Privacy Policy – Mulberry

Mulberry PM Limited Data Protection and Privacy Policy Notice

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. This notice provides information on how we collect, use, secure, transfer and share your information.

Mulberry PM – 11 Walmgate, York, YO1 9TX

We may collect and use the following personal information about you:

First Name
Other Names
Surname
Date of Birth
Gender
Marital Status
Present Address
Email Address
Telephone Number(s)
Previous Name(s)
Previous Addresses
Number of Dependants
Dependants Name(s)
Dependants Date of Birth
Employers Address
Employers Phone number
NI Number
Payslips
Previous employers details
Bank Details
Bank Statements
Salary
Personal Expenditure
Accountant Details
Self Employed Accounts
Credit Card Statements
Personal/Secure Loan Details
Personal Debt Details
Mortgage Statements
Existing Mortgage Details
Existing Insurance Details
Residential Status
New Property Details
Landlord Details
Proof of Deposit
Solicitor Details
Nationality
Ethnicity
IP Address

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you. We will always request the minimum amount of data to enable us to deliver our services effectively.

Methods of Collection

In the general conduct of business, we collect information relevant to the services being provided by us from a number of sources:

yourself
next of kin
spouse / partner / family member
business associates
employers

Third party sources including:

government / land registers, including Companies House or HM Land Registry
credit / default agencies
financial institutes (banks, building societies, loan agencies, credit card companies)
insurance companies
through our professional advisors such as accountants or law firms
through consent to third parties disclosing information about you to us that they have collected
from cookies on our website

Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our branches 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:

through websites
in response to marketing or other communications
through social media
by signing up for a product or service
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 that those third parties have collected.

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, mobile applications, 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.

Purposes of Collection

Under data protection law, we can only use your personal information if we have a proper reason for doing so, including:

to comply with our legal and regulatory obligations
for the performance of our contract with you or to take steps at your request before entering into a contract for our legitimate interests or those of a third party
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

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

Assessing applications for and providing products / services
Conducting business, developing relationships with us and our 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 (ids and passwords) you may have with us
Provide, administer and communicate with you about our 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, mobile applications other digital assets
Evaluate your interest in employment and contact you regarding possible employment
Staff administration and to ensure safe working practices

Anti-money Laundering

In addition to helping 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’). We and other subsidiaries are required to obtain certain information from you to comply with the Regulations.

If required, we will require 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. We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search will not affect your credit rating.

Promotional Communications

We may, with your consent, use your personal information to send you updates (by email, text message, telephone or post) about our services, including offers, promotions or new products or services. We will always treat your personal information with care and never share it with other organisations for marketing purposes unless otherwise stated in this privacy policy.

You have the right to opt out of receiving promotional communications at any time by:

contacting us at info@mulberrypm.co.uk
using the ‘unsubscribe’ link in emails
contacting us at our head office

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described in this 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, consultants and partners / financial institutions / insurance companies for business facilitation to provide required services
Formally contracted service providers to perform services on our behalf
Helpdesk and Call Centres who help us to carry out our services. 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
Review and customer satisfaction specialists to seek customer opinion and feedback

Where your personal information is held

Information may be held at our offices and those of third-party agencies, service providers, representatives and agents as described above (see above: ‘Information we Share’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

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 in order to keep records required by law or to respond to any questions from you after we have completed our services.

Transferring your information out of the EEA

To deliver services to you, it may be necessary for us to share your personal information outside the European Economic Area (EEA), for example:

if your and our service providers located outside the EEA
if you are based outside the EEA

These transfers are subject to special rules under European and UK data protection law. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you would like further information, please contact our Data Protection Officer (see ‘How to Contact Us’ below).

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.

These rights are:

Access

You 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
object to how we use your data

The right to access personal information may be limited in some circumstances by local law requirements. To exercise these rights, please see the details in ‘How to Contact Us’ 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.

Data Portability and the right to be forgotten

You have the right to receive this information you provided us in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations. You also have the right to require us to delete your personal information in certain situations.

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 or would like access and / or update information or preferences you provided

You may e-mail us at: info@mulberrypm.co.uk

Or write to us at:

Data Protection Officer, Mulberry PM Ltd, 11 Walmgate, York, YO1 9TX

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 cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can. The General Data Protection Regulation (GDPR) also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.

How We Protect Personal Information

The security of your personal information is very important and Mulberry PM 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 also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Privacy Policy

We may change this privacy notice from time to time. When we do, we will update the version date on our website.

Cookie Policy

Mulberry PM (“we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website Mulberryltd.uk, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customise the Site and improve your experience.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.

Cookies are text files placed on your device to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. Learn more at www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Use of cookies

A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.

Types of cookies

The following types of cookies may be used when you visit the Site:

Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

Analytics Cookies

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our Cookies

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

Personalisation Cookies

Personalisation cookies are used to recognise repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorised parties.

Site Management Cookies

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page.

Third-Party Cookies

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you.

Control of Cookies

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:

In addition, you may opt-out of some third-party cookies through the Your Online Choices Opt-Out Tool.

Other tracking technologies

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email.

They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.

Contact

If you have questions or comments about this Cookie Policy, please contact us:

By email: info@mulberrypm.uk Or
Write to us at:
Data Protection Officer, Mulberry PM Ltd, 11 Walmgate, York, YO1 9TX

Last updated: 22/01/2020