Client Privacy Notice
Stonebridge Mortgage Solutions. Registered Office: c/o 9 Lords Ct, Basildon SS13 1SS. Registered in England Number: 5601592.
Companies known together in this document as “Stonebridge Mortgage Solutions”, “we” and “us”
Birtles Mortgages & Financial Solutions is an Appointed Representative of Stonebridge Mortgage Solutions. 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 Stonebridge Mortgage Solutions 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 Stonebridge Mortgage Solutions 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 31st 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 [email protected]
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 [email protected] 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 Stonebridge Mortgage Solutions 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 hero 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 Hero 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 | Reason |
| Within Stonebridge Mortgage Solutions | Depending on your requirements, it may be necessary to share your personal data with Stonebridge Mortgage Solutions’ network and specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients |
| Lenders and protection product suppliers | To source and submit applications in order to conclude the contract for the mortgage / protection application and the ongoing servicing of these contracts. |
| Financial Institutions | To source your bank account information via Open Banking with your consent |
| External suppliers | Specialist IT system providers to deliver our service to you (including sourcing of products, providing continuing advice, sharing of documentation, payment processing, informing you about relevant products and services, service & advice quality checking and improvements, and to request feedback on customer service standards). It may also be necessary to share your personal data with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Stonebridge Mortgage Solutions. |
| Solicitors / Conveyancers | To update the firm of solicitors / conveyancers with whom you are interacting aboutthe progress of your application and confirm your identity / proof of deposit. |
| Estate agents / new home builders | To update the firm of mortgage / protection advisers, estate agents and home builders with whom you are interacting about the results of affordability checks and progress of your application. |
| Licensed Credit Agencies | For the purposes of confirming your identity to comply with Anti Money Laundering requirements (TransUnion data processing information can be found in the privacy notice on the www.callcredit.co.uk website); to perform a credit assessment to assess your eligibility; to obtain a Lenders Decision In Principle; and as part of a full application. |
| Regulators | In order to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities. |
| Others | Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. |
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 Stonebridge Mortgage Solutions 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.