Privacy Policy

JUST Mortgage Brokers Ltd is committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently.

This Privacy Notice explains:

• Who we are
• What personal information we collect
• How we use your personal information
• Who we share you information with and why
• How we keep your information secure
• Cookies
• Your rights
• How to contact us

WHO WE ARE

JUST Mortgage Brokers Ltd provide mortgage planning solutions and advice through experienced and qualified advisers based in the UK.

JUST Mortgage Brokers Ltd collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for, the purposes of those laws.

JUST Mortgage Brokers Ltd is a company registered in England and Wales (company number 8389911 whose registered office is at 22-24 High Street, Needham Market, Ipswich, IP6 8AP). Just Mortgage Brokers Limited is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited which are authorised and regulated by the Financial Conduct Authority.

WHAT PERSONAL INFORMATION WE COLLECT

Personal information includes your name, address and telephone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit one of our advisers, visit a website we may have, or register to receive one of our newsletters (if applicable).

The type of personal information we collect will depend on the purpose for which it is collected and includes:

• Contact details
• Information to verify your identity
• Family, lifestyle, health and financial information
• Payment details.

We collect personal information directly from you.  For example, we ask for personal information at the start of our relationship and in subsequent communications in order to check your identity and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.

SPECIAL CATEGORY INFORMATION

In some instances, it is necessary to collect more sensitive information (such as health or lifestyle information) which is called Special Category Data.  This is to allow us to provide our financial advice to you.  We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely.  You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.

DATA RETENTION

We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements.  Personal information will be securely disposed of when it is no longer required, in accordance with our Data Retention and Disposal Schedule.  A copy of this is available using the contact details below.

HOW WE COLLECT DATA

The processing of your personal data is allowed for a number of reasons.  The data required for the provision of products and services is processed on the basis there is a contract with you to do so.  Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so however you have rights, as listed below, which impact how we can use and process your data.

HOW WE USE YOUR PERSONAL INFORMATION

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements.  This includes the following:

• Providing our advice, products or services to you
• Carrying out transactions you have requested
• Confirming and verifying your identity for security purposes
• Credit scoring and assessment, and credit management (where applicable)
• Detecting and preventing fraud, crime, money laundering or other malpractice.

We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we process your information to send you marketing literature that is tailored to your interests. Our business purposes include the following:

• Enhancing, modifying, and personalising our services for the benefit of our customers
• Providing communications which we think will be of interest to you
• Market or customer satisfaction research or statistical analysis
• Audit and record keeping purposes
• Enhancing the security of our network and information systems.

You have the right to object to this processing if you wish: Please see “YOUR RIGHTS” section below. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.

We may also process your personal data as part of an acquisition or sale.  Should this happen, you will notified about any change to processing or data controller arising as a result of this activity.

WHO WE SHARE YOUR INFORMATION WITH AND WHY

We share your information with trusted third parties who perform tasks for us and help us to provide the services you require and these include:

• Third parties to verify your identity in line with money laundering or other requirements (this may involve carrying out checks with credit reference databases);
• Third parties who perform tasks for us to help us set up or service your plan (these third parties may be based in countries outside the European Economic Area (EEA) but where they are, we will undertake an assessment of safeguards in place);
• Other organisations, including regulatory bodies, the police and fraud prevention agencies, to prevent and detect fraud;
• Third parties where required by law, court order or regulation;
• Third parties as part of an acquisition or sale;

HOW WE KEEP YOUR INFORMATION SECURE

We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls, related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

OUR COOKIES

YOUR RIGHTS

JUST Mortgage Brokers Ltd is as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below.  This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found on the ICO website.

MARKETING

You have the right to opt out of marketing information and tell us what your communication preferences are by contacting JUST Mortgage Brokers  Ltd using the details provided at the end of this notice, or by using the opt out option below or on any marketing e-mail. You may opt out at any time if you do not want to receive any further communications of this nature.

INDIVIDUAL DATA RIGHTS AND REQUESTS

• The purposes of the processing;
• The right to be informed – you can request that we provide ‘fair processing information’, typically through this privacy notice;
• The right of access – you may request a copy of the personal information we hold about you using the contact details found on the end of this policy;
• The right to rectification – the accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information;
• The right to erasure – you may request the deletion or removal of personal data where there is no compelling reason for its continued processing;
• The right to object – you may object to the processing of your data based on legitimate interests;
• The right to restrict processing – you have a right to request that we ‘block’ or suppress processing of your personal data;
• The right to data portability – you may request to obtain and reuse your data; and
• The right not to be subject to automated decision-making including profiling.

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the address within this document.

CONSENT TO GATHER SPECIAL CATEGORY DATA

As detailed above, in some instances, it is necessary for us to collect more sensitive information (such as health or lifestyle information) which is called Special Category Data.  This is to allow us to provide financial advice to you.  This is where we need to gather your consent to the collection and processing of this data.   You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.

QUESTIONS

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 our Data Privacy Manager, by sending an email to [email protected]  or write to The Data Privacy Manager, 22-24 High Street, Needham Market, Ipswich, IP6 8AP. We will respond to you as soon as is 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 JUST Mortgage Brokers Ltd 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.