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Privacy Policy

The Buy to Let Business is committed to protecting the privacy and confidentiality of information provided by its customers and upholding data protection principles.

The Buy to Let Business privacy notice provides information on how The Buy to Let Business and any of its third party providers collect, use, secure, transfer and share your information. The Buy to Let Business and its affiliates (Buy to Let Club, Countrywide Mortgage Line and The Good Mortgage Company) is a leading provider of residential and investment mortgages, pure protection and general insurance.

The Buy to Let Business head office is located at:

88-103 Caldecotte Lake Drive

Caldecotte

Milton Keynes

Buckinghamshire

MK7 8JT

The Buy to Let Business trading office is located at:

Building Eight

Watchmoor Park

Camberley

Surrey

GU15 3YL

 

The Buy to Let Business services most major lenders and the general public via the following business
units/divisions.

Financial Services Marketing
This division includes the UK’s largest specialist buy to let brokerage and also offers expert advice on pure protection. The Buy to Let Business markets its services via a suite of websites and other means.

 

Types of Information Collected

Typically The Buy to Let Business collects:

1. Forename(s) 2. Details of personal/secure loans 3. Bank statements*
4. Surname 5. Existing mortgage details 6. Mortgage statements*
7. Date of birth 8. Existing insurance details 9. ASTs*
10. Gender 11. New property details 12. Proof of deposit*
13. Nationality 14. New mortgage details 15. Payslips &/or P60*
16. Telephone number(s) 17. New insurance details 18. Self-employed accounts*
19. Email address 20. Solicitors details 21. SA302s & SA100s*
22. Current address 23. Doctors details 24. Tax Year Overviews*
25. Residential status 26. Employers name 27. Details of mortgages/loans refused
28. Previous addresses 29. Employers address 30. Details of any repossessions
31. Marital status 32. Salary 33. Personal expenditure
34. Number of dependents 35. Previous employers details 36. Details of personal debt
37. Dependents date of birth 38. Health 39. Credit/debit card details
40. NI number 41. Primary ID* 42. IP address
43. History of adverse credit 44. Address ID* 45. Cookies

 

*Copies will be taken of the original document and stored on file in line with the retention period detailed.
We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, or visit our websites, pages or other digital assets.
The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytic services on our websites. The analytic providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites.
“Your Rights and Choices” section of this Privacy Notice specifies your ability, to opt in or limit the usage of the information collected.

 

Methods of collection

In the general conduct of business, The Buy to Let Business collects information relevant to the services being
sought across the range of services offered (listed previously) from:

• Yourself
• Next of kin
• Spouse/partner/family member
• Business Associates
• Employers
• “Trusted” sources including:
o Government/land/police registers
o Credit/default agencies
o Financial institutes (banks, building societies, loan agencies, credit card companies)
o Insurance companies
o Other law firms
o Health providers
• Through consent to third parties disclosing information about you to us that they have collectedSuch information will generally be collected directly via the use of our standard forms, over the internet, via
email or through a telephone conversation with you. We may also collect personal information through our
affiliates or suppliers.
 

In addition, you may choose to submit information directly to us via several methods, including:

• The Buy to Let Business and affiliate websites
• In response to marketing or other communications
• Social media
• Signing up for a product of service with The Buy to Let Business
• Through participation in an offer, program or promotion
• In connection with an actual or potential business or employment relationship with us
 

You may also agree to third parties disclosing information about you to us which those third parties have
collected.

Purposes of collection

Generally, we will collect, use and hold your information for the purposes of:

• Assessing applications and providing The Buy to Let Business products/services
• Conducting business, developing relationships with The Buy to Let Business and affiliates
o Process payments/transactions including: Accounting, Authorisation, Clearing, Chargebacks,
Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities
• Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax
evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity,
compliance and security of business processes
• Create and manage any accounts, associated authentication criteria (ID’s and passwords) you may have
with The Buy to Let Business
• Provide, administer and communicate with you about The Buy to Let Business products, services, offers,
programs and promotions, their issuers, acquirers, retailers and partners.
• Compile business directories, including business contact information
• Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other
digital assets and business.
o Developing new products and services
o Managing communications, assess effectiveness and optimisation of advertising
o Functionality of our websites and other digital assets
• Evaluate your interest in employment and contact you regarding possible employment opportunities
• Enforce The Buy to Let Business “Terms of Use”, other legal rights as may be required by applicable laws
and regulations or requested by any judicial process or governmental agency having or claiming
jurisdiction over The Buy to Let Business or its affiliates.
• Comply with industry standards and The Buy to Let Business policies

 

Anti-Money Laundering

In addition, to help you with a property related service we have to comply with certain regulations. For example
the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
(referred to as the Regulations). The information provided will only be used by The Buy to Let Business in relation
to complying with the Regulations and will not be shared with any other party unless we are required to do so
under law.

If you decide to enter in to a business relationship with The Buy to Let Business we will require a minimum of
two separate identification documents; one primary and one secondary document (even if it appears on both
lists). The information may be required at various stages of the process depending on the service being provided.

Primary documents – proof of ID

• Valid Passport with MRZ
• Valid full UK photo driving licence
• Valid full UK Driving licence (Non photo, paper) issued before 1998
• Valid EU/EEA/Switzerland photo driving licence
• Valid EU/EEA/Switzerland national Identity Card
• Valid UK Armed Forces ID Card
• Valid UK Biometric Residence Permit
• Department for Works & Pensions letter confirming pension details including National Insurance Number
dated within the last 12 months

 

Secondary documents – proof of residence/address

• Valid full UK photo driving licence
• Valid full UK Driving licence (Non photo, paper) issued before 1998
• Local authority council tax bill (dated within the last 12 months)
• UK Bank / Building societies statements/bills showing activity, dated within the last six months Including
account number and sort code
• UK mortgage statement (dated within the last 12 months)
• Utility bill dated within the last 3 months including – Electricity bill (with MPAN number), Landline, Gas,
Satellite TV, Water (Not mobile phone bills)
• Her Majesty’s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement (dated
within the last 12 months) with National Insurance number
• Department for Works & Pensions letter confirming pension details and NI Number. (Dated within the
last 12 months)

 

We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search
will show as a soft search on your credit report, but will not affect your credit rating.

 

Lawful basis of processing

The Buy to Let Business processes your information under the following lawful basis:

• Performance of a contract: where you enter into a contract with The Buy to Let Business and we need
to process your information as part of this contract

• Legitimate interests: some information is processed by The Buy to Let Business as part of its legitimate
interests which include: Fraud, risk assessment, due diligence, network and information security,
suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web
analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and
other core products and service provided by the data controller

• Public interest: some information is processed in accordance public interest such as relocations

• Consent: where we process information under consent we will seek you clear and unambiguous
consent prior to processing your data

 

Information we share

We do not sell or otherwise disclose personal information we collect about you, except as described in this
Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information
we collect with, but not limited to:

• Vetted affiliates and partners (including Countrywide Plc) / Financial Institutions / Insurance Companies for
business facilitation to provide required services, such as mortgages, insurance cover etc.
• Formally contracted service providers to perform services on our behalf:
o Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as
a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
o Helpdesk, Call Centres etc.

We contractually require these service providers to safeguard the privacy and security of personal information
they process on our behalf and authorise them to use or disclose the information only as necessary to perform
services on our behalf or comply with legal requirements

• Councils, health and care providers
• Other Law firms
• Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs (HMRC), Financial Conduct
Authority (FCA) and other relevant regulatory bodies
• Additionally, we may share information about you, if required legally, to prevent harm or financial /
reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
• Perspective employers requesting references via your written consent

On websites, features can be accessed where we partner with other entities that are not affiliated with The Buy to Let Business. These include social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features.

The Buy to Let Business reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect / use your information consistent with our Global Privacy Notice. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.

 

How long do we keep information for?

We will keep information for a reasonable amount of time in order to perform the purposes listed above.

We only keep your information for as long as necessary. We generally keep personal information for 7 years
after last contact with you. However The Buy to Let Business reserves the right to keep information for longer if we feel that this is in the legitimate interests of The Buy to Let Business.

 

International data transfers

The Buy to Let Business may transfer the personal information collected about you to recipients in countries
other than the country in which the information was originally collected. Those countries may not have the same
data protection laws as the country in which you initially provided the information. When we transfer your
information to other countries, we will protect that information as described in this Privacy Notice or as
otherwise disclosed to you at the time the data is collected.

We currently engage a company called WNS who are based in India. We have ensured that WNS meet the
required privacy and security requirements through our contract with WNS. You can find out more about WNS here.

 

Profiling

For the purposes of business conduct, enhancement, identification of fraud, money laundering and other
potential un-authorised activities, The Buy to Let Business engages profiling activities via direct use or
anonymisation of sensitive personal information.

 

Direct Profiling

Direct profiling is engaged for the fair and lawful purposes, to provide The Buy to Let Business the ability to
enforce The Buy to Let Business “Terms of Use”, legal reporting as may be required by applicable laws,
regulations, policies/standards or requested by any judicial process or governmental agency having or claiming jurisdiction over The Buy to Let Business or its affiliates; including, but not limited to:

• Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement
plans, promotions and awards.
• Background checks for existing and new employees, clients, business partners, affiliates
• Financial viability analysis/reports
• Business partner/client portfolio position, performance, risk positions
• Anti-money laundering
• Tax reporting
• Credit defaulting/exposure

 

Indirect profiling

Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated
data reports showing anonymised information, including, but not limited to, the following:

• Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the
purpose of advising our partners/affiliates and servicing institutions, retailers and other customers
regarding past and potential future patterns of service usage, spending, fraud, and other insights that may
be extracted from this data.

• Compiling and communicating promotional and marketing information about products and services that

The Buy to Let Business, affiliates and other organisations that we have affiliations with have and that may
be of interest to you..
• Conducting market research.
• Facilitating our internal business operations, including the fulfilment of any legal requirements..

 

Your rights and choices

Your rights regarding the sensitive/personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.

 

Access and correction

You may have the right to:

• obtain confirmation that we hold personal information about you
• request access to and receive information about the personal information we maintain about you
• receive copies of the personal information we maintain about you

The right to access personal information may be limited in some circumstances by local law requirements.
To exercise these rights, please contact us as set forth below.

 

Update and correct inaccuracies in your personal information

If you feel that the information we hold about you in incorrect or inaccurate you can contact us outlining the
information you feel is incorrect of inaccurate.

If we refuse to correct your personal information, we will provide you with a written notice that sets out the
reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a
statement regarding the mechanisms available to you to make a complaint. We will provide you with access to information we hold about you:

 

Object to the processing of your personal information

If you would like to object to any processing of your information by The Buy to Let Business you can contact us outlining what processing of information you would like to object to.

 

Have information blocked, anonymised or deleted

If you would like The Buy to Let Business to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised.
To update your preferences, ask us to remove your information from our mailing lists or submit a request to
access, update, correct or delete your personal information, please contact us as specified in the “How to
Contact Us” section below.

 

Opt out of processing

You can opt out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However without cookies you may not be able to use all of the website features and/or online services.
The Buy to Let Business operate a cookie policy (please see below). Some of our service providers and partners may collect information about your online activities over time and across third-party websites to customise and target our adverts.

You can at any time tell us not to send you marketing communications by:

• e-mail “compliance@thebuytoletbusiness.com”
• unsubscribing via the “unsubscribe link” within the marketing e-mails you receive from us, or
• contacting The Buy to Let Business as indicated below.

 

Use of Cookies by The Buy to Let Business

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in
order to make websites work, or work more efficiently, as well as to provide information to the owners of the
site. The following explains the cookies we use and why.

A list of cookies used on this site follows. Please note that providers may change cookie names and expirations,
so you are advised to visit their privacy pages for further information.

Essential Site Cookie

Every time our site is visited, a cookie is used to hold the unique session ID. This cookie is deleted when you
close the browser.

Name Expires
PHPSESSID When user exits browser

 

Google Analytics Cookies

These cookies are used to collect information about how visitors use our site. We use the information to compile
reports and to help us improve the site. The cookies collect information in an anonymous form.

A – stores each user’s amount of visits, the time of the first visit, the previous visits, and the current visit. B&C –
are used to check approximately how long you stay on a site, when a visit starts and ends. Z – Store where a
visitor came from (search engine, search keyword, link). To opt out of being tracked by Google Analytics across
all websites visit:http://tools.google.com/dlpage/gaoptout

Name Expires
_utma 2 years
_utmb Less than a day
_utmc End of session (Date not set)
_utmz 6 months

 

Facebook Cookies

This website carries embedded ‘share’ facebook buttons to enable users of the site to easily share articles with their friends through Facebook.

Name Expires
Datr 2 years
Lsd End of session (Date not set)
reg_ext_ref End of session (Date not set)
reg_fb_gate End of session (Date not set)
reg_fb_ref End of session (Date not set)

 

Twitter Cookies

Twitter may use both session cookies and persistent cookies to improve their service including understanding user interaction, monitor aggregate usage and webs traffic routing.
Twitter’s privacy policy page.

Name Expires
K 7 days
guest_id 2 years
original_referer End of session (Date not set)
external_referer 1 day
_twitter_sess End of session (Date not set)

 

LinkedIn Cookies

LinkedIn cookie, introduced by the LinkedIn share button. Used to track which pages the user visits to collect them. For more information visit Linkedin’s privacy policy page.
LinkedIn’s privacy policy page.

Name Expires
leo_auth_token Less than one day
JSESSIONID Date not set
bcookie 730 days
Visit 730 days
PersistenceCookie Less than one day
NSC_MC_QH_MFP Less than one day
lang Date not set
leo_auth_token Less than one day
NSC_MC_WT_DTQ_IUUQ Less than one day

 

Stumble Cookies

Stumbleupon cookie, introduced by the Stumbleupon submitter button, used to enable uses of the site to
easily share a link to the current page via StumbleUpon. For more information visit: http://www.stumbleupon.com/privacy/

Opting out of cookie usage

If you want to control which cookies you accept, you can configure your browser to accept all cookies or to
alert you every time a cookie is offered by a website’s server. Most browsers automatically accept cookies. You
can set the browser option so that you will not receive cookies and you can also delete existing cookies from
your browser. You may find that some parts of the site will not function properly if you have refused cookies.
Most web browsers allow control of most cookies through the browser settings. To find out more about
cookies, including how to see what cookies have been set, how to manage and delete them: visit
http://www.allaboutcookies.org/

 

Withdrawal of consent

If we obtain your information by consent you have the right to withdraw any consent you previously provided to us.

If we process your information under legitimate interest you can object at any time on legitimate grounds, to
the processing of your personal information.

 

The Buy to Let Business will apply your preferences going forward. Doing so will mean that you cannot take advantage of certain The Buy to Let Business and affiliate products, services and promotions.

The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.

 

How to contact us/complaints and feedback

If you wish to make a complaint about a breach of your personal information, applicable privacy laws/principles, a concern about The Buy to Let Business privacy practices or would like access and/or to update information of preferences you to us, please email us at compliance@thebuytoletbusiness.com

Or write to us at:
Ying Tan – Local Data Protection Officer
The Buy to Let Business
Building Eight
Watchmoor Park
Camberley
Surrey
GU15 3YL

If we fall short of your expectations in processing your personal information, or you wish to make a complaint
about our privacy practices, please contact us via the details above.

To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.

If we are unable to complete your request due to lawful reasons we will explain this to you to the extent that
we lawfully can.

 

How we protect personal information

The security of your personal information is very important and The Buy to Let Business is committed to
protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

We use SSL encryption on a number of our websites from which we transfer certain personal information.

The Buy to Let Business stores personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it.

 

Updating this privacy statement

We will update this statement from time to time so we suggest that you review this statement at regular
intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you
directly about these changes.

March 2018