Privacy Policy
How themortgagepeople looks after your personal data, and the rights you have over it.
Privacy Policy
As we use an enquiry form within our website, themortgagepeople, and collect personal information and financial documents, we feature a privacy policy within our website to map how we will process the user's personal data.
Privacy Notice
themortgagepeople is owned and operated by Ramsey Lomax LTD.
Ramsey Lomax Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
By "We" or "Us", we mean Ramsey Lomax LTD ("Ramsey Lomax").
By "You" we mean the customer or individual who has accessed our service or the individual to whom data relates that we process or control.
We are registered in England and Wales. Registered Address: United House, North Road, London, England, N7 9DP. Company Number: 08591146. ICO registration number: ZA441156.
Ramsey Lomax LTD is authorised and regulated by the Financial Conduct Authority (FCA). Our licence number is 740282.
Ramsey Lomax LTD is a credit broker and not a lender.
Purpose of this privacy notice
This privacy notice aims to give you information on how Ramsey Lomax collects and processes your personal data through your use of this website, or directly via electronic communication, including any data you may provide through this website or any data that you have provided to third party companies wherein you consented to the passing and processing of data by Ramsey Lomax.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
Our contact details
Ramsey Lomax is the controller and is responsible for any of your personal data it controls and processes. Our full details are:
- Full name of legal entity: Ramsey Lomax
- Email address: compliance@ramseylomax.co.uk
- Postal address: Ramsey Lomax, 7 Bell Yard, London, WC2A 2JR
- Telephone number: 020 3932 5509
The data that we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details, financial statements and balances, credit reference agency information, wage slips, credit card details, loan details, mortgage details and expenditure details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, 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 you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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 we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Credit Reference Agencies
We help customers obtain finance by a number of means. In order to get a picture of your true credit position, we may access and search your credit file with a credit reference agency.
We believe in informing customers at all stages about searches we carry out and we will seek your permission to complete these when they become necessary.
If you wish to know how the credit reference agencies will treat your data, please see their policies here: TransUnion and Experian.
How is your personal data collected
We use different methods to collect data from and about you, including through:
Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or automated chat bots, or by corresponding with us by post, phone, email, SMS or otherwise. This includes personal data you provide when you:
- Use our online loan application and search form.
- Wish to search for a loan product.
- Agree to a search with a credit reference agency.
- Create an account on our website.
- Subscribe to our service or publications.
- Request marketing to be sent to you.
- Give us some feedback.
- Email us regarding a complaint or SAR.
- Phone us with a business or consumer enquiry.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources
- Technical Data from analytics providers such as Google, based outside the EU.
- Technical Data from advertising networks such as Google, Facebook, Taboola, Revcontent and Outbrain, based outside the EU.
- Technical Data from CRM providers based inside the UK such as Databowl, Salesforce, Mailchimp or Constant Contact.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, based inside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided us consent to control or process your data for direct marketing purposes.
Purposes for which we will use your personal data
Below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose. Please email compliance@ramseylomax.co.uk if you need details about the specific legal ground we are relying on.
Lawful basis
- Consent means you giving a freely informed choice for us to contact you in relation to the service we wish to offer and how we use your data. We will make sure that consent is appropriate and offers you a real choice of control over how we will use your data.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
| Purpose / Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a new customer | Identity, Financial, Contact | Performance of a contract with you |
| Providing mortgage quotes | Identity, Financial, Contact | Performance of a contract with you |
| Introducing you to an FCA authorised broker who will help you with your enquiry | Identity, Financial, Contact | Performance of a contract with you |
| Providing mortgage advice | Identity, Financial, Contact | Performance of a contract with you |
| To make an introduction to a credit broker who will be able to provide you with quotes | Identity, Financial, Contact | Performance of a contract with you |
| To manage our relationship with you | Identity, Financial, Contact | Performance of a contract with you |
| Notifying you about changes to our terms or privacy policy | Identity, Contact | Necessary to comply with a legal obligation |
| Asking you to leave a review or take a survey | Identity, Financial, Contact | Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity, Financial, Contact | Necessary for our legitimate interests (running our business, IT services, network security, fraud prevention, business reorganisation) and to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising we serve | Identity, Financial, Contact | Consent, and necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business and inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Identity, Financial, Contact | Necessary for our legitimate interests (to define customer types, keep our website relevant, develop our business and inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity, Financial, Contact | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or from third parties that work with us and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside Ramsey Lomax for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing us at compliance@ramseylomax.co.uk at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service engaged.
Cookies
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things such as remembering your preferences, recording what you have put in your shopping basket, and counting the volume of people accessing the 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.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email compliance@ramseylomax.co.uk.
If we need to use your personal data for an unrelated purpose, we will notify you and we will 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.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy. We may also disclose your information with:
- HM Revenue & Customs, Claims Management Regulator, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Accountants, solicitors, compliance consultants and other like services acting as processors, based in the United Kingdom, who require reporting of processing activities in certain legal and compliance circumstances.
- 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.
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.
Software and marketing partners
| Company | Details | Purpose of activity |
|---|---|---|
| Ramsey Lomax LTD | https://ramseylomax.co.uk/ | Performance of a contract with you |
| https://twitter.com | Provision of Marketing Activities | |
| https://facebook.com | Provision of Marketing Activities | |
| https://www.google.com/ | Provision of Marketing Activities | |
| Outbrain | https://www.outbrain.com/ | Provision of Marketing Activities |
| Taboola | https://www.taboola.com/ | Provision of Marketing Activities |
| StackAdapt | https://www.stackadapt.com/privacy-policy | Provision of Marketing Activities |
| YouTube | https://www.youtube.com/ | Provision of Marketing Activities |
| Adespresso | https://adespresso.com/ | Provision of Marketing Activities |
| Landbot.io | https://landbot.io/ | Marketing activities, data collection, data analysis, website interaction, automated conversations |
| LeadGenApp.io | https://leadgenapp.io/ | Marketing activities, data collection, data analysis, website interaction, automated conversations |
| Unbounce | http://unbouncepages.com/ | Marketing activities, data collection, data analysis, website interaction, website optimisation |
| Hotjar | https://www.hotjar.com/ | Marketing activities, data collection, data analysis, website interaction, website optimisation |
| Salesforce | https://www.salesforce.com/uk/ | Data storage and processing, contact |
| Data-8 | https://www.data-8.co.uk/ | Provision of data and validation services |
| Experian | https://www.experian.co.uk/ | Provision of credit bureau services |
| TransUnion | https://www.transunion.co.uk/ | Provision of credit bureau services |
| CAKE | https://getcake.com/privacy-policy/ | Technology and marketing provider for enquiry distribution, data analysis, data compliance |
| DataBowl Limited | https://www.databowl.com/ | Technology and marketing provider for enquiry distribution, data analysis, data compliance |
Loan and credit brokers
| Company | Details | Purpose of activity |
|---|---|---|
| Fluent Lifetime LTD | https://www.fluentlifetime.co.uk/ | Provision of credit brokering services |
| Key Retirement Solutions | https://www.keyadvice.co.uk/ | Provision of credit brokering services |
| Access Equity Release | https://www.accessequityrelease.com/ | Provision of credit brokering services |
| Your Mortgage Decisions | https://www.yourmortgagedecisions.com/ | Provision of credit brokering services |
| Later Life Retirement Planning | https://laterliferetirementplanning.co.uk/privacy-policy/ | Provision of credit brokering services |
| Optimise Finance | https://optimisefinance.co.uk/privacy-policy/ | Provision of credit brokering services |
| Mortgage Advice Bureau | https://www.mortgageadvicebureau.com/privacy-policy/ | Provision of credit brokering services |
| Lendle | https://www.lendle.co.uk/privacy-policy/ | Provision of credit brokering services |
| Cornerstone Networks & Partners | https://cornerstonefinance.co.uk/privacy-policy/ | Provision of credit brokering services |
| The Money Advice Centre | https://themoneyadvicecentre.com/privacypolicy | Provision of credit brokering services |
| Norton Finance | https://www.nortonfinance.co.uk/customer-privacy-notice | Provision of credit brokering services |
Fees
themortgagepeople or our parent company Ramsey Lomax LTD will never charge you a fee.
We are a profit making company and we will receive fees for our services, but they are not paid by consumers using our website. We receive two types of fees:
- Enquiry Fee. If a user completes our website form we will refer that user to an FCA authorised broker. The broker will pay us a one-off fee for making this introduction. This fee will be paid to us whether you take out a mortgage or not.
- Completion Fee. If you decide to take out a mortgage via a broker we have referred you to, then they (the broker) will pay us a fee once your mortgage has been agreed and funded.
Broker fees: if you decide to take out a mortgage with one of our recommended brokers then you may be charged a fee by the broker. All of our brokers offer a no upfront fee policy, which means you can speak with them, get free quotes, have all of your questions answered and then decide to progress further, and there will be no charge for this part of the process.
All of the brokers that we work with will explain any fees in full before you make any decisions, but please always check with the broker directly regarding any fees.
International transfers
Some of our external third parties or traffic partners such as Facebook, Google and others, or software providers, are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
Please email compliance@ramseylomax.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data security
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties 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.
Data retention
We will only retain 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.
Ramsey Lomax LTD is authorised and regulated by the FCA. As such we have regulatory requirements to maintain details of our customers for at least 6 years. In some cases we may retain personal data for longer than 6 years.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us at compliance@ramseylomax.co.uk. By law we have to keep certain information about our customers and this data will be held solely and securely for those legal purposes.
In some circumstances you can ask us to delete your data. However, an erasure request may be partially declined. In the event a complaint has been made, coupled with an erasure request, we will maintain records relating to the complaint, including basic information such as name, email and telephone. In the event that you do not wish to be contacted by us, we are required to maintain a log of this request, withholding applicable data to ensure we no longer contact you further.
In some circumstances we may 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request 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, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please email us at compliance@ramseylomax.co.uk.
Subject access request
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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 want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will respond to your request within one month of receiving your request. We will inform you of the third parties to whom your data has been disclosed.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The right to be informed
The right to be informed encompasses our obligation to provide "fair processing information", typically through a privacy notice. It emphasises the need for transparency over our uses of personal data.
The information we will supply relating to the processing of personal data must be:
- Concise, transparent, intelligible and easily accessible;
- Written in clear and plain language, particularly if addressed to a child; and
- Free of charge.
The use of data, including how we protect and store data, will be made readily available to individuals through our privacy notice on our website.
What information must be supplied?
- Full contact details of our firm (and where applicable, the controller's representative) and the data protection officer;
- The purpose of the processing and the legal basis for the processing;
- The legitimate interests of the controller or third party, where applicable;
- The categories of personal data;
- Any recipient or categories of recipients of the personal data;
- Details of transfers to third countries and safeguards;
- Our retention period or criteria used to determine the retention period;
- The existence of each of the data subject's rights;
- The customer's right to withdraw consent at any time, where relevant;
- The customer's right to lodge a complaint with a supervisory authority;
- The source the personal data originates from and whether it came from publicly accessible sources;
- Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data; and
- The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.
The right to access
The data subject shall have the right to obtain from the controller confirmation as to whether personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- (a) the purposes of the processing;
- (b) the categories of personal data concerned;
- (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject, or to object to such processing;
- (f) the right to lodge a complaint with a supervisory authority;
- (g) where the personal data are not collected from the data subject, any available information as to their source;
- (h) information on the existence of automated decision making, including profiling, and meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data is transferred to a third country outside the EEA or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. Such safeguards include a legally binding and enforceable instrument between public authorities or bodies, and binding corporate rules in accordance with Article 47.
When requested, the controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs.
Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others.
The right to restrict processing
Under the DPA, individuals have a right to "block" or suppress processing of personal data. The restriction of processing under the GDPR is similar, as detailed in Articles 18 and 19 respectively.
When processing is restricted, we are permitted to store the personal data, but not process it further. We can retain just enough information about the individual to ensure that the restriction is respected in future. This needs to be applied and communicated to each data processor where applicable and documented where appropriate.
When does the right to restrict processing apply?
- Where an individual contests the accuracy of the personal data, we should restrict the processing until we have verified the accuracy of the personal data. We would do this by asking the individual to confirm the information is correct and, where required, update accordingly.
- Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our organisation's legitimate grounds override those of the individual.
- When processing is unlawful, and the individual opposes erasure and requests restriction instead, we are obliged to ensure this request is documented and the data collected is only used for the intent on which it was originally collected, and not processed further.
- If we no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim. We would ask the individual to submit a DSAR and release the data upon receipt and in accordance with the DSAR procedure.
- We may need to review procedures to ensure we are able to determine where we may be required to restrict the processing of personal data.
- If we have disclosed the personal data in question to third parties, we must inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so. We must inform individuals when we decide to lift a restriction on processing.
The right to object
Individuals have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest / exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific / historical research and statistics.
If we process personal data for a legal task or our legitimate interests
Individuals must have an objection on "grounds relating to his or her particular situation". We must stop processing the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the individual, or the processing is for the establishment, exercise or defence of legal claims.
We must inform individuals of their right to object "at the point of first communication" and in our privacy notice. This must be explicitly brought to the attention of the data subject and presented clearly and separately from any other information.
If we process personal data for direct marketing purposes
We must stop processing personal data for direct marketing purposes as soon as we receive an objection. There are no exemptions or grounds to refuse. We must deal with an objection to processing for direct marketing at any time and free of charge.
If we process personal data for research purposes
Individuals must have "grounds relating to his or her particular situation" in order to exercise their right to object to processing for research purposes. If we are conducting research where the processing of personal data is necessary for the performance of a public interest task, we are not required to comply with an objection to the processing.
If our processing activities fall into any of the above categories and are carried out online, we must offer a way for individuals to object online.
Complaints procedure
It is our aim to provide a very high standard of service to every customer and website user. If you are unhappy, for any reason, with the service we provide to you, we would welcome your feedback and the opportunity to put things right.
It is important to us that all complaints are resolved as quickly as possible to the complete satisfaction of our customers, and that we learn from any complaints to further improve the quality of our service. We would always ask that you give us the opportunity to deal with your feedback or complaint first, before taking further action.
Step 1: Receiving your complaint
To register your complaint, we ask that you email compliance@ramseylomax.co.uk. To help us investigate and resolve your concerns as quickly as possible, we request that you provide:
- Your full name and address and a daytime contact telephone number;
- Full details of your complaint;
- Your account details and any policy numbers as relevant;
- Copies of any documents that you may think are relevant, such as any emails that you have received;
- Details of what you would like us to do to put things right.
If this is a complaint about an unwanted email then we kindly request that you do not delete the email but, along with your complaint information, forward on the entire marketing email that you received to complaints@ramseylomax.co.uk. This will help us to resolve your complaint more quickly.
We will acknowledge receipt of your complaint within 3 working days, but aim to have done so sooner. If you have not received our acknowledgment, then we request that you call us or write to: Complaints, Ramsey Lomax, United House, North Road, London, N7 9DP.
Step 2: Initial response
Once we have acknowledged receipt of your complaint we will aim to have an initial response for you within 7 working days. Complaints often occur as a result of a misunderstanding, so we hope that our initial response will bring the matter to a satisfactory conclusion.
Step 3: Final response
If you are unhappy with our initial response, we would request that you reply registering your dissatisfaction and detail what further action you would wish us to take. We will then provide you with a final response within 4 weeks.
If you are not satisfied with our final response
You can report a concern to the Information Commissioner's Office ('ICO'), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Or visit the Financial Ombudsman Service for further information, or the FCA for additional information.
Subject access request
Our firm must provide a copy of all the personal data undergoing processing, commonly known as a subject access request ('SAR'), when requested. In clear terms, a subject access request enables an individual to find out what personal data our firm holds about them. This must be provided free of charge initially; however, in the event that any further copies are requested, we may charge a reasonable administrative cost fee. Where the request is made in an electronic form, the subject must receive the requested information in an accessible and commonly used electronic form.
In compliance with Recital 63 of the GDPR, we will endeavour (where possible) to provide a secure system that will grant the data subject direct access to his/her data; however, it must be duly noted that this is not a strict obligation.
Within the requested SAR, we will include:
- The purpose of processing;
- The categories of data processed;
- The recipients, or categories of recipients (in particular, details of disclosure to recipients in third countries or to international organisations);
- Our complaints escalation process.
In addition to the above, we will include (where practicable):
- The envisaged retention period of the data, or if this is not possible, the criteria used to determine this period;
- The individual's rights of rectification or erasure, to restrict processing or to object to processing and to lodge a complaint to a supervisory authority;
- Information regarding the source of the data (if not collected from the data subject); and
- Any regulated automated decision taking – including information about the logic involved and the significance and envisaged consequences of the processing for the data subject.
If we do not comply with a SAR, we will provide reasons for not doing so.
We note that the data subject's right of access to personal data should not adversely affect the rights or freedoms of others, including trade secrets or intellectual property and in particular the copyright protecting the software. Where we process a large quantity of information concerning the data subject, we will request that, before any information is delivered, the data subject specifies the information or processing activities to which the request relates.
A Subject Access Request (SAR) was created under section 7 of the Data Protection Act. It is most often used by individuals who want to see a copy of the information an organisation holds about them. We have made the Subject Access Request process as simple and quick as possible and we do not charge a fee for this.
Step 1: Submit your request
We ask that you submit your Subject Access Request via email to compliance@ramseylomax.co.uk, adding 'Subject Access Request' into the subject line of the email.
If your SAR was prompted by receipt of an email, we would kindly request that you also forward on the original email that you received along with your SAR. In certain circumstances we may not actually hold any personal data about you and indeed it may be a third party marketing company that sent you the email. We can still help with your SAR, but receiving the original email will help us complete it as quickly and comprehensively as possible.
We will acknowledge receipt of your SAR within 3 working days but aim to have done so sooner. If you have not received our acknowledgment, then we request that you call us or write to: SAR, Ramsey Lomax LTD, United House, North Road, London, N7 9DP.
Step 2: Initial response
Once we have acknowledged receipt of your SAR we will aim to have an initial response for you within 14 working days. This will be a full breakdown of what information we may hold about you, including your consent details.
Step 3: Final response
If you are unhappy with our initial response, we would request that you reply registering your dissatisfaction and detail what further action you would wish us to take. We will then provide you with a final response within 4 weeks.
If you are not satisfied with our final response to your SAR, we would request that you make your dissatisfaction known via our complaints procedure. To make a complaint to the Information Commissioner's Office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
