COOKIE POLICY

This is the cookie policy for Willow Brook mortgages. We are committed to protecting your privacy. This Cookie Policy forms part of our legal information and sets out how we use cookies on our website to help make your visits more effective.

WHAT ARE COOKIES?

Cookies are small text files placed on your computer by websites and sometimes by emails. They provide useful information to organisations, which helps to make your visits to their websites more effective and efficient. We use cookies to ensure that we are able to understand how you use our website and to ensure that we can make improvements to our websites. Cookies do not contain personal or confidential information about you.

HOW WE USE COOKIES

We use cookies to ensure that you get the best from our website. The first time that you visit our website you will be asked to consent to the use of cookies and we suggest that you agree to allow the cookies to be active on your device whilst you visit and browse to ensure that you experience our website fully.

THE TYPES OF COOKIES WE USE

We use three types of cookies on our website:

• Session cookies that are deleted after each visit

• Persistent/tracking cookies that remain in place across multiple visits to our websites

• Third party cookies that are used by other parties, for example Google Analytics

Session cookies and persistent cookies are necessary in order for you to use our website. These cookies can be deleted via your browser, but this will restrict the functions that you are able to carry out on our websites. For more information on how to disable cookies in your browser please see the Information Commissioner’s Office website. (http://www.ico.org.uk/for-the-public/online/cookies/)

Session cookies expire when you leave the website and are not stored on your computer and do not contain any personal data.

Persistent cookies last beyond your visit to our website. We use Google Analytics on our website. This is a tracking cookie which enables us to track how popular a site is and to record visitor trends over time. The cookie does not contain any personal data but it does contact your computer’s IP address to determine where in the world you are accessing the website from and to track your page visits within the site.

OPTIONAL COOKIES

These cookies are usually supplied by business partners and help us to filter out information which is not relevant to you.

ACCEPTING / BLOCKING COOKIES

You can accept or block any cookies from any website through your browser settings. For more information on how to disable cookies in your browser please see the Information Commissioner’s Office website. (http://www.ico.org.uk/for-the-public/online/cookies/).

Please note that if you share your computer, accepting or blocking the use of cookies will affect all users of that computer.

COOKIES AND DEMOGRAPHICS

We may use data from Google’s interest-based advertising or third party audience data (such as age, gender and interests) with Google Analytics.

MORE INFORMATION

For more information about cookies visit the Information Commissioners website

www.ico.org.uk/for-the-public/online/cookiesThis statement can be condensed by only displaying the questions and expanding the text to show the answer when the customer clicks on that question.

PRIVACY POLICY

Your Personal Data

To enable us to give you the right advice, we will need to hold some personal information about
you. The Data Controller in relation to any personal data you supply is Stonebridge Group and any
information you give will be processed in accordance with the General Data Protection Regulation.
We take our obligations under the General Data Protection Regulations (GDPR) and Data
Protection Act 2018 seriously. All our staff are provided with appropriate training and required to
comply with formal data protection policies, guidelines and procedures designed to keep personal
data secure and support privacy.

Why we need it

We need to know basic personal data and may share this information:-
• To enable Stonebridge Group and our representatives to manage your dealings with us. We
may use personal information supplied to meet your needs in arranging a mortgage, loan,
protection and any associated arrangements. Data will be processed in the legitimate interest
of the business.
• To disclose information to any third parties relevant to the transaction; such as lenders,
insurers, lending specialists or contracted software providers. Data will be processed in the
legitimate interest of the business.
• In order to verify your circumstances, third parties may be contacted such as your employer,
accountant or credit reference agency. Data will be processed in the legitimate interest of the
business.
• For compliance monitoring purposes, your data may be made available to the Financial
Conduct Authority. Data will be processed in the legitimate interest of the business.
• To allow Stonebridge Mortgage Solutions Ltd. or their representatives to conduct compliance
monitoring, to prevent financial crime, and to contact you for the purpose of ensuring you
have received adequate advice. Data will be processed in the legitimate interest of the
business.

Necessary for our legitimate interests (to operate our business effectively)If you do not provide
this information, then we will be unable to provide the services you have requested. We will not
collect any personal data from you that we do not need in order to provide and oversee the
services we provide.

If you provide an e-mail address, you consent to us sending communications by e-mail. While we
will take reasonable steps to ensure security of information by e-mail, you accept the risks
involved with this type of communication.

What we do with your data

All the personal data we hold about you will be processed by our staff in the United Kingdom.
Selected third parties as detailed above will have access to your personal data where there is a
service they provide to us or there is a legal obligation for us to provide them with this. Please be
aware, however, that your information may be stored on a cloud-based system whose servers are
located within the United Kingdom.

How long will we keep it

We will generally keep your personal data for a minimum of 6 years after our business
relationship, after which time it will be destroyed if it is no longer required for the lawful
purpose(s) for which it was obtained. The business relationship will usually be classed as over
once we are aware any mortgage or insurance product has ended.

Stay in Touch

We hope you find our service valuable and hope we can help you again in the
future, especially when your mortgage rate comes to an end.

We are always keen to do all we can for our customers. Often there are new financial products
available or extra services we can offer, so we would like the chance to tell you – but only if we
think you will be interested and only if you give us permission to do so. Please tell us how you
would like us to stay in touch.

We will only keep in touch with you for up to five years unless you renew your permission

Sensitive Personal Data

In addition to the basic data described above, it may also benefit you to notify us of any health
condition or disability you have, so that we are aware of these conditions. This type of
information is known as ‘special category information’ (you may also know this as ‘sensitive
personal data’) and we require your explicit consent to process this information.

This type of information will only be collected from you and used by us to assist you in connection
with an insurance application, as such it may be shared with an insurance company in order for
them to consider your application.

Some insurers may give you the option of speaking to them directly with this information.

What are your rights?

Under data protection legislation, you have several rights relating to the use of your personal
data:-
• You have the right to ask for a copy of information, usually free of charge. We will respond to
this request within a month.
• You also have the right for certain data you have provided us, this will be provided to you in a
structured and commonly used electronic format (for example, a Microsoft Excel file), so that
you can move, copy or transfer this data easily to another data controller. You may also
request that we transmit this data directly to another organisation where it is practical for us
to do so.
• You have the right to have personal data rectified if it is inaccurate or incomplete.
• You are entitled to have data deleted if it is no longer needed or there is no longer a legitimate
reason for the processing, or if the data in question has otherwise unlawfully been processed.
You may also request deletion of your personal data if it was only being processed as a result
of you consenting to this and you now withdraw your consent.
• You have the right to object to the processing of your personal data (please note that this only
provides you with the right to raise your objections, not a blanket right to have any and all
processing cease).
• You have the right to restrict the processing of your personal data under certain
circumstances, including if you have contested its accuracy and while this is being verified by
us, or if you have objected to its processing and while we are considering whether it has
legitimate grounds to continue to do so.

How to complain about use of your data

If you wish to raise a complaint about how we have handled your personal data, including in
relation to any of the rights outlined above, you can contact
complaints@stonebridgegroup.co.uk and they will investigate your concerns.

If you are not satisfied with our response, or believe we are processing your data unfairly or
unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further
information about the ICO and their complaints procedure here: https://ico.org.uk/concerns .
I have read this information and understand how the information I provide may be used.

Willow Brook Mortgages will be what is known as the ‘controller’ of the personal data you provide to us. We only collect basic personal data about you which does not include any special types of information or location-based information.

 

Why do you need my data and what will it be used for?

We need to know your basic personal data so we can make contact with you and respond to your message, request or query. All the personal data we process is processed by our staff in the UK.

Who is my data shared with?

Your data will only be shared with third parties if this is necessary to respond to your request. If this is the case, we will seek your permission before passing on your details.

How long do you keep my data for?

We may store your data for up to six years past the end of any business relationship, after which time it will be securely destroyed. If you would no longer like us to process your data at any time, you have the right to object to processing of your data. To do this, please contact EMAIL ADDRESS

What are my rights?

You have the right to object to the processing of your data. You also have the right to request access to your data at any time. You have the right to rectification and/or erasure of personal data or restriction of processing. If you wish to raise a concern related to how we have handled your personal data, you can contact us to have the matter investigated at compliance@sdlgroup.co.uk. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the information commissioner’s office: https://ico.org.uk