- Accountability and Openness/Compliance MORTGAGE ADVISER DIRECTORY is responsible for personal data under our control. We have established policies and procedures to effectively safeguard any confidential personal data that we collect and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality, and security of your personal data, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal data. Representation for data subjects in the UK We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/cc/MortgageAdviserDirectory
Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.
- Consent By using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal data as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal data at any time by contacting the Privacy Officer in writing at the email address listed above (see: Accountability and Openness/ Compliance). In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.
- Collection and Retention of Information We collect personal data only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information).
Subject to any legal or accounting requirements, we will retain personal data only as long as necessary to fulfil the purposes for which it was collected. Personal data that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on backup media. Information that we may collect includes: User Submitted Information
We collect certain personal data at the time users register to create an account or update their account details including a user’s name, e-mail address, and other contact information. We also collect personal data that users submit through their use of the Services, including when they submit contact and other information, they have collected from their email subscribers and when they create and send email campaigns. Usage Data
We collect certain non-identifying information about the usage of the Services, including information about how users are using the Services and the characteristics of those users. This information is anonymized and is not used by us to identify you as an individual. Account Deletion Requests
At any time, you can request to have your account data deleted by contacting us. Upon receiving the request, we will send you an email to confirm this request. After successful confirmation, your account will be marked for deletion in 30 days. During this 30-day period, you may request to have your account reactivated by contacting us. After 30 days your account is permanently deleted and cannot be reactivated. For more information about account deletion processes, please see the section called Data Retention Policy below. Account Inactivity
To protect your privacy and your data, if your account is not active for a period of 1 year, it will automatically be permanently deleted. 30 days prior to this deletion, an email notification will be sent to the account email address with information about the deletion and instructions on how to keep the account active if desired. For more information about account deletion processes, please see the section called Data Retention Policy below. Data Retention Policy
An account can be permanently deleted by either a deletion request or from account inactivity. We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These may include retention periods: • needed to maintain adequate and accurate business and financial records • for resolving, preserving, enforcing or defending our contractual/legal rights • mandated by law, contract or similar obligations applicable to our business operations • to protect recipients from spam or malicious emails Technical and Device Information
We collect certain non-identifying information related to a user’s access to the Services, including the Internet Protocol (IP) address of the user’s computer, the date and time the user accessed the Services and the operating system that the user is using. We make no attempt to link this information with the identity of individuals visiting our website without express permission. We may, however, review server logs and anonymous traffic for system administration and security purposes, for example, to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage. The possibility, therefore, exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches. Cookies and Web Beacons
- Purpose – Why We Collect, Use and Disclose Information We will identify the purposes for which we collect personal data before or when we request the information. We will not collect personal data which is not necessary and, except as specified below, will not use or disclose personal data for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. This includes:
• to enable you to access and use the Services; • to process, track and communicate with you about the usage of the Services; • to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request; • internal business purposes, such as administering or improving the Services; • to perform internal market research and conduct polls and surveys; • to obtain feedback regarding the Services and our ability to address a user’s needs; • to provide users with information and promotional materials regarding MORTGAGE ADVISER DIRECTORY’s products and services; • to protect us against error, fraud, theft or damage to our goods, our business or our property; • to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and any other reasonable purpose for which you provide consent. We may collect, use or disclose your personal data without your knowledge or consent where we are permitted or required to do so by applicable law, government request or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request or court order, or to protect our assets, the users of our website, or the public.
- Disclosure to Third Parties We may disclose your personal data in response to requests from government agencies, law enforcement authorities, and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal data when we buy a business or sell all or part of our business. You further acknowledge and agree that, in the course of providing the Services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal data to a third-party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them.
- Safeguards – How Information is Protected We maintain reasonable security safeguards to protect personal data in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal data, with the highest level of protection given to the most sensitive personal data. We use user IDs, passwords and encryption technology, and restrict the employees and contractors who have access to personal data to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal data, we delete electronically stored personal data and shred any tangible materials containing personal data. While we will endeavor to destroy all copies of personal data, you acknowledge that deleted information may continue to exist on backup media but will not be used unless permitted by law. We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by using the Services and/or communicating electronically with us, you acknowledge and agree to our processing of personal data in this way and agree that we are not responsible for any personal data which is lost, or which is altered, intercepted or stored by a third party without authorization.
- Accuracy / Access MORTGAGE ADVISER DIRECTORY has a responsibility to ensure that all personal data contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal data. We will inform you of your personal data held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal data, and if you demonstrate the inaccuracy or incompleteness of personal data, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal data changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to the Privacy Officer at the address listed above (see: Accountability and Openness/Compliance).
- International Transfer and Storage of Information You acknowledge and agree that your personal data may be transmitted, transferred, processed, and/or stored outside of the United Kingdom, including in Canada, the United States and in the EU, and therefore may be available to governmental authorities under lawful orders and laws applicable in such jurisdictions. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of the United Kingdom.
- Third Party Content and Links to other Websites The Services may contain optional links to third party Internet websites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites or services. This Policy applies only to the MORTGAGE ADVISER DIRECTORY Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.
- Minors Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal data to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of an adult. MORTGAGE ADVISER DIRECTORY does not knowingly collect personal data from minors.
- Notice of Breach In the event of a security breach causing unauthorized intrusion of our Services that materially affects you or your contacts, MORTGAGE ADVISER DIRECTORY will notify you as soon as possible and later provide a report of the action we took in response to this intrusion.
- Other Data Rights MORTGAGE ADVISER DIRECTORY takes reasonable steps to ensure the data we collect is accurate, complete and up to date and is reliable for its intended use. You can manage most of your data through the Services, however, you can always contact us directly through our contact page if you have any questions about your data. If you would like to contact us directly about deleting, updating or accessing your personal data you can email us directly at firstname.lastname@example.org. We will honor your request in accordance with applicable laws. If you are using our Services to process personal data from certain territories such as the European Union, you may have broader data protection rights identified below:
- Contact Information: We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/cc/MortgageAdviserDirectory