Who we are and how to contact us

Your personal information will be held securely by ModaMortgages, which is a trading name of Chetwood Financial Limited (‘Chetwood’), company number 09964966 of Ellice Way, Wrexham Technology Park, Wrexham, LL13 7YT.

We’ll collect personal information about you and the way you use our website when you, as a customer (including in your capacity as a Director of the Limited Company) or in your capacity as a mortgage intermediary/broker, apply for a mortgage. The ways in which we may use your personal information are described below.

Chetwood Financial Limited is the data controller (this means an organisation who determines the purposes and manner in which any personal data is processed) of your information under data protection laws because, in the context of our business relationship with you, we decide how and why it is processed in the ways explained in this policy. We’re registered with the Information Commissioner’s Office, under registration ZA218401.

To contact our Data Protection Officer, find out more about how we process your personal data or exercise any of your rights (see below), get in touch on our website.

How we collect your personal information

We’ll collect your personal information in different ways. Please see below.

Direct - we’ll collect personal information from enquiries sent through our website, or during the application process.
Intermediary - we’ll collect the personal information you’ve provided to a broker or other third party during your application or during the application process.
By information that we learn about you through our relationship with you and the way you manage your ModaMortgages account. This may be data collected by a third-party service provider.
By information that we gather from the technology you use to access our services (for example, location data from your mobile phone, an IP address or telephone number).
Through automated technologies or interactions - as you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Public Sources – we may collect data from publicly available sources, such as Companies House or the Land Registry, when you have given your consent to share information or for instances where the information is made public as a matter of law. We also collect personal data from other third parties such as Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs).

What kinds of personal information we collect and process

We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We’ll limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice.

Personal information may include some or all of the following:

Personal information – including your name and address, date of birth and contact details.
Family, lifestyle and social circumstances - your dependents, marital status and next of kin details.
Financial information – your bank account number, sort code and account and transactional history.
Financial circumstances - your income and expenses, assets and liabilities, credit and borrowing history, financial statements submitted as part of your mortgage application and your financial needs and goals.
Employment details - information about your employment status including whether you’re a student, employed, retired or receive benefits.
Visual images - passport photos or information contained on other identity documents.
Online profile, social media information and browsing activity - based on your interaction with us and our websites and applications. Including, for example, your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, and site visits and spending patterns.

We may also process certain special categories of information for specific and limited purposes, such as detecting and preventing financial crime, if it is in the wider public interest (for example, to protect customers’ economic well-being) or to make our services accessible to customers. We’ll only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular grounds and purposes set out in the section why we process your personal information below).

Special categories of information for specific and limited purposes may include:

Racial or ethnic origin.
Religious or philosophical beliefs.
Trade union membership.
Customer vulnerabilities and/or additional support needs, which may include details of health or medical conditions.
Biometric information relating to the physical, physiological or behavioural characteristics of a person, for example, using voice recognition or similar technologies to help us prevent fraud and money laundering.

Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data with law enforcement and regulatory bodies.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could come 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 website or application Usage Data to calculate the percentage of users accessing a specific website or application feature. 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 policy.

Why we process your personal information

Data protection laws require us to explain what legal grounds justify us using your personal information (this includes sharing it with other organisations). The laws refer to “processing” of information which includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it. For some processing, more than one legal ground may be relevant (except where we rely on a consent).

Here are the legal grounds that are relevant to us:

Contractual obligation

Where processing of your personal data is necessary for us to perform our contract with you or for taking steps before entering into the contract.

Assessing your eligibility for a mortgage and as part of our automated decision making (please refer to our section below).
Setting up your ModaMortgages account.
Verifying and updating your contact information.
Processing payments.
Day-to-day management of your account.
Issuing formal notices.
Sending service communications.
Addressing any enquiries or complaints we receive from you.

Consent

Where processing of your personal data requires us to obtain your clear consent.

When you request and give consent that we share your information with someone else.
For direct marketing communications.
For some of our automated decision-making.
For some of our processing of special categories of personal data including, for example, your vulnerabilities and/or additional support needs, which may include details of health or medical conditions.

Legal obligation

Where processing of your personal data is necessary for us to comply with laws we abide by.

Confirming your identity and undertaking checks with FPAs (see the section on FPAs below).
Prevention, detection and investigation of crime.
Assessing your affordability when applying for a mortgage.
Carrying out monitoring and maintaining records.
Complying with laws that apply to us.
Responding to enquiries and requests for information by any of our Regulators.
For establishment, defence and enforcement of our legal rights.
When sharing your information with other organisations. For example, law enforcement agencies and courts.
To otherwise meet our obligations under all laws and regulations based on law which apply to our business activities.

Legitimate interests

Where processing your personal data is necessary for your individual legitimate interests or the legitimate interests of a third party including their commercial interest or the broader interests of society.

Administering and managing your account, which may be via a third-party provider.
Updating your contact details.
Recovering debt, which may include repossession.
Testing the performance of our products, services and internal processes.
Adhering to the guidance and best practice of Governmental or regulatory bodies such as the Information Commissioner’s Office (ICO).
Gathering analytics and profiling to monitor and predict market trends.
Monitoring, reviewing and improving the content and appearance of our website.
For management and audit of our business operations.
To carry out searches through third parties such as credit reference agencies (see the section on CRAs below).
To carry out monitoring and keep records.
To administer good governance requirements.
For market research, analysis and development of statistics.
As part of our automated decision-making.
Where we share your information with other people or other organisations. For example, the broker or intermediary who introduced you to us, financial institutions and trade associations, debt recovery agencies and market research organisations.
Processing of special categories of personal data, for example, your vulnerabilities and/or additional support needs, which may include details of health or medical conditions.

Vital interests

Where processing of your personal data is necessary to protect someone’s vital interests including protecting someone’s life.

Processing of special categories of personal data. For example, your vulnerabilities and/or additional support needs, which may include details of health or medical conditions, if it's necessary to protect your economic well-being if you're at risk, and seeking consent would be unreasonable or negatively impact our ability to help you.
To fulfil our legal obligation and regulatory requirements.
When we share your personal information with other people and organisations. For example, if they need to know you’re a vulnerable customer, social services, your carer or relatives and anyone who has power of attorney over your affairs.

Public interests

Where processing is necessary “for the performance of a task carried out in the public interest” or “in the exercise of official authority”.

Processing of special categories of personal data, for example, your vulnerabilities and/or additional support needs, which may include details of health or medical conditions if it's necessary to protect your economic well-being if you're at risk and seeking consent would be unreasonable or negatively impact our ability to help you.

How we share your data

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

Other parties in the Chetwood Group, details of which can be found here.
External Third Parties including service providers who provide business administration services to us, professional advisors, regulators and other authorities.
Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPA’s). See sections on CRAs and FPAs below.
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 policy.
Mortgage intermediary / broker through whom you have applied for a ModaMortgages mortgage.

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.

How we use Credit Reference Agencies (CRAs)

To process your application, we’ll perform credit and identity checks on you with one or more credit reference agencies (CRAs).

CRAs collect and maintain information about customers’ and businesses’ credit behaviour.

CRAs use information from:

Electoral register.
Credit information.
Public information such as County Court Judgments, decrees, and bankruptcies.

ModaMortgages uses soft searches, also known as ‘quotation searches’, to work out whether you’re approved for a mortgage.

When requesting a quotation, we will carry out a soft search on each individual that is a party to the application. If an applicant is requesting a quotation for a company, this will include each Director of the company and we will also conduct a full search on the company.

We’ll only register a full search against each individual once an application is submitted to us, and you (via a broker or other intermediary) have given us permission to do so. If the applicant is a company, we will also register a full search against each Director of the company and we may also do a full search on the company.

When CRAs receive a full search from us they will place a search footprint on your credit file that may be seen by other lenders. Fraud Prevention Agencies (see the section on FPAs below) will also keep a log of the searches that we’ve carried out.

CRAs will record any outstanding debt. We’ll also inform the CRAs about settled accounts, if you make repayments on time and if you repay your balance in full at the end of the term of your agreement with us. CRAs may share this information with other organisations.

This is explained in more detail by following the links below:

How we use Fraud Prevention Agencies (FPAs)

The personal information we’ve collected from you will be shared with fraud prevention agencies (and CRAs) who will use it to:

Prevent fraud.
Prevent money-laundering.
Verify your identity.

If fraud is detected, you could be refused certain services, finance, or employment.

Further details on how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by following the links below:

We’ll continue to exchange information about you with CRAs and FPAs while you have a relationship with us.

We’ll use this information to:

Help us understand whether you can afford to take out the ModaMortgages Mortgage you’ve applied for.
Check the accuracy of the data you have provided to us.
Prevent criminal activity, fraud and money laundering.
Manage your account.
Trace, recover and/or enforce debts.
Ensure any offers provided to you are appropriate to your circumstances.

Using credit scoring and other automated decision-making

When you apply for credit, an automated system known as credit scoring may be used to decide if we can approve your ModaMortgages Mortgage. It’s a system widely used by credit providers to help make fair and informed decisions on lending.

Credit scoring takes account of information from three sources:

The information you provide on your application.
Information provided by CRAs.
Information that may already be held about you by ModaMortgages.

A credit scoring system helps us lend responsibly as it considers information from these sources, to make an overall assessment of your application.

You have the right to ask that the decision is not made based solely using a credit scoring system. Where we determine it is required, we may use an underwriter to make an overall assessment of your application.

How we monitor your personal information

This means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages and other communications.

Some of our monitoring may be to do the following:

Comply with regulatory rules.
Comply with self-regulatory practices.
Procedures relevant to our business.
To prevent or detect crime.
To have a record of what we have discussed with you and actions agreed with you.
To protect you and to provide security for you.
For quality control and staff training purposes.

Where we store your personal information

We’re based in the UK and will generally store your personal information in the UK & Republic of Ireland, but we may transfer your personal information abroad.

If your information is processed within the EEA it is protected by European data protection standards. If your information is transferred outside the EEA, we’ll make sure that suitable safeguards are in place before we transfer the information.

How long will we keep your personal information?

ModaMortgages customers

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.

Unless we explain otherwise to you, or we have legal grounds to hold for a longer period (such as your consent) we’ll hold your personal information from the end of your relationship with us for the following periods and reasons:

Up to 6 years - to respond to any queries or complaints.
Up to 10 years - to maintain records according to rules and regulations that apply to us.

We manage our records of your personal information to help us to serve you as our customer (for example for operational reasons, such as dealing with any queries relating to your account and to comply with legal and regulatory requirements).

Retention periods for records are determined based on the type of record, the nature of the activity, product or service, and the applicable legal or regulatory requirements. Retention periods may be changed from time to time based on business or legal and regulatory requirements. We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators.

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.

ModaMortgages applicants

If you apply unsuccessfully for a ModaMortgages mortgage, we’ll hold your personal information only for as long as is necessary to deal with any queries you may have.

Your rights

Here are your rights under data protection laws. There may be reasons why you can’t exercise your rights, but we’ll always tell you if this is the case and explain in more detail when your request is made.

Right to be Informed – the right to know we’re processing your personal information.
Right to Access - the right to request access to the personal information we hold about you.
Right to Rectification - the right to request we update and correct any out-of-date or inaccurate personal information we hold about you.
Right to Erasure (‘The Right to be Forgotten’) - the right to request that we remove all personal information we hold about you, if there is no need for us to keep it.
Right to Restrict Processing - the right to request we restrict the processing of your personal information.
Right to Object to Processing - the right to request we stop processing your personal information.
Right to Data Portability - the right to request us to provide personal information you’ve supplied to a third party.
Rights in relation to automated decision-making which has a legal effect or otherwise significantly affects you.

If you want to contact us to exercise these rights, get in touch with us on our website.

If you wish to exercise any of these rights against the CRAs, the FPAs, or an intermediary, you’ll need to contact them directly as they’re data controllers in their own right.

What should you do if your information changes?

Get in touch with us as soon as possible if your information changes so we can update our records. If you are a ModaMortgages customer, please use our Customer Get in Touch page. If you are an intermediary, please use our Intermediary Get in Touch page.

Marketing

If you opt-in to receive our marketing communications, we’ll use your personal information to contact you and provide you with product details and offers that are relevant to you.

You can change your preferences at any time by getting in touch with us. If you are a ModaMortgages customer, please use our Customer Get in Touch page. If you are an intermediary, please use our Intermediary Get in Touch page.

IP addresses

When you visit our website, regardless of whether you log in or not, our web servers automatically take note of your domain name, IP address and details about your device. These details reveal nothing personal about you. We use this information to investigate abuse of our website and their users, and to co-operate with law enforcement. We also share this information with third parties.

Cookies

At ModaMortgages we use cookies to give you the best possible experience on our website. Cookies are text files stored on your computer, mobile or tablet, when you visit websites. Take a look at our Cookie Policy to find out more.

Third-party websites

When we include links to other websites, please bear in mind that they’ll have their own privacy and cookie policies that will govern the use of any information you submit. We recommend you read their policies as Chetwood isn’t responsible or liable for their privacy practices.

Complaints

If you’re not happy with any aspect of the way that we process your information or fulfil our obligations, you have the right to complain to the Information Commissioner’s Office who enforce data protection laws. They can be found at: https://ico.org.uk/.

Changes to our Privacy Policy

From time to time, we update our policy to reflect changes we’ve made for our customers. This Privacy Policy was last updated in August 2023.