Piccadilly Mortgages Ltd trading as Piccadilly Mortgages is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights.
For the purposes of the GDPR the data controller is Piccadilly Mortgages Ltd trading as Piccadilly Mortgages. Our contact details are 77 Camden Street Lower, D02XE80, 01 9072553, info@piccadillymortgages.ie.
When we refer to we/us, we mean Piccadilly Mortgages Ltd trading as Piccadilly Mortgages.
Please read this Privacy Notice carefully as this sets out the basis on which any personal data, we collect from you, or that you provide to us, will be processed by us.
Who are we?
Piccadilly Mortgages is an Irish impartial mortgage, life cover and pensions consulting company. Piccadilly Mortgages Ltd trading as Piccadilly Mortgages is a member of Brokers Ireland. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & protection, pensions and mortgage products. A full list of lending agencies with which we deal is available on request.
Our Data Protection Officer can be contacted directly here:
- Name: Tracy O’Sullivan
- Email address: tracyosullivan@piccadillymortgages.ie
- Phone number: 01 9072553
How do we collect your information and what information do we collect?
The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data.
Our organization collects personal data in the following ways, if you:
- request a service from us; make an enquiry about a mortgage or life cover or pension product, make an application for a mortgage, life cover or pension product.
- register with or use any of our websites or online applications.
- use our website/apps and it installs cookies or other tracking technologies onto your device.
- contact us with a complaint or query.
- apply for a position with us.
How do we collect your information and what information do we collect?
The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data.
What information do we collect?
The information we collect about you includes the following:
| 1. | Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline |
| 2. | Unique identifiers e.g.
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| 3. | Demographic details, age, gender, marital status, and mortgage requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. |
| 4. | Family and Beneficiary Data, e.g.,dependents, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant. |
| 5. | Employment information e.g.,role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history; This information is necessary for our Fact Find with our clients. |
| 6. | Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office. |
| 7. | Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain special categories of information, for example for example information about your personal characteristics (biometric information) or disability information or any health information which may impact on your ability to pay your mortgage in the future, or which may categorize you as a vulnerable client. |
| 8. | Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, PAO. These may be required in the event that you wish to extend the term of your mortgage beyond your normal requirement age or if we are reviewing the suitability of your current protection and pension in place. |
| 9. | Financial details e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, thirdparty deductions, bonus payments, benefits and entitlement data, national insurance contributions details, gift donation details. |
| 10. | Claims Data (from you and any relevant third parties) – in the event that you wish to use the proceeds of a claim to fund the purchase of your new home, we will require to collect confirmation in relation to your claim proceeds. |
| 11. | Marketing preferences: we will only send you direct marketing if you explicitly consent. |
| 12. | Online information: e.g., information about your visits to our websites; We may obtain information about your general Internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits so that you can access information in a faster and more efficient way. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the website can “remember” you on your return visit. Generally speaking, cookies do not contain personal data from which you can be identified, unless you have separately furnished such information to the website. Some of the cookies we use are essential for the website to operate. For more information on how to manage cookies, including how to disable cookies please visit: www.aboutcookies.org. |
| 13. | Events information – information about your interest in and attendance at our events, including provision of feedback forms. |
| 14. | Social media information (e.g., likes and posts) with our social media presence; this includes, LinkedIn, Facebook and Instagram. |
| 15. | Criminal records information – confirmation in relation to whether you have received a formal police caution in the past 5 years, ever been convicted of, or have any prosecutions pending will be required from you. |
| 16. | Searches that we undertake to identify if you are a client/investor meeting the definition of a ‘politically exposed person’ (PEP), or the PEP’s immediate family member or associate as such terms are defined in the section 37 of Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended by the Criminal Justice Act 2013 and Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 (‘regulatory requirements’). We will carry out these searches via publicly available information. |
| 17. | Calculators on our website. We use this data to perform calculations to prepare quotations for mortgages. We only collect your proposed mortgage amount, mortgage term and interest rate. No other details are collected. |
When our organization collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and we have your explicit consent and/or authorization prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.
Information we automatically collect
We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent. Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page.
How do we use your personal data?
Your Personal Data will be used to enable us to fulfill our contractual obligations in relation to your request for mortgage enquiry quotes, mortgage applications and life insurance referrals.
| 1. | Performing services for our clients and prospective clients – when you require mortgage/insurance/investment/pension products, we use your data to enable us to provide the required product. |
| 2. | Statutory and other regulatory requirements – we are required to carry out various obligations which include:
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| 3. | Communicate and marketing to you – communicate by email, phone call and text message. We will email you based on your chosen email. We generally recommend to use your personal email as opposed to your work email. |
| 4. | To contact you if required or to respond to any communications that you might send to us. |
| 5. | To administer our site including data analysis, testing, research, statistical and survey purposes. |
| 6. | Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request. |
| 7. | Provide professional services for mortgage, life & protection and pension advice based solely on the undertaking of the lender and partners that we work with. |
| 8. | Handling complaints – please contact us for our complaints handling procedure. |
| 9. | To notify you about changes to our service. |
Legal Basis
We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data.
| Performance of a contract | When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service. |
| Legal obligation | The use of some of your personal data is necessary for us to meet our legal obligations e.g., Regulatory purposes to the Central Bank. |
| Consent | We rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data in relation to any criminal convictions or alleged offences in order to share this information with a bank for the purpose of applying for a mortgage. Or used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers.
Sometimes if you refuse to provide information that we reasonably require to provide our services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect. We also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely. We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time. We also rely on your consent to contact you 12 months after your mortgage funds have issued/end date of our contract. This would be required in order to inform you of any appropriate mortgage offers which we would deem suitable for you. This would also be required in order to review your mortgage when you are coming to the end of your fixed rate mortgage term, if you chose a fixed rate mortgage term. Although, we would generally not contact you after 6 years from our contract end date on the basis that 6 years is how long we are only required to retain your information. |
If you require further information on any of the above basis for processing your data, we can provide you with further details.
How we share your data
When required, we may make your information available to third parties with whom we have a relationship, where that third party is providing services on our behalf. We will only provide those third parties (data processors) with information that is necessary for them to perform the services. We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements.
| 1. | Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster. update as required. You can refer to their privacy statements on their website for more information about their privacy practices. |
| 2. | Legal advisers, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature. |
| 3. | Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity. |
| 4. | Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers. These processing operations remain under our control, and we have data processing agreements in place with all our third party processors to ensure all processing is carried out in accordance with our security standards and the GDPR. |
| 5. | External auditors where necessary for the conduct of company audits or to investigate a complaint or security threat. |
| 6. | On the sale or re-organization of our business whether by asset or share disposal or other transaction relating to our business. |
Security
The security of your personal data is important to us, we have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk. We have processes in place to protect your personal data from loss, unauthorized access, misuse, alteration and destruction.
Retention
Piccadilly Mortgages Limited trading as Piccadilly Mortgages shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary. In general, this period is 6 years after our relationship ends.
Piccadilly Mortgages Limited trading as Piccadilly Mortgages may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.
Personal data will be disposed of securely.
Data Subjects Rights
Piccadilly Mortgages Limited trading as Piccadilly Mortgages will facilitate your rights in line with our data protection policy and the Subject Access Request procedure. This is available on request.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. (The erasure of such data will be dependent on our other legal obligations, and whether the data is subject of legal privilege).
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling.
- Right to make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why.
All the above requests will be forwarded on, should there be a third party involved, as we have indicated in the processing of your personal data.
Complaints
If you wish to make a complaint about how your personal data is being processed by Piccadilly Mortgages Limited trading as Piccadilly Mortgages or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer.
You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are:
Address: 21 Fitzwilliam Square South, Dublin 2., D02RD28
Web: www.dataprotection.ie
Email: info@dataprotection.ie
See website for updated contact details to reach the appropriate section within the DPC.
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
When you fail to provide us with information, we require to fulfil our obligations to you, we may be unable to offer our services to you.
Profiling – automatic decision making
An automated decision is when we input your personal data into a computer programme and this programme analyses your personal data to provide us with a result. There is no human involvement in the decision making. An example of this is when we produce quotes for the business you are contacting us for. If a decision is taken by automated means, you have the right to object to this and ask us to reconsider the service you have asked us to provide. Some further examples of automated decisions that we undertake are listed below.
An example:
Financial and mortgage advisors using profiling in their business. The main categories are:
a) Risk profiling
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product
d) Bankruptcy check (where publicly available)
e) PEP check (where publicly available)
a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
b) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above we run automated queries on our computerized data base to establish the suitability of proposed products or services to your needs.
c) Establishing affordability and providing quotations for financial services products.
Special Categories of personal data
Special categories of data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals.
If we collect any special categories of personal data, such as health data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data.
These measures relate to the below:
- A policy of insurance of life assurance
- A policy of health insurance or health related insurance
- An occupational pension, a retirement annuity contract or any other pension arrangement
- The mortgaging of a property
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01 90272553 or email tracyosullivan@piccadillymortgages.ie.
Privacy notice/statement changes
When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.