CMME Mortgages and Protection (CMME) will always take your privacy with complete seriousness and assure you that every reasonable precaution will be taken to protect the personal information you supply.
Please take some time to read through this and ask us to explain anything that isn’t clear.
About CMME and how to contact us
This document includes important information about how we use your personal data. If you want to talk to us more about it, you can get in touch with us, by email, telephone or post, using the details below, or by contacting your dedicated Mortgage Consultant or Case Manager in our Client Services Department.
By phone: 01489 555 080
By email: firstname.lastname@example.org
By post: CMME, 2 Glass Wharf, Bristol, BS2 0FR
CMME is responsible for processing the personal information you provide to us and is registered with the Information Commissioners Office in the UK (registration number Z8193635).
Who is your data controller?
Where you are introduced or referred to us by a third party, we become your data controller upon completion of your first call with us.
Information we collect about you
Who are “you”?
You are visiting one of our websites because you are curious.
You have received, are receiving, or are in the process of agreeing to receive advice from us.
To give you the best service possible we will need to ask you for certain personal information. If you use our services, we will also use this information for security, identification and verification purposes.
Contact info – You might provide us with your contact information, whether through use of our services, a form on our website, an interaction with our sales or customer support team, or a response to one of our emails.
Usage info – We collect usage information about you whenever you interact with our websites and services. This includes which web pages you visit, what you click on when you perform those actions, what language preference you have, and similar usage information that helps us to optimise our website for our users.
Device & browser data – We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you on a mobile device we also collect the Universal Unique Identifier (UUID)for that device.
Log data – Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., website pages, graphics, etc.), operating system versions, device type, and timestamps.
Information from third parties – We collect your personal information or data from third parties if you give permission to those third parties to share your information with us or where you have made that information publicly available online.
If you are a Client of CMME we will also collect:
Information to process your mortgage and/or protection contract – We collect information from you relating to your financial situation, your health, your work life and your expenditure in order to produce offer summaries, key fact illustrations and other documentation relating to Protection & Mortgage services specified within the Initial Disclosure Document.
Billing Information – If you make a payment to CMME, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number).
- To gather metrics about your website experience.
For example, we will collect data about the number of clicks someone made before they left the website, whether they visited certain parts of our website and how long they stayed for. However, this information is collated and kept at an aggregated and anonymised level only.
- To make our site easier to use.
When you complete forms or search for things on our website, we store your previously submitted information in a cookie to make it quicker for you to sign in or complete forms.
- For security reasons.
- To provide you with personalised content.
We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can personalise the content you see.
- To improve our services.
We only ever collect information that helps us provide our services to you. We will keep your information for as long as is needed and only for the following purposes:
- Legitimate business activities
- Statutory or legal obligations
- Auditing and regulatory purposes.
We sometimes need to pass your information on to third parties who provide services to us. We do this with the understanding that they care for your information as carefully as we do, keep it confidential and use it only for the agreed purposes above.
So that we can offer you the best service throughout your relationship with us (either now or in the future), we will hold your personal information securely in our systems. This will include any information provided by you or others (for example, if you’re making a joint application) in various ways, including (but not limited to):
- In applications, emails and letters, during telephone calls and conversations in our offices, when registering for services, in customer surveys, when you participate in competitions and promotions when using our company websites, and during financial reviews and interviews
- From analysis (including the creation of profiles used to uniquely identify you when you use our online, mobile and telephony services) which are used to help us combat fraud and other illegal activity
- Information CMME receives from other organisations (for example, credit reference agencies, mortgage lenders, insurance companies, comparison websites, social networks, and fraud prevention agencies) whether in the course of providing products and services to you or otherwise, and from information we gather from your use of and interaction with our websites and the devices you use to access them.
Updating your details
If you tell us about changes to your personal details, we will update the records we hold about you. If you’ve opened an account or policy with another organisation that we introduced you to, you will need to contact them personally to make updates.
When you make an enquiry with us about any of the services we offer, we will ask you to provide some contact information. This may include some or all of the following:
- Full name
- Previous names
- Current home address
- Previous residential addresses
- Date of birth
- Landline and mobile phone number
- Email address.
If you apply for a mortgage or protection policy through us, we will ask you for direct debit details to pass onto your chosen lender or insurer so that they can collect your mortgage or insurance premium payments.
If the product you’ve applied for carries a cost (for example, mortgage valuation fees or lender product fees you choose to pay upfront) we will ask you to provide payment information such as your debit card or credit card details.
Your card details will be passed to mortgage lenders for fees that have been disclosed to you, and you have agreed to pay. Once the payment details have been passed to the lender they will no longer be held in any format by CMME.
For products such as insurance, we will need to collect and process information that the General Data Protection Regulations define as “special categories”. This includes details about your health and any criminal convictions you have. If we need to ask for anything like this, we will always explain what information we require and why. We will always process and store this information securely.
If you give personal information about someone else (such as a joint applicant), then it’s really important to make sure you have their permission to do so.
Using our website
CMME is the sole owner of the information collected via our website (www.cmmemortgages.com) and also the sole owner of any information you provide in relation to an enquiry when you speak to one of our agents.
Your data together with that of other CMME users may be aggregated for analytical purposes. At no time will your data be individually identifiable in such analysis.
Details we collect about how you use our website
When you visit our website or use our online services, we collect certain data automatically. This may include (but isn’t limited to) the following:
- How you connect to the internet (including your IP address)
- How you use our site, for example, your screen resolution and browser data stored on your device (such as cookies)
- Information about the device software you use, such as your internet browser
- Location data such as the city or region of the IP address you used when accessing our online services.
Recording phone calls
So that we can offer you the best possible service, we may monitor or record our phone calls with you. This helps us check we’ve done what you asked us to do correctly, resolve any queries or issues and train our staff to provide a quality service. We also monitor phone calls for regulatory purposes and to help detect and prevent fraud and other crimes.
How we use your information
We will need to use your information to accept you as a new or returning customer.
Confirming your identity and verifying the information you provide
When any of our customers apply for a product, the law requires us to check their identity. This makes it harder for criminals to use financial systems, or to use false names and addresses to steal the identities of innocent people. Checking everyone’s identity is an important way of fighting money laundering and other criminal activities.
To confirm that you are who you say you are, we will 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 in this way, we may ask you to provide us with other documents to confirm these details.
- TransUnion for identity checking – Subject to your permission, we share information with TransUnion to verify your identity. TransUnion may share that with other lenders and organisations to help them perform credit checks, trace you and recover any money you owe. More information can be found on TransUnion privacy notice here – https://www.transunion.co.uk/legal-information/bureau-privacy-notice
Improving how we support you
We use your information to provide and improve the support we offer. If you are a returning customer, this will make it easier for you to provide information, as you only provide information that has changed.
Telling you about other products you may be interested in
We will use your details to identify other products and services we offer that we believe you might want to know about – but only where we have your consent.
If you no longer wish to receive such information from us, you can update your preferences by writing to us, giving us an email, or a call. We will update your preferences straightaway.
We sometimes run prize draws, competitions, promotions, and surveys. If you take part in these promotional activities, we will use the personal data you provide us with for these activities.
Fraud investigation, detection, and prevention
We may use your information for fraud investigation, detection and prevention measures and in order to provide suitable security for your account and your information that we hold (such as to enable us to prevent others logging in to your account without your permission from unknown.
Investigation, detection, and prevention of crime
We may use your information for the investigation, detection, and prevention of crime (other than fraud).
Training our staff
To ensure you have the best possible experience when you contact us, we will use your information to ensure our team has the knowledge and expertise to meet your needs.
Reporting and analytics
Knowing more about who our customers are can help us improve the products we offer. So we will use your data for reporting and analytical purposes – for example, looking at how many of our customers are in the north or south of the country.
Tracking activity to improve our service – and protect your information
Collecting data on how you use our websites helps us to better understand your interests. It can also help us detect if someone else is trying to access your account or use the services that we’re providing you. By building a clearer picture of how you interact with us, we can help make sure we’re offering you our best service.
Maintaining our records
Like any business, we need to make sure we keep comprehensive and up to date records of the ways we process your information – along with the day-to-day administrative tasks that go into running our business.
Resolving complaints and disputes
Our goal is to make sure all our customers are happy with our service, but we’re only human. So if you do make a complaint, we will use the information we have about you to help us resolve things for you.
Complying with the law
As you might expect, the law requires us to comply with lots of regulations – including ones about processing customer information. Where necessary, we use your personal data to allow us to fulfill our legal requirements.
Improving our communications by tracking emails
We want to make all our communications as useful to you as possible. To achieve this, we may use performance tracking technology within our emails to capture information including (but not limited to) the time and date you open our emails and the type of device you used to open them.
The first thing these details allow us to see is whether our emails are opened, and what links our customers click on within them. Then we use this information to improve the emails we send to you and the services we provide.
We may share this information with other organisations (for example, mortgage lenders) to help them improve their own interactions with you. Rest assured that we won’t pass your data to any third parties for marketing purposes unless you have an existing relationship with them. You won’t receive any marketing emails from them unless you’ve given them your consent to contact you in this way.
Using social media
Like every business, we want to understand our customers even better. To do this, we may research what people are saying about us in public comments made on social networking sites such as Twitter and Facebook.
To save you time, if you’re an existing customer applying for a new product, we may speed up the new account opening process by pre-filling application forms with the information we already hold about you.
If we ever have to use your personal information for any purposes that we haven’t described in this policy, you’ll hear from us. We will let you know exactly what we will use it for before we go any further and, where appropriate, obtain your consent.
Legal grounds for handling personal information
Data protection laws require that to process your personal data, we must meet at least one prescribed condition for it. We rely on the following conditions for the activities we carry out:
Necessary for performance of a contract or to comply with the law
In most cases, you’ll provide the information we ask for because you want to use our services. This means that our use of your information is governed by contract terms. It’s your choice to give us this information. If you choose not to, we may not be able to provide the services you want.
This condition is one we rely on for data processing in the following scenarios:
- Enabling you to access our website and use our services
- Confirming your identity and verifying the information you provide
- Providing and improving customer support
- Sending you service communications
- Responding to your enquiries and complaints
- Providing you with products and services and keeping you up to date with important changes and developments to their features and how they work
- Managing offers, competitions, and promotions
- Carrying out financial reviews
- Understanding your requirements
- Assessing risks
- Updating, consolidating and improving the accuracy of our records.
Where we collect other information from you – or when third parties do so for us – we always ask for your consent first. For example, before you use our website you’ll be asked to consent to us using cookies to collect data about the device you’re using. If you don’t want to give consent, or you remove your consent at a later point, we may not be able to provide all the services you want.
We also seek your consent in the following scenarios:
- Marketing – To help you explore all your options, from time to time we’d like to let you know about products, services and offers from CMME
- Market research – We invite you to participate in market research (more on this below). Any feedback you provide is used with your consent.
Administering prize draws, competitions, surveys and other promotional activities necessary in our legitimate interests or those of a third party.
In the United Kingdom, organisations can use personal information where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals. The law calls this the “Legitimate Interests” condition for processing.
We rely on this condition for processing personal data for the following benefits:
Helping to prevent and detect crime such as fraud and money laundering – Fraud and money laundering cost the British economy billions of pounds every year. This cost ultimately reaches the public in the form of higher prices. We can help stop this from happening by using your personal data to avoid fraud and identity theft.
Complying with legal and regulatory requirements – We must comply with various legal and regulatory requirements. And the services we provide also help other organisations comply with their own legal and regulatory obligations. For example, CMME is regulated by the Financial Conduct Authority, who may require us to provide information to them as part of our regulatory responsibilities.
Training our staff – To offer you the best possible standards of service, we use the information we collect to train our staff so they can better meet your needs.
Marketing services – Like any commercial organisation, we run a business and – where necessary – process information that helps us do this. We’ve put in place various safeguards to make sure that the individuals whose personal information we handle are not disadvantaged by the activities we use their personal data for. These include making sure people can access the information they need to understand how their personal data will be used by us. We also try to make sure people are aware of the rights they have to obtain the information we hold and to have their information corrected or restricted – and how to complain if they’re unhappy.
Reporting and analytical purposes – Processing personal information helps us analyse the service we’re providing and spot ways to improve.
Tracking activity – Understanding how people use our website or get in touch with us helps us to improve our services.
Maintaining our records and other administrative purposes – We always strive to provide the most accurate information to our customers and clients.
Resolving complaints and disputes – If you have a reason to make a complaint, we will use your information to help us look into things for you.
Improving data accuracy and completeness – When you register for our services you may give us additional information about yourself. We will use this to improve the accuracy and completeness of our data.
Email Tracking – This helps us to improve our communications to our customers.
Invitations to take part in market research – To make the service we offer even better, we may ask you to take part in market research. It’s entirely up to you whether you chose to do so.
Who we share your personal information with
Because of the nature of our role as a mortgage adviser, we share the personal information you give us with people who need to handle it so that we can provide our services to you. If you were introduced to us by a 3rd party, we will update them about how your enquiry with us is progressing. And finally, we may also pass your personal information to fraud prevention agencies. This helps us keep our systems secure and – where necessary – protect either your or our best interests.
Here are the organisations that we may share your personal information with:
Suppliers – We use a number of service providers to support our business. They may have access to our systems and data so that they can provide services to us and/or to you on our behalf.
Resellers, distributors, and agents – We sometimes use organisations to help provide our products and services to you. They’ll have access to your data so that they can do this.
Public bodies, law enforcement, and regulators – The police, other law enforcement agencies, regulators, as well as public bodies such as local and central authorities can sometimes request personal information. This may be for reasons including:
- Detecting and preventing crime
- Apprehending or prosecuting offenders
- Assessing or collecting tax
- Investigating complaints
- Assessing how well a particular industry sector is working.
Lenders and Insurers – In some circumstances, we will share credit report information and personal information (such as your name and address) with lenders and insurers. This is for purposes that may include:
- Verifying that you’re eligible for the product you’re applying for
- Supporting you to complete your application to the lender (which may include pre-filling the application form on their website)
- Contacting you about credit and financial products and complying with any contractual, legal and/or regulatory obligations.
Estate agents / new homes agents – As part of your property purchase transaction, estate agents and new homes agents will contact us to establish progress of your mortgage application. In order to keep your transaction moving smoothly, we will give updates to your nominated contact at the selling agent’s office (as specified by you in the fact find).
Individuals – You can ask for a copy of the information we hold about you.
To fulfill our contractual obligations, we will also share your personal data with the following third parties:
- Mortgage Lenders
- Secured loan lenders
- Life Insurers
- The Source for building and contents insurance
- Lead suppliers (if you were introduced to us by a third party)
To help you benefit from the services of our expert partners, we will also share your personal data with the following organisations – but only with your consent:
- Premier Property Lawyers LLP Solicitors where you wish to take up a conveyancing quote
- Contractor Wealth Management for pension referrals
- ASC for a secured loan and bridging finance enquiries.
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 data with the following data processors where necessary to fulfill our services and regulatory obligations:
- iPipeline to provide life insurance quotations
- Twenty7Tec to provide mortgage illustrations
- Mailchimp to communicate with our customers and update consents
- Shred-IT to destroy our confidential waste
- CommVersion to provide webchat customer service facilities
- 4Com who provide our call recording software
- Mediahawk for call tracking
- Survey Monkey to conduct market research
Sharing information with these organisations allows us to better understand your needs and supply an efficient service.