Company Privacy Notice
Last Updated: 1st July 2019
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 (Dynamo for Intermediaries 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:
6 Caldecotte Lake Business Park
The Buy to Let Business trading office is located at:
The Buy to Let Business services most major lenders and the general public via the following business units/divisions.
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 services via a suite of websites and other means.
Types of Information Collected
Typically The Buy to Let Business collects:
*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:
- Next of kin
- Spouse/partner/family member
- Business Associates
- Trusted” sources including:
- - Government/land/police registers
- - Credit/default agencies
- - Financial institutes (banks, building societies, loan agencies, credit card companies)
- - Insurance companies
- - Other law firms
- - Health providers
- Through consent to third parties disclosing information about you to us that they have collected
Such 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
- 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.
- Developing new products and services
- Managing communications, assess effectiveness and optimisation of advertising
- Functionality of our websites and other digital assets
- Evaluate your interest in employment and contact you regarding possible employment opportunities
- Comply with industry standards and The Buy to Let Business policies
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:
- - Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
- - 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.
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.
- 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 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 at any time tell us not to send you marketing communications by:
- e-mail “[email protected]”
- unsubscribing via the “unsubscribe link” within the marketing e-mails you receive from us, or
- contacting The Buy to Let Business as indicated below.
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.
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
_utma 2 years
_utmb Less than a day
_utmc End of session (Date not set)
_utmz 6 months
This website carries embedded ‘share’ facebook buttons to enable users of the site to easily share articles with their friends through Facebook.
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)
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)
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
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 [email protected]
Or write to us at:
Ying Tan – Local Data Protection Officer
The Buy to Let Business
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.