Homes Made Simple Ltd is strongly committed to keeping your personal data safe. This privacy statement states why and how we collect and use your personal data and provides information about individuals rights. This applies to any personal provided to us by individuals or others. We may use your personal data for any of the reasons stated in this privacy statement. What is personal data? Personal data is any information relating to any living person. If you have any questions about this policy, feel free to email us at [email protected]
Our business is acting as a Mortgage broker. This involves searching against lenders we deal with to find the mortgage that is best suited for your circumstances. We will only ever collect information that help us provide our service to you. We will keep your information for as long as we need and only for Legitimate business activities, statutory or legal obligations or auditing and regulatory purposes.
We collect information either in person or over the phone. Homes Made Simple Ltd will only collect the following information.
• Personal identification Information (Full Legal Name, Address, Previous Address, Email, Date of Birth, Phone number, Nationality)
• Your current Employment Status
• Financial Information (Income, Expenditure, and any financial circumstances).
Depending on how you answer these questions will influence what questions are asked next. This is because different lenders have different criteria and serve different parts of the market.
If you give personal information about someone else (Joint application for example), you must have their permission to do so.
Once we have gathered information from you, we will use specific pieces of your information to help us identify you and verify that we are dealing with the right person.
The information you have given will need to be verified that it is the correct information. For an example, your full name will need to be proven by a form of ID. This is dependent on the information you have given us.
When you apply for a mortgage, we will always offer insurance, if you decide to proceed with insurance, we will need to collect and process information that could be “sensitive”. The type of information includes details about your health.
Throughout your relationship with us, we will hold your personal information securely within our systems. This information will include anything provided by you or others (Joint application for example) in various ways, including (but not limited to):
• Applications, emails and letters, telephone calls and conversations either in office or with your advisor and when registering for services.
• From analysis which are used to help combat any illegal activity.
• And Information we receive from or through organisations (For example, credit reference agencies, Mortgage lenders, Insurance companies, social networks and fraud prevention)
If there is any change to your personal information and you notify us, we will update your information in our systems. If you give someone else’s personal information, we may add it to the information we already hold about them. Please keep in mind that this will only be used in ways that is described in the privacy policy.
When applying for a Mortgage or Insurance, we will need to ask for your Direct debit details to give to the Lender or Insurance Provider. This is so that the Lender or Insurance Provider can collect payments.
When we charge for a fee for arranging a mortgage, or the mortgage we are arranging carries a cost (Valuation fee for example). We will ask for your payment details when the payment is needed.
Homes Made Simple Ltd is the owner of the information collected via our website (https://hms-limited.co.uk) and also any information you provide in relation to an enquiry through Ash (HMS Ltd Assistant bot)
Ash, our assistant bot is powered by Snatchbot.me. To see how they handle your data, visit https://snatchbot.me/privacy.
When using our website, no identifiable information will be collected unless you send an enquiry through Ash (HMS Ltd Assistant Bot) which then it is only the information you provided us.
The following information collected from our website (https://hms-limited.co.uk) may include (but not limited to);
• IP Address
• Device type
• Device software (Browser)
• Location data (The City or region of the IP Address)
Please keep in mind that whilst we have security measures in place to protect your personal information, the internet is not 100% safe. We cannot guarantee the security of any information you send to us online. We are also not responsible for any loss or damage to you or others may have from a result of losing confidentiality of your information.
We will use your personal information to confirm that you are who you are when you contact us. We will use the information to verify parts of your information such as name and addresses by checking details against our databases and to check against information held by the credit reference agencies. Any information that you give to us will also be used for our advisors to give any advice or recommendations for the services we offer and to submit applications to lenders.
Before we submit any type of application or product to the lender, the law requires us to make sure that your identity has been verified. This makes it harder for criminals to use financial systems or use false names and addresses of innocent people. We will also ask for you to provide us with documents to help us confirm your identity.
The law requires us to comply with several regulations. Where necessary, we use your personal data to allow us to fulfil our legal and regulatory requirements.
We will only share personal information with others when we are legally permitted to do so. When we share data with others, we put arrangements and security measures in place to protect the data and to comply with our data protection, confidentiality and security standards. We use third parties to help run our business and provide services to you, we may share your personal data with third parties.
• Mortgage lenders
• Insurance providers
• Conveyancers
• Lead suppliers (If you were introduced to us by a third party)
Your Personal information maybe transferred to these authorised parties:
We use services provided by organisations to support us to provide our services to you and to help provide, run and manage out internal IT systems. For examples, providers of IT, cloud-based applications, website & email hosting, data back-up, security and storage services. The severs powering the cloud applications are in secure data centres around the world and personal data maybe stored in one of them.
Here at Homes Made Simple, we perform anti-fraud, credit and security checks using your details and receive information about you from other sources such as credit agencies which will be added to the personal information which we already hold about you.
We may use your information to detect or prevent fraud. We may also use your data for the investigation, detection and prevention of crime other than fraud.
Sometimes, we may receive requests from third parties with authority to obtain personal data such as the Police, Regulatory bodies or legal advisors in connection with any alleged criminal offence, unlawful activity or suspected breaches of Terms of Conditions/Terms of Use, where required by law or where we suspect harm or potential harm to others. We will co-operate with any law enforcement authorities, court order requesting, directing us to disclose the identity, location of or any information about anyone breaching any relevant terms and conditions, for the prevention or detection of crime, the apprehension or prosecution of offenders. We shall not be obliged to give you any further notice of this if this were to happen.
If we have your consent, we will use your information to identity other products or services we offer that we believe you might want to know about.
By knowing more about our customers, we can improve our service to you. We will use your data for analytical purposes. We will also collect data on you use our website, so we can better understand your interests and improve the website’s performance and our overall service.
Sometimes, we may use a tracking system within our emails to give the time and date you open our emails. This allows us to know whether our emails are opened and to make sure if we are still able to contact you.
We will not pass your data to any third parties for marketing purposes unless you have an existing relationship with them, and you have given your consent for them to contact you in this way.
See our cookie policy for more information about how we collect data about your online activity.
We use social media and are wanting to understand our customers and what people are saying about us. We may use the information we gather to research public comments made on social networking sites such as Twitter or Facebook.
If you do not wish to receive information from us as explained above, you can update your preferences by contacting us as below:
In Writing:
Data Protection,
Homes Made Simple Ltd
Suite 7-8, Raglan House,
William Brown Close, Llantarnam,
NP44 3AB.
Email: [email protected]
Telephone: 01633 302024
If we ever have to use your personal information for any purposes that we haven’t described in this policy, we will let you know exactly what we will use it for before we go any further and obtain consent.
This privacy policy only covers Homes Made Simple Ltd and no other companies, services or applications we use. These companies may have their own privacy policy which we recommend you read before using any such services.
Data protection laws require that, to process your personal data, we must meet at least one prescribed basis for it. We rely on the following basis for the activities we carry out.
We rely upon this basis because you will provide us with your personal data as you want to use our services. This means that our use of your information is in contract terms (governed). It is your choice to give us this information, however if you choose not to provide it, we may not be able to offer some or all the services you are asking for.
Under the basis, we process your data in the following scenarios:
• Understanding your circumstances and any requirements you request
• Assessing risks
• Generating our advice and recommendations to you
• Updating, Consolidating and improving the accuracy of our records
• Letting you know about changes to products, terms or privacy policy
• Verifying your identity and the information you provide
• Providing/Improving customer support or communication
• Responding to you enquires and complaints
Where we collect other information from you or when third parties do so for us, we will always ask for your consent first. If do not want to give consent, or you remove your consent at a later point, we may not be able to provide some or all the services you require.
In the UK, organisations can use personal information where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals.
We rely on this basis for processing personal for helping to prevent and detect crime such as fraud or money laundering, complying with legal and regulatory requirements, ongoing services, training our staff, marketing services, Analytical purposes, tracking activity, maintain our records, resolving complaints and disputes, improving data accuracy and completeness and email tracking. All of this is explained in this privacy policy.
Because of our role as a Mortgage broker, we share personal information you give us with people who need to handle it so that we can provide our services to you.
Here are the organisations that we may share your information with:
• Suppliers – We use service providers to support our business to provide our service to you. They may have access to our systems and data so that they can provide services to us and/or to you on your behalf
• Public Bodies, Law enforcement and regulators – The Policy and other law enforcement agencies can sometimes request personal information, this may for reasons including detecting and preventing crime, apprehending or prosecuting offenders or assessing or collecting tax.
• Lenders and Insurers – In some cases, we share credit report information and personal information with lenders and insures. This is so they can verify that you’re eligible for the product you’re applying for, supporting you to complete your application and contacting you about credit and financial products and complying with any contractual, legal and/or regulatory obligations.
To fulfil our obligations, we will also share your personal information with the following third parties:
• Mortgage lenders
• Insurance providers
• General Insurance providers
• Lead Suppliers
• Conveyancers
To help you benefit from the services of our specialist partners, we may also share your personal data with the following organisations, but only with your consent:
• MCI Club for Mortgages
• A comprehensive panel of lenders/providers for Equity release and Protection
• A panel of conveyancing service providers
If you no longer wish us to share your data with any of these organisations, you may withdraw your consent at any time.
We will also share your personal information with the following data processors where necessary to fulfil our services and regulatory obligations:
• A panel of life insurance providers
• MCI Club to provide mortgage illustrations
• Mailjet to communicate with customers
• Ekeeper group who provides our Customer Relationship Management system
• Hetzner who provides our Email and Web services
• Morecom to provide our phone systems
If you were introduced by a third party, we may update them about how your enquiry with us is progressing.
Homes Made Simple is based in the UK. Our main databases are in the UK and Germany. This means any personal information we access from or transfer to these locations is protected by General Data protection regulation.
Individuals have the right to be informed about the collection and use of their personal data. We do this in our Privacy policy.
Individuals have the right to access their personal data and supplementary information such as:
• Confirmation that their data is being processed
• Access to their personal data
• And other supplementary information
We will not charge for requests to provide information but may charge a fee if requests consist of information being posted. We will provide the requested information within 30 days unless there are specific/complex requirements which then it can take up to 2 months.
If the request is being made in a repetitive way, we may refuse your request to respond. In these situations, we will inform you and explain our reason.
Before we proceed with any request, we will take steps to verify the identity of the individual making the request.
Individuals have the right to request that inaccurate personal data is rectified or completed if it is incomplete. If you make such request, we will verify that the data provided is accurate and verify the person requesting the changes to be made.
Individuals have the right to be have their personal data erased if:
• The personal data is no longer necessary for the purpose which it was originally collected
• We rely upon consent as our lawful basis for holding the data and you withdraw the consent
• We rely upon legitimate interests as our basis for processing and you object to the processing of your data and there is no overriding legitimate interest to continue this processing
• We are processing your personal data for marketing purposes and you have withdrawn consent
• We have processed your personal data unlawfully
• We must do it to comply with a legal obligation
As an example, we are regulated by the FCA (FCA NUMBER: 742389) and are required to retain records that demonstrate the advice we provide to our customers. These records contain personal information and data that enables us to generate our advice. We will not remove or delete any personal until such time as our regulatory obligation has been fulfilled in respect of each transaction or piece of advice.
Individuals have the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data in the following situations:
• You contest the accuracy of your personal data and we are verifying it accuracy
• The data has been unlawfully processed and you oppose erase, requesting restrictions instead
• We no longer need the personal data, but you need to keep it in order to establish, exercise or defend a legal claim
• You have objected to us processing your data and we are considering whether our legitimate grounds or override your request
If you choose to exercise this right, we may not be able to proceed to provide you with our advice. This may mean that we unable to submit or progress an application with a lender or a product provider. In these situations, we will notify you of the impact of your request.
If you choose to exercise this right, we may not be able to proceed to provide you with our advice. This may mean that we unable to submit or progress an application with a lender or a product provider. In these situations, we will notify you of the impact of your request.
This allows individuals to obtain and reuse their personal data for their own purposes across different services. The right to this only applies to:
• Personal data you have provided to us
• Where the processing is based on your consent or for the performance of a contract
• Where processing is carried out by automated means
We will provide this request within one month unless your request has specific requirements or overly complex which then it can take up to two months.
Individuals have the right to object to:
• Processing based on legitimate interest
• Direct Marketing
If you exercise your right to object, we will stop processing your personal data unless:
• There are compelling legitimate grounds for us to continue to process, which override your interests, rights and freedoms
• The processing is for the establishment, exercise or defence of legal claims.
You can exercise your right to object at the first point of contact with us or at any other time by contact us as detailed below. If exercising you to object affects or prevent us from being able to provide you with one or any of the services, we offer we will inform you.
It is necessary with most lenders to obtain an initial decision for a mortgage. This is mostly referred to a Decision in Principle – DIP. To obtain a DIP, we may process your information through a lender’s automated decision-making system which will provide an initial lending decision based on algorithms programmed into it. We will always obtain your consent before completing a DIP. Whilst we do not set or determine the algorithms used in the automated decision system. We can put in touch with the respective lender should you require it.
To exercise any of your rights detailed above, you can contact us detailed below.
In Writing:
Data Protection Officer,
Homes Made Simple Ltd
Suite 7-8, Raglan House,
William Brown Close, Llantarnam,
NP44 3AB.
Email: [email protected]
Telephone: 01633302024
We take the privacy of your information very seriously. If you ever feel you need to complain about how we have handled your data, you can contact us using the following methods below.
In Writing:
Complaints Department
Homes Made Simple Ltd
Suite 7-8, Raglan House,
William Brown Close, Llantarnam,
NP44 3AB.
Email: [email protected]
Telephone: 01633302024
If your compliant is about the administration or terms and conditions of a product sold by us but provided by lender/insure, you may need to contact them about. If needed, we will forward details of your compliant to the insurer concerned, as well as giving you their contact details.
To help make sure you always speak to the right person about your compliant, if it looks like another company will be better to handle your case, we will let you know how to contact them.
If you are still unhappy with any aspect of how we handle your data, you can contact the Information Commissioner’s office (ICO). The ICO is the UK’s independent body set up to uphold information rights. You can contact it as follows:
Via its website: https://ico.org.uk
In writing:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Telephone: 0303 123 1113
Here at Homes Made Simple, we know how important it is to keep your personal information secure. We use a variety of systems and procedures to protect your private from being accessed, used or disclosed in any way it should not be. Together, they to protect the personal information we hold from risks including loss, theft or unauthorised access, collection, use, disclosure, copying modification, disposal and destruction.
We regularly review our policies and procedures to make sure they remain relevant.
As explained in “How do we use your Personal information”, we use third parties to help us run business as a mortgage broker to fulfil our contractual obligations, we may share your personal data these third parties. We require every third party that we share information with to maintain adequate security safeguards and comply with all the required laws and standards for protecting personal information
We will keep your personal information securely stored for as long as we need it to provide you with the services you request from us. We also keep it for legal reasons and to help us resolve any issues you may have.
Depending on what information we may hold and what products or services you are signed up to, we may need retain certain details for longer then others. In every case, we regularly reassess whether, we need to hold your personal information and securely dispose of any information that we no longer need.
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