ready to proceed • Re-engagement when existing products nears expiry / review protection needs
|
• Identity • Contact • Profile & Usage • Marketing & Comms
|
Necessary for our legitimate interests
(as joint data controller with Mortgage Advice Bureau, to re-engage with you to review your existing mortgage / protection needs, to maintain and improve customer service standards, and to communicate with you as part of a nurture journey until you are ready to proceed with a mortgage / protection application) |
|
| To respond to case enquiries and input to & defend against complaints |
• Identity • Contact • Profile & Usage • Transaction • Marketing & Comms • Special Category
|
Necessary for our legitimate interests
(to ensure that complaints can be responded to accurately) Special Category data – Legal Claims & Judicial Acts |
|
| To perform an affordability check for a property on behalf of an Estate Agent or New Home Builder |
• Identity • Contact • Financial
|
Necessary for our legitimate interests and of the New Home Builder / Estate Agent (to ensure that a property is affordable before the purchase process) | |
| Record appointments to perform checks on the quality of advice our advisers provide to clients |
• Identity • Contact • Special Category
|
Consent
Special Category data – Explicit Consent |
|
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
• Identity • Contact • Technical
|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) | |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
• Identity • Contact • Profile & Usage • Technical
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | |
| To use cookies, data analytics and other systems to improve our website, products/services, marketing, customer relationships and experiences |
• Identity • Technical • Profile & Usage
|
Consent / Explicit Consent |