Privacy Notice
Why we have a Privacy Notice
We are committed to respecting and protecting your privacy. This Privacy Notice sets out the type of information we collect from you and what we do with that information.
Who we are
Moneybox Mortgages Limited is an Appointed Representative of Mortgage Advice Bureau and Mortgage Advice Bureau (Derby) Ltd. As joint controllers of your data, we comply with Data Protection laws in the United Kingdom. For the purpose of this Privacy Notice, companies known together in this document as “Mortgage Advice Bureau”, “we” and “us”, which are responsible for processing your data:
- Moneybox Mortgages Limited, Registered office: 1-2 Hatfields, London, SE1 9PG. Registered in England Number: 12954235
- Mortgage Advice Bureau Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 3368205
- Mortgage Advice Bureau (Derby) Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 6003803.
Moneybox Mortgages Limited is also registered with the Financial Conduct Authority (FCA) with the FCA registration number (FRN) 942190 as an Appointed Representative of Mortgage Advice Bureau (FRN 455545) and Mortgage Advice Bureau (Derby) Limited (FRN 466154).
Moneybox and Mortgage Advice Bureau have appointed Data Protection Officers (DPO) who are responsible for overseeing questions in relation to this Privacy Notice, including requests to exercise your legal rights. Their contact details are below.
- Mortgage Advice Bureau
- Postal correspondence to: Capital House, Pride Place, Derby DE24 8QR
- Email to data.protection@mab.org.uk
- Moneybox
- Postal correspondence to: Data Protection Officer, Moneybox, 1-2 Hatfields, London, SE1 9PG; or,
- Email to dpo@moneyboxapp.com
Other relevant policies and terms
This Privacy Notice should be read together with the Moneybox Mortgages Terms of Business, our Website & App Terms of Use, our Cookie Policy, and if you have signed up to a Moneybox account, our Customer Terms & Condition and our Digital Moneybox Privacy Notice.
Our commitment
We are committed to protecting your personal information and other data provided to us. Information from which you could be identified (“personal data”), will only be used in accordance with this Privacy Notice. We will be the joint controller along with Mortgage Advice Bureau for your data when you purchase a product or service with us. We may also act as a data processor where you gained access to our products or services through a third party.
This Privacy Notice supplements any other notices you may receive from Moneybox about the use of your personal data and is not intended to override them.
Lawful basis of processing
Under Data Protection laws, we must have legal grounds to process your personal data. We consider the following grounds to be relevant:
- Consent: where you have given us permission to collect, use and store your personal data for a specific reason or reasons. Generally we do not rely on consent as a legal basis for processing your personal data, but when we do you can withdraw your consent at any time
- Performance of a contract: in order to provide a service or product
- Legal obligation: where processing of the data is required by law, for example carrying out anti-money laundering checks. We are also required by law to retain certain information of people that register to open an account and of customers beyond the date when they cease to be our customers.
- Legitimate interest: where it is reasonable to achieve our and others’ legitimate interests, such as to understand how you interact with our app and to send communications about products and services we think will be of interest to you
More detail on the legal basis for the different ways we use your data is presented in the table later in this Privacy Notice.
What information do we collect?
We might collect, store and use the following types of information about you depending on the Moneybox products and services you use:
-
- Identity data: including name, date of birth, gender, marital status, national insurance number, and any documents used to verify your identity such as passport or driving licence
- Contact data: including home address, email address and telephone numbers
- Financial data: including bank statements, bank account details, payment card details, salary and occupation details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
- Special category data: including information you choose to share with us about medical conditions, trade union or political party membership costs if that is included in your bank or credit card transactions
- Transaction data: including details about payments into and withdrawals from products and services you have purchased from us and your bank or credit card transactions if you used Open Banking to link to these to use the round-up service
- Technical data: including internet protocol (IP) address, 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 used to access the Mortgage Advice Bureau website
- Profile data: including username and password, feedback and survey responses
- Usage data: including purchases made by you and how you use our website, app, products and services
- Marketing and communications data: including communications with Moneybox (in-app chat, email, phone call), your preferences for receiving marketing from us and our business partners and your communication preferences
How do we collect information from you?
- Directly: including interactions with an adviser in person, by post, phone (including call recordings and voicemail), email, videoconferencing or otherwise when sourcing and applying for a mortgage or protection products
- Automatically: including your use and browsing patterns, and technical data about the device you are using to access our website, via the My Mortgage Account portal, web enquiry form or the Find A Mortgage function, which is collected using cookies, server logs and other similar technologies
- From third parties/public sources: including business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies. Some specific information from third parties includes:
- Estate agents with whom you may be interacting (but only with your consent)
- New home builders
- Enquiries you may perform on third-party mortgage sourcing websites
- When you use the Home Wealth Tool, your mortgage information as further set out in the Home Wealth Terms and Conditions
What does Moneybox do with this information?
Moneybox may use your personal data for the following purposes:
- Provide the requested products and services to you
- Monitor traffic patterns and usage of the app, website and tools to help improve the design and layout
- Identify, troubleshoot and resolve any issues
- Provide customer service, including responding to your enquiries and fulfilling any requests
- Keeping a record of your relationship with us
- Generating aggregated or anonymised statistics for internal business purposes
- Analyse and profile personal data to evaluate certain things such as estimating how likely you are to be interested in other Moneybox products available to you and to personalise your experience of the Moneybox app with more relevant screens, features or in-app messages, educational content and send more relevant communications or present more relevant marketing
- To help Moneybox provide relevant support based on information you have chosen to share with us relating to medical need or personal circumstances, and we may limit messages or marketing that are not appropriate to you
- Carry out checks to prevent financial crime
- Send you important information about Moneybox products, services and other technical notices, updates, security alerts, and support and administrative messages
- To enable you to participate in a prize draw, competition or complete a survey
- To deliver relevant app and website content, marketing and communications and advertisements to you and measure and understand the effectiveness of the advertising we serve to you
- Comply with legal obligations, and to establish, exercise, or defend against legal claims
More detail on what data Moneybox uses for different purposes and the legal basis for its uses is presented in the table below.
| Purpose/Activity | Type(s) of data | Lawful basis for processing |
|---|---|---|
| To initially engage with you to discuss your requirements |
|
Consent |
| To source products, provide indicative quotes, and process & deliver your application for a mortgage or protection product |
|
Performance of a contract with you to provide advice services
Special Category data – Explicit Consent (Medical information for protection policies) |
| To comply with FCA rules including record keeping, consumer duty, vulnerable customers, and to meet Anti Money Laundering legislation, and notifying you about changes to our terms or privacy policy |
|
To comply with a legal obligation
Special Category data – Substantial Public Interest (Statutory & Government Purposes) supported by Vulnerable Customer policy |
| To recover debts due to us |
|
Necessary for our legitimate interests |
| To create and maintain access to the My Mortgage Account portal account |
|
Performance of a contract with you |
To manage our client relationship with you, which will include:
|
|
Necessary for our legitimate interests
(as joint data controller with Mortgage Advice Bureau, to re-engage with you to review your existing mortgage / protection needs, to maintain and improve customer service standards, and to communicate with you as part of a nurture journey until you are ready to proceed with a mortgage / protection application) |
| To respond to case enquiries and input to & defend against complaints |
|
Necessary for our legitimate interests (to ensure that complaints can be responded to accurately)Special Category data – Legal Claims & Judicial Acts |
| To perform an affordability check for a property on behalf of an Estate Agent or New Home Builder |
|
Necessary for our legitimate interests and of the New Home Builder / Estate Agent (to ensure that a property is affordable before the purchase process) |
| Record appointments to perform checks on the quality of advice our advisers provide to clients |
|
Consent Special Category data – Explicit Consent |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use systems including AI and automated decision making to support our services and assist with document validation, affordability and product sourcing |
|
Necessary for our legitimate interests (to assist advisers with the advice process and inform our client re-engagement and marketing strategy) |
| To use data analytics, including profiling, to personalise your experience of the Moneybox app with more relevant screens, features, products or in-app messages, and send more relevant communications or present more relevant marketing. We will also use this information to improve our app, website, products, services, marketing, customer relationships and experiences. We may also exclude you from some marketing if it is not relevant to your circumstances. |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) Legitimate interests (to define types of customers for our products and services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy) |
| To use data analytics and other systems including AI and automated decision making to improve our website, products/services, marketing, customer relationships and experiences |
|
Consent / Explicit Consent
Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business, and to inform our client re-engagement and marketing strategy)
|
| To enable you to participate in a prize draw, competition or complete a survey |
|
Performance of a contract
Legitimate interests (to study how customers use our products and services, and better inform us how to develop them, to grow our business) |
| To market to non-Moneybox customers including via our social media channels |
|
Legitimate interest (to identify marketing target group)
Consent (to directly contact non-Moneybox customers). |
| To de-identify your data (anonymise or aggregate) |
|
Legitimate interest (to increase data security and protection, and to use for analysis to grow and enhance our business) |
Changes to our Privacy Notice
We keep our Privacy Notice under regular review. If appropriate we will notify you by email about changes. This Privacy Notice was last updated on 8th July 2024. Historic versions can be obtained by contacting us.
Storing your information
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. We also limit access to your personal data to only those staff, appointed representatives, advisers, business partners and suppliers 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.
Where we have given you, or you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our website or app, you are responsible for keeping this password or PIN confidential. You must not share this password or PIN with anyone.
Cookies
When using our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Data Retention
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, 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 and regulatory requirements.
| Purpose of processing | Retention |
|---|---|
| Successful mortgage / protection applications | For the full mortgage or protection policy term plus a further 6 years, or for a period of 30 years for historical cases if the original term is not recorded |
| Withdrawn, stalled, incomplete and failed mortgage / protection applications | 2 years from the date the latest application was started, or 6 years from the application submitted date if application was submitted and subsequently rejected or from creation date if advice has been provided but not pursued |
| Affordability checks | 2 years from Decision In Principle if affordability check does not proceed to a full mortgage application |
| Enquiry data obtained from third parties that do not result in an application | 2 years from the date the lead was received from the Introducer |
| Video recordings of appointments used for quality checking of advice | Up to 1 month after the appointment date |
After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
Outside the EEA
Transfers of data from the UK to the European Economic Area (EEA) is permitted by the UK government. Some of our external suppliers are based outside the EEA so their processing of your personal data will involve a transfer of data outside of the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by:
- Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Using the International Data Transfer Agreement approved by the Information Commissioner’s Office which gives personal data the same protection it has in the UK.
Links to other websites
Our app may, from time to time, contain links to and from the apps or websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Change of purpose
We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and 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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.
Disclosing your personal information
We may share your information between companies within the Moneybox Group and with selected third parties or categories of third parties listed in the table below.
| Type of recipient | Reason |
|---|---|
| Moneybox Group companies | We may share your information between companies within the Moneybox Group. |
| Within Mortgage Advice Bureau | Depending on your requirements, it may be necessary to share your personal data with Mortgage Advice Bureau’s network and specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients and to obtain input from specialist trainers within our network to improve advice quality. |
| Lenders and protection product suppliers | To source and submit applications in order to conclude the contract for the mortgage / protection application and the ongoing servicing of these contracts. |
| Financial Institutions | To source your bank account information via Open Banking with your consent. |
| External suppliers | Specialist IT system providers to deliver our service to you (including sourcing of products, providing continuing advice, sharing of documentation, payment processing, informing you about relevant products and services, service & advice quality checking and improvements, and to request feedback on customer service standards). It may also be necessary to share your personal data with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Mortgage Advice Bureau. |
| Solicitors / Conveyancers | To update the firm of solicitors / conveyancers with whom you are interacting about the progress of your application and confirm your identity / proof of deposit. |
| Estate agents / new home builders | To update the firm of mortgage / protection advisers, estate agents and home builders with whom you are interacting about the results of affordability checks and progress of your application. |
| Licensed Credit Agencies | For the purposes of confirming your identity to comply with Anti Money Laundering requirements (Onfido and RDC); to perform a credit assessment to assess your eligibility; as part of an application request for a Lenders Decision In Principle; and to perform a credit assessment with your consent as part of a full application. |
| Regulators | In order to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise cooperate with law enforcement, legal proceedings or regulatory authorities. |
| Transunion | When you use the Home Wealth Tool in the Moneybox app, we send your personal data, including your name, DOB and 3 years address history to Transunion so that we can surface your mortgage details in the Moneybox app. To find out how Transunion and their sub-processor iovation use your information please refer to the Transunion Privacy Notice, currently available at https://www.transunion.co.uk/legal-information/bureau-privacy-notice, and the iovation privacy policy, currently available at https://www.iovation.com/privacy. |
| Others | 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. |
These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Mortgage Advice Bureau instructions. 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.
Your rights
We will need to confirm your identity and ensure your right to access your personal data or to exercise any of the other rights listed below. We may also need further information from you in order to speed up your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed below), however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month, but occasionally this may take longer if your request is particularly complex, or you have made a number of requests (if this is the case, we will notify you and keep you updated).
Access to your personal data
You have the right to request access to your personal data (commonly known as a data subject access request (DSAR)). If you would like a copy of the information held on you, please contact our Data Protection Officer (see the beginning of this Notice for details).
Correction of your personal data
You have the right to request the 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, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Erasure of your personal data
You have the right to request the erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below).
Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objection to processing of your personal data
You have the right to object to the 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 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.
Restriction of processing your personal data
You have the right to 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 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; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Transfer of your personal data
You have the right to request the transfer of your personal data to you or to a third party. Subject to the rules and regulations that govern the products and services we provide, 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.
Withdrawing consent
You have the right to 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.
Updating your marketing preferences
You have the right, at any time, to ask us not to process your personal information for marketing purposes. You can do so by emailing us at data.protection@mab.org.uk.
Questions
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Head of Information Security & Data Protection by emailing Data.Protection@mab.org.uk or by writing to us. We will respond to you as soon as possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
Contact the Information Commissioner’s Office
If you are not satisfied with how the Mortgage Advice Bureau has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom
The ICO’s details are:
- Postal correspondence: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline: 0303 123 1113
- Website: ico.org.uk
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