It's important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1. Who are we, and how can you contact us?
It's important to know who's handling your data. Here we set out who we are, why we have this policy in place, and how you can get in touch with us if you have any questions or would like to talk to us about your data.
Personal data we hold about you may be processed by Ask Ladder Ltd, and where necessary shared with third parties, such as product providers, for the purpose of processing your application, assessing the risk to grant credit and for regulatory purposes.
Ask Ladder Ltd, 74 Rivington Street, London, EC2A 3AY
Email address: firstname.lastname@example.org
Telephone number: 0203 795 1113
We are an Appointed Representative of Sammon Mortgage Management Ltd (company no. 7101913) who are also a data controller as part of our services. Sammon Mortgage Management’s registered office is Sutherland House, 3 Lloyds Avenue, London, EC3N 3DS.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK independent supervisory authority for data protection issues (www.ico.org.uk). We'd always appreciate the chance to deal with your concerns before you approach the ICO however, so please contact our Complaints Department below:
Ask Ladder Ltd, Complaints Department, 74 Rivington Street, London, EC2A 3AY.
2. The Information we collect
Personal data, or personal information, is any information about you from which you can be identified. It doesn't include data where your identity has been removed (anonymous data).
As a mortgage broker, we want to tailor the best recommendations for your personal circumstances. We therefore ask you for a variety of information to be able to provide this personalised service. Your responses to the questions you provide have a direct impact on what further details we may need from you, as different lenders require different information. This helps us ensure we can select from the widest range of products to provide you with the most appropriate recommendation. We'll always explain this to you, and you can ask us any questions about the data we're collecting at any time.
If you are an existing customer we may use the information we have on you to pre-fill forms when you apply for a new product, but we'll always check that these details are accurate and up to date.
We may collect, use, store and transfer different kinds of personal data about you as follows:
*Name, User Name, Password for account creation, Marital Status, Date of Birth, Address Citizenship & Employment details, email address & telephone numbers.
*Bank account details, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, mortgages held, and, if the lender requires, direct debit details, for instance if your chosen mortgage product requires any payment for things such as valuation.
*Details about products and services you may have benefitted from by using Ladder, along with information about how you use our website, products and services.
*Internet protocol (IP) address, your login data, 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 you use to access this website.
*Your preferences in receiving marketing from us, our third parties and your communication preferences.
We collect data relating to number of dependents as this affects our affordability calculations to provide you with the most appropriate recommendation. However, we'll only ask for further data relating to dependents if specifically requested as part of an application to be submitted to a lender. We'll only request this data if absolutely necessary. This data will be treated sensitively and we won't use this data for marketing purposes or creating personality or user profiles.
Apart from the information customers provide to us directly, we may also record information about potential vulnerabilities where we think this is appropriate to meet the obligations placed on us by the Financial Conduct Authority (FCA) with regard to vulnerable customers.
3. How is your personal data collected and what is it used for?
You'll communicate with us in a variety of different ways while processing your application with Ladder, so it's important to understand what happens to your personal information along the way.
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, SMS, phone, email or otherwise. This includes personal data you provide when you:
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.
We may receive personal data about you from various third parties and public sources as set out below:
Identity and Contact Data (as part of the anti-money laundering checks we're required to undertake).
We'll only use your personal data when the law allows us to. Most commonly, we'll use your personal data in the following circumstances:
Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw consent to marketing at any time by contacting us.
We will use your information to:
*Register you as a new customer
*Process & manage any Mortgage application you consent to us making on your behalf.
*Notifying you of any change in our Terms or Privacy Statement.
*To use Data Analytics to improve our website, products & services offered, marketing & relationships.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we're using your data. Please contact us if you need details about the specific legal ground we're relying on to process your personal data where more than one ground has been set out in the table below.
To protect against money laundering, we're required to conduct customer identity screening. As part of this process, we'll try to verify your name and address by checking your details against databases held by credit reference agencies and the electoral roll. If we can't verify your name and address, we may ask you to provide us with other documents to confirm these details. This does not affect you credit history or status.
If you're a joint mortgage applicant we'll record any information you give us about any other persons who are joined to the application.
Marketing, Promotions and feedback
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
In addition, we value all feedback our customers provide to help us build our business and improve our product. If you leave us a review, we may contact you to ask you if you would like to publicise your review, or to offer you follow up assistance with any difficulties encountered. We may also follow up to for feedback or to ask if you are willing to contribute to marketing material.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You'll receive marketing communications from us if you've requested information from us or used our services, or if you provided us with your details when you created an account and, in each case, you've opted to receiving that marketing.
Opting out of Marketing
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this won't apply to personal data provided to us as a result of a product transaction.
4. Disclosures of your personal data
We'll always treat your data and privacy with respect. This applies where we need to share this to provide you with the best possible service. More details are set out below.
External third parties
To perform the activities set out above, we may have to share your personal data with the following parties:
It's important to note that mortgage lenders and other third parties are also data controllers in their own right, and have their own privacy notices.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We don't allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We'll also share your personal data with the following data processors where necessary to fulfil our services and regulatory obligations:
We may disclose information to either the Financial Service Ombudsman or the Financial Conduct Authority where they request this to resolve complaints, or our auditors in connection with their duties.
As a UK based company, all the personal information we process is protected by European data protection standards. And, if we ever have to send data overseas, we take care that it's covered by the same high standards.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We'll only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5. Keeping your Data Secure
We understand how important it is to keep your personal data secure, and 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties 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're legally required to do so.
6. How long do we hold your Data for?
We won't hold your data for any longer than we need to, to make sure you're getting maximum benefit from our services. Find out more here:
We'll only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As our service offers lifetime mortgage monitoring, we'll keep a full record of your interactions for the lifetime of your mortgage after you complete a mortgage transaction with us or sign up for mortgage monitoring. As well as making sure you're always on the most suitable deal for your circumstances, this enables us to adhere to our regulatory requirements, ensure we gave suitable advice, and to answer any questions you may have later down the line. If you don't transact with us, depending on the stage of your application, we may delete your information sooner in accordance with our data retention policy.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers who receive advice from us (including Contact, Identity, Financial and Transaction Data) for six years after the transaction for UK Money Laundering regulatory purposes.
In some circumstances you can ask us to delete your data. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Your legal rights
As a consumer, you have the right to be informed about the collection and use of your personal data, and to have a say in how it's handled. It's important to be aware of these rights and when you can exercise them, so we've set them out here.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. We'll be happy to discuss these and how they might apply to you.
If you wish to exercise any of the rights set out below, please contact us.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we'll notify you and keep you updated.
You won't have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
In summary, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we're lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you 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 or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we're required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure 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're 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're 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 don't 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'll 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're relying on consent to process your personal data. However, this won't 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'll advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.