PRIVACY AND COOKIE POLICY

Turtle Mortgages Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits these websites (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of each of Our Sites and you will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.

Details of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);

“We/Us/Our” means Turtle Mortgages Ltd, a limited company registered in England under company number 08130498, whose registered address is St Johns Court, 70 St Johns Close, Knowle, Solihull, B93 0NH.

2. Information About Us

2.1 Our Sites are owned and operated by Turtle Mortgages Ltd (15804362) which is registered in England and Wales, 6-7 Waterside, Station Road, Harpenden, England, AL5 4US.

2.3 Our Data Protection Officer is Kieran Stanbridge, and can be contacted by email at hello@turtlemortgages.co.uk by telephone on 01582 292391, or by post at 6-7 Waterside, Station Road, Harpenden, England, AL5 4US

2.4 Turtle Mortgages Ltd is an Appointed Representative of The Right Mortgage Network Ltd, which is authorised and regulated by the Financial Conduct Authority (FCA).

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. Our site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites, and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and we will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of our site, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of Cookies and similar technologies):

5.1 Name;

5.2 Business/company name;

5.3 Profession;

5.4 Contact information such as email addresses and telephone numbers;

5.5 Demographic information such as postcode;

5.6 IP address;

5.7 Web browser type, version, and device type;

5.8 Operating system;

5.9 A list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to;

5.10 Annual test results;

5.11 Customer data including contact information such as email address and telephone numbers, demographic information such as address and postcode, business details such as firm name and products you are interested in or are eligible to sell.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security, see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our/your legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;

6.2.2 Providing and managing your access to our site;

6.2.3 Personalising and tailoring your experience on our site and other media used by us;

6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);

6.2.5 Personalising and tailoring Our services for you;

6.2.6 Replying to emails from you;

6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in the footer of all emails or emailing hello@turtlemortgages.co.uk);

6.2.8 Market research;

6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes, which may include contacting you by email, telephone, text message, and post with information, news, and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

6.4 You have the right to withdraw your consent to Us using your personal data at any time and to request that We delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1 For no longer than it is necessary for us to fulfil our legal and regulatory responsibilities.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland,