Privacy Policy
Last updated: January 2025
1. Introduction
Commercial Mortgage Dealer Ltd ("we", "our", "us") is committed to protecting and respecting your privacy. This privacy policy explains how we collect, use, and protect your personal information when you use our website or services.
We are regulated by the Financial Conduct Authority (FCA) and registered under reference number [FCA_NUMBER]. Our registered office is at [REGISTERED_ADDRESS].
2. Information We Collect
Personal Information
We may collect and process the following personal information:
- Name, address, telephone number, and email address
- Financial information including income, expenditure, and assets
- Business information including company details and trading history
- Property information and valuation details
- Credit history and credit scores
- Identity verification documents
Technical Information
- IP address and browser type
- Operating system and device information
- Website usage data and cookies
- Pages visited and time spent on our website
3. How We Use Your Information
We use your personal information for the following purposes:
- To provide mortgage broking services and advice
- To assess your eligibility for financial products
- To process your applications with lenders
- To comply with regulatory requirements
- To communicate with you about your application
- To improve our services and website functionality
- To send you relevant marketing communications (with consent)
4. Legal Basis for Processing
We process your personal information under the following legal bases:
- Contract: To provide our services and fulfill our contractual obligations
- Legal obligation: To comply with FCA regulations and anti-money laundering requirements
- Legitimate interests: To improve our services and protect our business interests
- Consent: For marketing communications and non-essential cookies
5. Sharing Your Information
We may share your information with:
- Lenders and financial institutions for mortgage applications
- Credit reference agencies for credit checks
- Surveyors and valuers for property assessments
- Legal advisors and conveyancers
- Regulatory bodies when required by law
- Third-party service providers who assist with our operations
We ensure all third parties are contractually obligated to protect your information and use it only for specified purposes.
6. Data Retention
We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Typically:
- Active client records: Duration of relationship plus 7 years
- Unsuccessful applications: 3 years from application date
- Marketing data: Until consent is withdrawn
- Website analytics: 26 months
7. Your Rights
Under GDPR, you have the following rights:
- Access: Request a copy of your personal information
- Rectification: Correct inaccurate or incomplete information
- Erasure: Request deletion of your information (subject to legal obligations)
- Restriction: Limit how we process your information
- Portability: Receive your information in a structured format
- Objection: Object to processing based on legitimate interests
- Automated decision-making: Not be subject to automated decisions
8. Cookies
Our website uses cookies to enhance your browsing experience and analyze website traffic. You can manage cookie preferences through your browser settings. Essential cookies are necessary for website functionality and cannot be disabled.
9. Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, and regular security assessments.
10. Contact Us
If you have any questions about this privacy policy or wish to exercise your rights, please contact us:
Email: privacy@commercialmortgagedealer.co.uk
Phone: 0203 838 6148
Post: Data Protection Officer, Commercial Mortgage Dealer Ltd
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe we have not handled your personal information properly.
11. Changes to This Policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.