Privacy policy

Commercial Trust understands how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of the personal information we hold about you, and what we do with that information.

Commercial Trust may change its Privacy Policy from time to time.

The policy was last updated February 27th 2024.

Company details

• Telephone: 01603 896878
• Email: info@commercialtrust.co.uk
• Commercial Trust Limited is a company registered in England and Wales, company number 08633445
• Address: Norfolk Tower, 48-52 Surrey Street, Norwich NR1 3PA
• VAT number GB765353512
• Authorised and regulated by the Financial Conduct Authority (FCA) Reference no. 610175
• Registered with the Information Commissioner’s Office. Reference No. ZA041124

Data Protection Officer

You can contact our Data Protection Officer by telephone, email or post at:

Data Protection Officer, Commercial Trust Limited, Norfolk Tower, 48-52 Surrey Street, Norwich NR1 3PA

Telephone: 01603 896878

Email: dpo@commercialtrust.co.uk

Gathering information from you at initial enquiry

There are a number of ways contact between us may arise, these are described below.

Our website

You may choose to contact our company, having visited our website, in a number of ways.

Some of the ways data passes from you to us is handled using technology our company has built and controls, such as our website forms.

Other ways data passes from you to us may use technology we pay a third party to provide, such as our Live Chat interface.

These methods of contact are described below.

1. Enquiry form

By submitting an enquiry form you are agreeing to us contacting you via telephone, email, SMS and letter about your enquiry.

Changed your mind about hearing from us? See “Stopping attempts at contact” below.

Lender deals and landlord news

Before submitting an enquiry form, you will be asked whether you would like to be kept informed of lender deals and landlord news, with the option to receive this information via email, SMS, telephone or letter.

If you do not give your consent, you will not be sent this information.

If you do give your consent, you are giving us permission to send you this information via the channel(s) you have stipulated.

You can adjust your contact preferences or opt-out at any time by visiting our Contact Options form.

These consents do not affect any interactions you may have with our advisor team relating to the conduct of our service (see “Interactions regarding our service” below).

2. Call-back form

By submitting your details via our call-back form, which you may see on a number of pages on our website and is specifically identified as such, you are agreeing to our advisor team calling you on the number you have submitted to discuss our service with you (see “Interactions regarding our service” below).

Changed your mind about hearing from us? See “Stopping attempts at contact” below.

3. Email newsletter sign-up form

By submitting your details via our newsletter sign up form, which you may see on a number of pages on our website and is specifically identified as such, you are agreeing to our sending information about our industry to you via email.

Changed your mind about hearing from us? You can adjust your preferences or opt-out at any time by visiting our Contact Options form.

4. Email communications

We use a third party platform to facilitate the sending of some of our emails. The software is provided by a company called Spotler Limited, trading as Pure360, who operate as a Data Processor for Commercial Trust Limited. When you work with us, or subscribe to receive information from us, the following details are held on the Pure360 platform to enable us to send you process emails and informational emails (if you have opted to receive informational emails):

a) Your email address
b) Your first and last name
c) Your telephone number
d) Your marketing preferences

These details reside on Pure360 servers. Your data will not be transferred outside the European Economic Area unless; the receiving country has adequate protection in place; appropriate safeguards have been imposed and you have enforceable rights and effective legal remedies; or, you have given prior written consent, having been made aware of possible risks. Replies to emails sent to you come directly to Commercial Trust Limited only.

Wherever and however your data is processed, Pure360 adheres to processes and measures necessary to adequately protect your data.

For information on their data protection obligations, visit these pages of their website.

Copies of email correspondence between you and your advisor (if applicable) are saved on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

5. SMS communications

We use a third party platform to facilitate the sending of our SMS. The software is provided by a company called Commify UK Limited (trading as Text Anywhere) who operate as a Data Processor for Commercial Trust Limited.

When SMS communications are sent by us to you, or by you to us, they are handled by the Text Anywhere platform, this means that some or all of the following information resides on the Text Anywhere servers:

a) Your mobile phone number
b) Your first name
c) The message content

Your data is held in the UK and with the relevant countries network operators.

Wherever and however your data is processed, Text Anywhere adheres to processes and measures necessary to adequately protect your data. Your data is subject to the Text Anywhere retention period of 12 months; after which it is deleted from their platform.

For information on the security measure put in place by Text Anywhere, visit these pages of their website.

Copies of SMS correspondence between you and your advisor (if applicable) are saved on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

6. Live Chat

We use a third party platform to deliver our Live Chat service to handle customer enquiries in real time. The software is provided by a company called Click4Assistance.

When you interact with the Live Chat interface, the following details may be recorded by the Click4Assistance live chat service:

• Any data added to the Chat window
• IP Address (An IP address is a number sequence that identifies a device (not a user) that is connected to the internet. Some IP addresses are the same each time they connect to the internet, “Static IP” and some change each time “Dynamic IP”.)
• Language
• User Agent (technical data which includes device, browser etc.)
• Referral site, search engine, search keywords if you visited our Website from one of these types of web page
• URL from which you started your chat
• If you have reached our website as the result of marketing activity; our campaign code, traffic medium (e.g. paid search traffic, email traffic), campaign name, search keyword
• Number of visits
• Number of pages and which pages visited
• Device/Operating System/Browser
• Country, Region, City, Longitude/Latitude,
• ISP/Domain (all based on IP lookup)
• Any data you choose to send in attachments
• Any data you choose to send on any forms (pre-chat, survey, offline etc.)

If you use the Live Chat service and you request to speak to a member of our advisor team we may ask you for your name, telephone number and email address in order to arrange contact with our advisor team. This is optional.

The details of your Live Chat conversation reside on Click4Assistance servers. Click4Assistance servers are based in the UK. Your data will not pass outside the UK at any point as a result of using the Click4Assistance live chat service via our Website. Click4Assistance may use “sub-processors” (third parties) to help them in the conduct of providing their service.

Wherever and however your data is processed, Click4Assistance adheres to processes and measures necessary to adequately protect your data.

For information on how Click4Assistance secures the data that exists on the Live Chat platform, visit these pages of their website.

Your Live Chat conversation will also be passed to the advisor team so that they understand the nature of your enquiry.

Advisors usually save chat interactions with your client records on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

Telephone calls

All of our calls are recorded and may be monitored to resolve queries or complaints, improve our service quality and to detect or prevent fraud or other crimes. Telephone calls may also be monitored for staff training purposes.

SMS, Email, Letter or other correspondence

If you make your first enquiry with us via SMS, Email, Letter or any other means, we will attempt to call you to resolve your request.

This is because we have to have first-hand contact with you to conduct our service compliantly and we have to verify your identity.

Where you are engaged in ongoing dialogue with our staff, regarding a case we are handling for you, we keep copies of SMS, Emails and Letters between us, in order to efficiently and accurately conduct our service on your behalf.

Interactions regarding our service

If you have made an enquiry to our company regarding our broker service, we will attempt to contact you up to three times a day for seven days, to ensure we have made every effort to respond to your request for information.

Our team may use telephone, email, SMS or letter to contact you regarding our service.

Gathering information from you, beyond initial enquiry

What information do we collect from you?

During the enquiry/application process we will collect personal and financial information (including but not limited to):

• Name, address and postcode
• Employment type and income
• Contact information including telephone numbers and email addresses
• Date of Birth
• Address (residential history)
• Property details
• Credit history
• Details of existing credit commitments (including car finance and hire purchase)

We do not request or process ‘sensitive’ information (such as medical records) during the application process. If sensitive information is provided to us, we will ask for your explicit consent prior to recording it.

Legal basis for processing personal data

When we process your personal data, including performing credit searches with one or more lenders, we do so because this is required to progress your mortgage enquiry and potential mortgage application. Such processing is a requirement of the service you have requested.

How we use the information we collect from you

The information gathered is used to:

• Process your application
• Assess your needs and make an appropriate recommendation
• To keep your broker (if any) informed about the progress of your loan application
• Keep you updated on the progress of your application
• Electronically verify your identity
• Administer your application
• Record and respond to complaints
• Improve our services
• Statistical analysis, research and behavioural analysis.

Consequences of processing – credit decision

As your mortgage broker, we will discuss your personal circumstances with mortgage lender/s, in order to determine the most appropriate product for your needs. In order to make a recommendation we will complete a credit search with one or more lenders. These searches may be seen by other organisations searching in the future. Details of the search will be recorded whether you proceed with the application or not.

Legal basis for processing personal data – Anti fraud

When Commercial Trust process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with the laws that apply to us. Such processing is also a contractual requirement of the services you have requested.

We may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data, and if you are considered to pose a fraud or money laundering risk, they could hold your data for up to six years.

Consequences of processing – Anti Fraud

If fraud or money laundering is identified, details will be passed to fraud prevention agencies to prevent fraud or money laundering. If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or to employ you or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or employment to you. If you have any questions about this, please contact us on the details above.

How we check your identity

We will search credit reference agency files who, will provide details and information from the Electoral Register to verify your identity. The agency keeps a record of the search, whether or not your application proceeds with us. Our search is not seen or used by lenders to assess your ability to obtain credit in the future.

We may also request physical forms of identification to enable us to proceed with your application.

Information sharing with brokers and others who introduce business to us (if applicable)

If you have been introduced to Commercial Trust by a broker (intermediary) or someone else, we may tell that person about our contact with you, the progress of any mortgage application that you may make with our help, and whether or not any such application is successful. We may also tell them about relevant dates, the type of loan we have helped you with and the loan amount.

This will be for the purposes of establishing whether any payment may be, or become, due to that person (or someone associated with them), the amount and timing of any such payment, for assessing their effectiveness in identifying suitable clients for us, for monitoring our relationship with that person and shaping their future conduct in identifying and referring to us possible new clients). We will not pass on to them details about the nature of any help we may have given to you.

Our commitment to you about your personal information

We will treat all your information as private and confidential (even when you are no longer a client).

We will not give your data to anyone else unless we have your express consent, except where we are required to do so by a court or regulator, or where disclosure is made at your request or with your consent in relation to arranging your mortgage.

Your rights

Your personal data is protected by legal rights, which include your rights to:

• Object to our processing of your personal data
• Request that your personal data is erased or corrected
• Request access to your personal data.

Stopping attempts at contact

If you change your mind and are no longer interested in our service, you can:

• Tell our representative when they contact you

Or contact our Data Protection Officer using your choice of the following options:

Data Protection Officer

• Call 01603 896 878
• Email dpo@commercialtrust.co.uk stipulating your first and last name and the telephone number you supplied so that we can identify you and update our records
• Write to: Data Protection Officer, Commercial Trust Limited, Norfolk Tower, 48-52 Surrey Street, Norwich, NR1 3PA

Your right to erasure

In certain circumstances you have the right to have personal information erased. Any request for erasure will be dealt with in conjunction with our retention period table (below).

Accuracy of the data we hold about you

If you have reason to believe that the data we hold about you is inaccurate, please write to the Data Protection Officer at the address provided, detailing the error. We will promptly any information confirmed to be incorrect.

Future Marketing

If you have provided your consent, we will keep you informed of the latest products and industry news.

Future marketing contact may be made by letter, telephone email or SMS.

If you prefer not to be contacted by us, please e-mail your name, address and postcode to:

dpo@commercialtrust.co.uk or write to the Data Protection Officer informing us which communication channels you wish to restrict (i.e. telephone, text, e-mail).

If you wish to unsubscribe from all channels, please confirm that you wish to cease all future marketing.

Your right to access information that we hold about you (Subject Access Request)

Under General Data Protection Regulation, you have the right to have access to certain information we hold about you. Any request should be made to our Data Protection Officer.

There is no charge for submitting a Subject Access Request.

Upon receipt of a Subject Access Request Commercial Trust Limited has one month to respond.

Other technology we use on our website

Third party licences for code

To build parts of the functionality on the Commercial Trust website, our development team have used a variety of code libraries. The details of the authors and the copyright associated with these libraries can be found here.

Security of your data

Commercial Trust is committed to ensuring that your personal information is held securely. We have put in place various controls and procedures to protect and keep secure the information we collect online, on a recorded call or hold separately.

If you contact Commercial Trust you will be asked a number of security questions before we will discuss your application.

Questions about our privacy policy

If you have any questions or comments regarding our privacy policy, please contact our Data Protection Officer.

Your data - Retention periods / how we keep your data

Complaints

To register a complaint with Commercial Trust Limited, please click here to visit our complaint page.

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 (ICO).

To register a complaint with the ICO, please click here for additional information.