Privacy Policy

TWENTY7TEC – WEBSITE, PRODUCT AND SERVICE USER PRIVACY NOTICE

Introduction

The Twenty7Tec Group respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will tell you about to how we look after your Personal Data when you visit our website (regardless of where you visit it from) or use our products and services, and tell you about your privacy rights and how the law protects you.

Please also see the Glossary set out further below, which provides further detail on the meaning of some of the terms used in this Privacy Notice.

1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how the Twenty7Tec Group collects and processes its users’ Personal Data through your use of this website and our products and services, including any data you may provide to us when you:

• use this website, our products and our services (either directly or as an employee of a client);
• provide your contact details as a potential client (or an employee of a potential client);
• use our products and services via a third party (who will provide you with their own privacy notice);
• contact us to make a complaint; or
• contact us directly for another purpose.

This website, our products and our services are not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other privacy, data protection or fair processing information we may provide on specific occasions when we are collecting or processing Personal Data about you (including when we provide you with our products and services) so that you are fully aware of how and why we are using it. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

Controller

The Twenty7Tec Group (Group) is made up of different legal entities, currently including:

• Twenty7Tec Group Ltd (CRN: 08660235)
• The Big Blue Trading Company Limited (CRN: 07262973)
• MortgageSourceTec Ltd (CRN: 09135158)
• Lazy Dog Software Ltd (CRN: 10828154)
• Meet Parker Ltd (CRN: 13066663)

This Privacy Notice is issued on behalf of the Group so when we mention T7T, we, us or our in this Privacy Notice, we are referring to the relevant company in the Group responsible for controlling and processing your Personal Data where you have a direct relationship with us.

We have appointed a data protection champion (DPC) who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (as referred to further below), please contact us using the details set out below.

Processor for third parties

T7T also acts as a data processor in certain instances where it processes Personal Data on behalf of customers as part of its services and / or provision of its products. Where you have accessed our products or services via a third party (such as a lender or mortgage advisor) you should confirm with their privacy policy if they have provided your Personal Data to us as a processor for them or to us as a controller. Where we act as a controller this notice will apply but if we act as a processor then the third party’s privacy notice will apply.

In certain circumstances where we act as a processor for third parties, we may collect and process Special Categories of Personal Data about you in line with their instructions. This type of data includes certain health and lifestyle information, vulnerable individual information and smoker status. We may also collect a limited amount of information about criminal convictions and offences for specific and limited activities, such as to perform checks to prevent and detect crime, to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption. This will not include specifics about the criminal convictions and offences, but only if there is a known criminal conviction or not. We do this in accordance with the instructions of the relevant controller – please refer to their privacy notice for how your Personal Data is collected and processed (including the legal basis for such processing). Please note, it may not be mandatory for you to provide this information and you may still make use of the website, products and services without doing so.

Contact details

If you have any questions about this Privacy Notice (including any requests to exercise your legal rights) or our privacy practices, please contact our DPC or us at:

Email address: security@twenty7tec.com

Postal address: Suite A 7th Floor, Avalon Oxford Road, Bournemouth, England BH8 8EZ

Telephone number: 01202 553457

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), if you are concerned in relation to how we collect or process your Personal Data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review and any changes will be notified to you by posting an updated version on this site and / or by contacting you by email. Any changes will take effect immediately. We recommend you regularly check for changes and review this policy whenever you visit the website or make use of our products or services.

It is 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.

Third-party links

This website, our products and our services may include links to third-party websites, plug-ins, applications and social media platforms. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins, applications or social media platforms and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Our products and services may be provided in conjunction with or via third parties such as a lenders or mortgage advisors. The third party will confirm how they pass data to us. Where you have accessed services via a third party we will provide information to them that they require to deliver their services to you.

2. The types of Personal Data we collect about you

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier and title. This may include details of your employment if acting as an employee.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes payment methods, bank details and direct debit mandates.
• Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
• Technical Data includes 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, our products and our services.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use and interact with our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to produce statistical research and reports. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your Personal Data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, making use of our products and / or services or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
• enquire about, place an order for, or make use of our products or services;
• subscribe to our services or publications;
• request marketing to be sent to you; or
• give us feedback or contact us.
• From other employees. If your employer is dealing with us they may provide your details to us in order that we can deliver our services and products, or for you to engage with us.
• Automated technologies or interactions. As you interact with our website, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:
  • Technical Data is collected from the following parties:
    • analytics providers such as Google based outside the UK;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  • Identity and Contact Data is collected from data brokers or aggregators.
  • Identity and Contact Data is collected from publicly available sources such as Companies House based inside the UK.

4. How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Performance of a Contract – where we need to perform the contract we are about to enter into or have entered into (including with a third party for the benefit of you), where we supply you with access and / or use to our products and / or services or where you are in discussions with us about any new product or service or where we arrange for the supply of a third party’s products or services to you.
• Legitimate Interests – where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Legal Obligation – where we need to comply with a legal obligation. We will identify the relevant legal obligation when we rely on this legal basis. This includes when you exercise your legal rights under data protection law, for the establishment and defence of our legal rights and for compliance with legal and regulatory responsibilities that apply to us.
• Consent – we rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose. You can withdraw your consent at any time by contacting us on the details provided above.

Please see the Glossary and Lawful Basis sections of this Privacy Notice below to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one basis has been set out in the table below.

Marketing

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 will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing, or if you indicate via our website, products and services that you would like to receive marketing from us.

Third party marketing

We will get your express consent before we share your Personal Data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing messages at any time by following the unsubscribe instructions set out in the relevant communication, using the function within the relevant products or using the contact details above.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product or service purchase or order, product or service experience or other transactions.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table above:

• Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not 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 may share your Personal Data with third parties who have agreements with you for whom we act as a Data Processor. Where we act on this basis it is the third party who is the Data Controller and will confirm the basis of any Personal Data use.

6. International transfers

All information you provide to us is stored on our secure servers which are located within the UK.

We share your Personal Data within the Group.

Whenever we transfer your Personal Data out of the UK to countries which have laws that do not provide the same level of data protection as the laws which apply in the UK, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

• We ensure your Personal Data is protected by requiring all our group companies and independent contractors to follow the same set of rules when processing your Personal Data.

We may also transfer your Personal Data to service providers that carry out certain functions on our behalf. This may involve transferring Personal Data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your Personal Data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• the UK has decided that the country or the organisation we are sharing your information with will protect your information adequately; or
• we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the UK) to ensure your information is adequately protected. To obtain a copy of these contractual safeguards, please contact us at the details set out above.

7. Data security

We 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 are legally required to do so.

However, please note that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our products and services and any transmission is at your own risk. Once we have received any data, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given (or where you have chosen) a password which enables you to access the our websites, products and services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

8. Data retention

How long will you use my Personal Data for?

T7T has a separate Retention Policy that sets out our principles and approach to retaining and ultimately disposing of Personal Data which we hold across our organisation. A copy can be requested using the contact details above. However, the general retention principles for the purposes of this privacy policy are as set out below.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

If you have signed up to receive marketing from us, we will store your Personal Data for as long as you are subscribed to our marketing list. If you unsubscribe, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for whilst you continue to be a customer and for a period of six years after they cease being customers for tax purposes. However, if you cease to be a customer of T7T, we will retain your Personal Data in case of any queries from you or in case you decide to re-activate your account for a period of seven years from the date that the account is deactivated.

In some circumstances you can ask us to delete your Personal Data – see the Your Legal Rights section below for further information.

The only exceptions to the above are where:

• we may need your Personal Data to establish, bring or defend legal claims or to comply with a legal or regulatory requirement;
• the law requires us to hold your Personal Data for a longer period, or delete it sooner; or
• in limited cases, the law permits us to keep your Personal Data indefinitely provided we put certain protections in place.

To note, in some circumstances we will 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.

9. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

This website uses the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. The website cannot function properly without these cookies.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
• Embedded third party content. Some of the content on our website (e.g. videos) is provided by online services operated by third parties. When you visit a page containing content from one of these services, a cookie may be set by the relevant third party. We use YouTube to show some of our video content. YouTube may set cookies on your browser in order to display those videos and monitor non-attributable statistical information about your use of each video. Please see further information at YouTube’s privacy policy.
• Advertising cookies. We also use and work with a number of third party suppliers and partners who set cookies on this Website in order to deliver targeted advertising to you. Please see a summary of the third party advertising cookies used in the table below. If you would like more information about the cookies used by these organisations or would like to access a tool which you can use to disable them, please visit the Your Online Choices site at www.youronlinechoices.com/uk/your-ad-choices or click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies.

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. Please refer to the table below for further details.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/. Alternatively, you may wish to visit www.allaboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies. Please note that, as these websites are not owned or operated by us, we are not responsible for any of the content on them.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

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 are 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 are 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 are 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 are 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your Personal 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 will 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 are relying on consent to process your Personal Data. However, this will not 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 will 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 using the details set out above.

No fee usually required

You will not 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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your Personal Data where it is necessary for the performance of a contract or to take steps at your request pursuant to such contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

• Our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf (including those listed at: https://www.twenty7tec.com/sub-processors). Such third parties may include cloud service providers (such as hosting and email management), IT software or maintenance providers, data backup providers, advertising and marketing agencies, IT developers, data analysis providers, security services providers and administrative service providers.
• Lenders, banks and building societies that we work with in order to manage the mortgage sourcing and application services that we provide.
• Research companies if we undertake customer satisfaction surveys for the purposes of gathering general information and specific information relating to us and our products and services.
• Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK and EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
• Service providers acting for you in the provision of related services.

Last Updated: June 13, 2024