Client Privacy Notice
The Mortgage Hut Limited. Registered Office: Ground Floor, Threefield House,
Threefield Lane, Southampton SO14 3LP
Registered in England Number: 07629941
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”
The Mortgage Hut 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:
• Identity Data including forenames, last name, maiden name, date of birth, gender, marital status,
and username or similar identifier
• Contact Data including home address, email address and telephone numbers
• Financial Data including banks statements, payment card details, savings, debts such as loans and
credit cards, income & expenditure, employer & pension benefits, and other assets
• Special Category Data inc. medical history and trade union / political party membership costs
• Transaction Data including payments made for products and services you have purchased from us
• 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 the Mortgage Advice Bureau website
• Profile and Usage Data including purchases made by you, feedback and survey responses, and
how you use our website, products and services
• 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 customer 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 comply with a legal obligation
Necessary for our legitimate interests
(to recover debts due to us)
Explicit Consent
To manage our client relationship
with you which will include:
• Create and maintain access to
your customer portal account
• Notifying you about changes to
our terms or privacy policy
• Customer reviews / surveys
• Re-engagement when existing
products nears expiry / review
protection needs
• Identity
• Contact
• Profile & Usage
• Marketing & Comms
Performance of a contract with you
To comply with a legal obligation
Necessary for our legitimate interests
(with Mortgage Advice Bureau and The Mortgage
Hut as joint controllers, to re-engage with you to
review your existing mortgage / protection needs,
and to maintain and improve customer service
standards)
To respond to case enquiries and
input to & defend against
complaints
• Identity
• Contact
• Profile & Usage
• Transaction
• Marketing & Comms
• Special Category
To comply with a legal obligation
Necessary for our legitimate interests
(to ensure that complaints can be responded to
accurately)
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
• Profile & Usage
Necessary for our legitimate interests and of the
New Home Builder / Estate Agent (to ensure that
a property is affordable before proceeding with the
purchase process)
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
To comply with a legal obligation
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
• Marketing & Comms
• 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 data analytics and other
systems including AI and automated
decision making to improve our
website, products/services,
marketing, customer relationships
and experiences
• Identity
• Contact
• Financial
• Special Category
• Technical
• Profile & Usage
Consent / Explicit Consent
Necessary for our legitimate interests (to analyse
customer usage, update our website, to develop
our business, and to inform our client re-
engagement and marketing strategy)
Change of purpose
We will only 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 contact us for an
explanation as to how any new processing is compatible with the original purpose. If we need to use your
personal data for an unrelated purpose, we will notify you and 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.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 31
st
December
2020. Historic versions can be obtained by contacting us.
Use of AI and Automated Decision Making
We may use your data in AI and automated decision-making systems for re-engagement purposes as a
legitimate interest to review your existing mortgage and source suitable new products. If you do not wish
your data to be used by such systems, please notify us at data.protection@mab.org.uk
Marketing communications
You will also have the choice to opt-in to receiving other related marketing information and related products
and services. You can opt-out of receiving these types of communications at any time by contacting your
adviser, by emailing data.protection@mab.org.uk or by clicking on the relevant link in email communications
you receive from us. However please note that your personal information will not be passed to any third-
party organisation for marketing purposes.
Data Security
We 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. We also limit access to your personal
data to only those Mortgage Advice Bureau staff, appointed representatives, advisers, business partners and
suppliers 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 are legally required to do so.
Cookies
When using the Mortgage Advice Bureau website, 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, please see our cookie policy.
Website Third-party links
Mortgage Advice Bureau website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every website you visit.
Sharing of personal data outside of the United Kingdom
Some of our external suppliers are based overseas so their processing of your personal data will involve a
transfer of data outside of the UK. In such cases data is transferred under conditions to provide protection to
personal data equivalent to UK Data Protection standards. This includes the use of standard contractual
clauses in contracts with external suppliers in order to provide the same level of protection for personal data
as it has in the UK.
Who we disclose personal data to
Type of recipient
Within Mortgage Advice
Bureau
Lenders and protection
product suppliers
Financial Institutions
External suppliers
Solicitors /
Conveyancers
Estate agents / new
home builders
Licensed Credit
Agencies
Regulators
Others
These companies are required to ensure appropriate security measures are in place and maintain the
confidentiality of your personal data, and to use your personal data only in the course of providing such
services and in accordance with Mortgage Advice Bureau instructions.
How long is your personal data retained?
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
2 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
Client Portal accounts
2 years from date of last login if not proceeded to full application
Affordability checks
2 years from Decision In Principle if affordability check does not proceed to
a full mortgage application
Enquiry data obtained from third parties
that do not result in an application
2 years from the date the lead was received from the Introducer
After these retention periods if there is no other on-going client relationship your personal data will either be
securely deleted or anonymised so that it can be used for statistical purposes but without any method of
identifying you individually.
Your legal rights regarding your personal data
You have the right to:
• Request access to your personal data. This enables you to receive a copy of the personal data we
hold about you and to check that we are lawfully processing it.
• Request correction of the personal data. This enables you to have any incomplete or inaccurate
data 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 personal data where
there is no good reason for us continuing to process it. You can also ask us to delete your personal
data where you have successfully objected to the processing (see below), where we may have
processed your information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to delete the data 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 are 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 are 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 do not 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 will 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 are relying on consent to process your personal data.
However, this will not 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 will advise you if this is the case at the time you withdraw your consent.
EU Citizens
Clients who reside within the European Union retain their data subject rights under the EU General Data
Protection Regulation. EU-based clients with queries regarding how Mortgage Advice Bureau processes
their data can contact our EU representative DataRep by emailing datarequest@datarep.com or by visiting
their website www.datarep.com/data-request
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 the Information Security & Data Protection
Manager by emailing Data.Protection@mab.org.uk or by writing to us. 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.
What if I am still not satisfied?
If you are not satisfied with how the Mortgage Advice Bureau 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.