Terms of use, privacy and cookie policy

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Terms of use

Introduction

This website www.commercialtrust.co.uk ('website') is owned and provided by Commercial Trust Limited.

References to "you" and "your" in these Terms of Use are to a person who accesses and/or uses the Website. References to "we" and "us" in these Terms of Use are to Commercial Trust Limited.

Commercial Trust Limited is a company registered in England and Wales under company number 8633445, whose registered office is at St. Crispins House, Duke Street, Norwich NR3 1PD.

We are authorised and regulated by the Financial Conduct Authority, registration number 610175. Our VAT number is 765 3535 12.

Your agreement to the Terms of Use

Your access to, and use of, this Website is subject to these Terms of Use and to our Privacy Policy.

By accessing and using this website (including by downloading any document that can be downloaded from or via this Website) you agree that these Terms of Use and our Privacy Policy apply to you and to your access to, and use of, this website and that you will be bound by, and comply with, these Terms of Use and our Privacy Policy.

If you do not agree to these Terms of Use and our privacy Policy you must stop using this Website immediately and must not download any material from or via this Website.

Permitted use of this website

You may access and use this Website only to find out about and make applications for mortgages and other products in respect of which we act as a broker and to seek general guidance on matters of relevance to the letting of property.  Any other use (including any use that is not for you personally or in connection with your own business involving the letting of residential property) is not allowed.  So, for example, you may not access and use this Website on behalf of someone else and/or in connection with a business other than your own business involving the letting of residential property.  

If you provide any information or material on, downloadable from, linked to from, or accessible via, this Website to another person you will be responsible to us for their use of, and reliance on, that information or material in the same way that you would be if their use of, or reliance on, that information or material was use of, or reliance on, that information or material by you.

Access to this website

Access to this and any other websites we may provide is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on this Website or any other such websites without notice (see below). We will not be liable if for any reason this Website or any other such website is unavailable at any time or for any period.

From time to time, we may restrict access to some parts (or all) of this Website or any other of our websites to users who have registered with us.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if we believe that you have not complied with any of the provisions of these Terms of Use. You are responsible for making all arrangements necessary for you to have access to this Website and of our other websites. You are also responsible for ensuring that all persons who access this Website and of our other websites through your internet connection are aware of these terms, and that they comply with them.

Limitation of our liability in respect of the use and content of this Website and the need to obtain competent advice

There are many factors that may affect the legal, financial and other consequences of owning and letting out property, including, but not limited to, the suitability and effectiveness of the documentation used in the particular circumstances in which it is used, the steps you take to meet your statutory obligations as a property owner and landlord, the scope of, limitations on, and the effectiveness of, any insurance cover, the terms on which monies are lent to you and the tax that you (or others) may be or become liable to pay (such as, but not limited to, Income Tax, Corporation Tax, VAT, National Insurance Contributions, Stamp Duty Reserve Tax (or its equivalent in jurisdictions other than England), Capital Gains Tax and Inheritance Tax).

The relevant laws and rules may be subject to frequent change, including changes made with little or no prior notice, or even with retrospective effect. As, by using this website, you are agreeing that we are not liable to you in any way for the consequences to you or others of the use of (including reliance on) any Materials (as defined below), we recommend that, to the extent that you do not possess the relevant skills, knowledge or expertise, you take competent professional advice that you can rely on in respect of all of these, and other relevant matters, and that you ensure that any advice you have received remains up to date and takes into account relevant developments, including changes in your circumstances.

Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence.

We will use our reasonable endeavours to correct any errors on this Website and on material downloadable directly from it within a reasonable time of being made aware of them, but neither we nor anyone else represents, warrants or guarantees that information or material on, downloadable from, linked to from, or accessible via, this Website:

• was, is or will be accurate or complete at any time
• is suitable for any particular purpose or in any particular circumstances.

We do not accept any responsibility for any content or any other aspect (including links) of any website to which the Website may be linked (“Linked Sites”) or sites linked to or from any Linked Sites.

You acknowledge that anything on, downloadable from, linked to from, or accessible via, this Website (“Material”) may contain inaccuracies or errors, may be incomplete and may not be fit for any purpose that you or anyone else intends to use it.

Regardless of what may be stated to the contrary therein, we make no representation that any Material is suitable for any particular circumstances or any particular purpose.

No Material constitutes advice and we accept no responsibility for any reliance that may be placed on it by you or anyone else or any consequence of its use by you or anyone else for any purpose or in any circumstances.

You agree that you will not seek to place, and will not invite, recommend or encourage any other person to seek to place, reliance on Material in any way which may create a liability of us to you or any other person.

You acknowledge that, before using any information or material on, downloadable from, linked to from, or accessible via, this Website in any way that may create a liability for you or any other person or that may cause you or any other person to suffer harm or loss, you will seek the advice of a suitably qualified person regarding the suitability of such information or material for the purpose for which you or such other person intends to use the same and that you or such other person will make all necessary deletions from or amendments or additions thereto as may be necessary to make the same suitable for their intended purpose.

Your indemnity of us in relation to this Website

IMPORTANT – IF YOU DO NOT UNDERSTAND THE IMPLICATIONS FOR YOU OF THIS INDEMNITY YOU SHOULD TAKE ADVICE BEFORE USING INFORMATION OR MATERIAL ON, DOWNLOADABLE FROM, LINKED TO FROM, OR ACCESSIBLE VIA, THIS WEBSITE

You will indemnify us for all liabilities, costs, expenses, damages and losses (including but not limited to any direct, indirect or consequential losses, loss of profit, loss of reputation and all interest, penalties and legal costs (calculated on a full indemnity basis) and all other reasonable professional costs and expenses) suffered or incurred by us arising out of use by you (or by others where this has been facilitated by you, including, for example, use of your equipment, connections, web access or other facilities) of any Material.

Links

Any links on this Website to Linked Sites are for your convenience and to provide further information.  They do not signify that we endorse the Linked Site(s).

We are not responsible for the content or operation of websites that are not run by us and your use of any website other than this Website (including Linked Sites) will be governed by the terms and conditions of use and privacy policy applicable to that website.  These are likely to be different to those that apply to this Website.

It is your responsibility to ensure that you understand and agree with the terms and conditions of use and privacy policy of any other website when you use that website.

Changes to Terms of Use

We may change these Terms of Use at any time and will always post the current version on this Website.  If you continue to use this Website after a change to the Terms of Use you will be deemed to have agreed to the Terms of Use as changed.  You are, therefore, advised to check this part of the Website regularly.

Intellectual property rights

We are, or are licensed by, the owner in respect of all intellectual property rights in this Website and in the materials published on it.  Those materials are legally protected.

If you print off, copy or download materials from the Website (which you may do, but only for your personal use) you must not:

  • alter those materials
  • use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text; or
  • unless we have given our consent in writing, use any part of those materials for any commercial purpose.

Jurisdiction and applicable law

The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to this Website.

These Terms of Use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) will be governed by, and construed in accordance with, the laws of England and Wales.

Privacy policy

Commercial Trust understands how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of the personal information we hold about you, and what we do with that information. 
Commercial Trust may change its Privacy Policy from time to time.

The policy was last updated May 2018.

Commercial Trust understands how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of the personal information we hold about you, and what we do with that information.
Commercial Trust may change its Privacy Policy from time to time.

The policy was last updated May 2018.

Company details

  • Telephone: 01603 896878
  • Email: info@commercialtrust.co.uk
  • Commercial Trust is a company registered in England and Wales, company number 08633445
  • Registered office: St Crispin’s House, Duke Street Norwich NR3 1PD
  • VAT number GB765353512
  • Authorised and regulated by the Financial Conduct Authority (FCA) Reference no. 610175
  • Registered with the Information Commissioner’s Office. Reference No. ZA041124

Data Protection Officer

You can contact our data protection officer by telephone, email or post at:

Data Protection Officer, Commercial Trust, Norfolk Tower, 48-52 Surrey Street, Norwich NR1 3PA

Telephone: 01603 896 878

Email: dpo@commercialtrust.co.uk

Gathering information from you at initial enquiry

There are a number of ways contact between us may arise, these are described below.

Our Website

You may choose to contact our company, having visited our website, in a number of ways.

Some of the ways data passes from you to us is handled using technology our company has built and controls, such as our website forms.

Other ways data passes from you to us may use technology we pay a third party to provide, such as our Live Chat interface.

These methods of contact are described below.

1. Enquiry form

By submitting an enquiry form you are agreeing to us contacting you via telephone, email, SMS and letter about your enquiry.

Changed your mind about hearing from us? See “Stopping attempts at contact” below.

Lender deals and landlord news

Before submitting an enquiry form, you will be asked whether you would like to be kept informed of lender deals and landlord news, with the option to receive this information via email, SMS, telephone or letter.

If you do not give your consent, you will not be sent this information.

If you do give your consent, you are giving us permission to send you this information via the channel(s) you have stipulated.

You can adjust your contact preferences or opt-out at any time by visiting our Contact Options form.

These consents do not affect any interactions you may have with our advisor team relating to the conduct of our service (see “Interactions regarding our service” below).

2. Call-back form

By submitting your details via our call-back form, which you may see on a number of pages on our website and is specifically identified as such, you are agreeing to our advisor team calling you on the number you have submitted to discuss our service with you (see “Interactions regarding our service” below).

Changed your mind about hearing from us? See “Stopping attempts at contact” below.

3. Email newsletter sign-up form

By submitting your details via our newsletter sign up form, which you may see on a number of pages on our website and is specifically identified as such, you are agreeing to our sending information about our industry to you via email.

Changed your mind about hearing from us? You can adjust your preferences or opt-out at any time by visiting our Contact Options form.

4. Email communications

We use a third party platform to facilitate the sending of some of our emails. The software is provided by a company called PurePromoter Limited, trading as Pure360, who operate as a Data Processor for Commercial Trust Limited. When you work with us, or subscribe to receive information from us, the following details are held on the Pure360 platform to enable us to send you process emails and informational emails (if you have opted to receive informational emails):

a) Your email address
b) Your first and last name
c) Your telephone number
d) Your marketing preferences

These details reside on Pure360 servers. Your data will not be transferred outside the European Economic Area unless; the receiving country has adequate protection in place; appropriate safeguards have been imposed and you have enforceable rights and effective legal remedies; or, you have given prior written consent, having been made aware of possible risks. Replies to emails sent to you come directly to Commercial Trust Limited only.

Wherever and however your data is processed, Pure360 adheres to processes and measures necessary to adequately protect your data.

For information on the Licence Agreement between PurePromoter Limited, trading as Pure360 and Commercial Trust Limited, which outlines their data protection obligations , visit these pages of their website: https://www.pure360.com/licence-agreement/

Copies of email correspondence between you and your advisor (if applicable) are saved on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

5. SMS communications

We use a third party platform to facilitate the sending of our SMS. The software is provided by a company called FastSMS Limited who operate as a Data Processor for Commercial Trust Limited.

When SMS communications are sent by us to you, or by you to us, they are handled by the FastSMS Limited platform, this means that some or all of the following information resides on the FastSMS Limited servers:

a) Your mobile phone number
b) Your first name
c) The message content

These details reside on FastSMS Limited servers. Your data will not be transferred outside the European Economic Area.

Wherever and however your data is processed, FastSMS Limited adheres to processes and measures necessary to adequately protect your data. Your data is subject to the FastSMS Limited retention period of 6 months; after which it is deleted from their platform.

For information on the security measure put in place by FastSMS Limited, visit these pages of their website: https://fastsms.co.uk/features/data-centres.html

Copies of SMS correspondence between you and your advisor (if applicable) are saved on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

6. Live Chat

We use a third party platform to deliver our Live Chat service to handle customer enquiries in real time. The software is provided by a company called Zopim, the Live Chat product is called Zendesk Chat.

When you interact with the Live Chat interface, the following details are recorded by Zendesk Chat:

  • Username (which may or may not be your actual name)
  • IP address (An IP address is a number sequence that identifies a device (not a user) that is connected to the internet. Some IP addresses are the same each time they connect to the internet, “Static IP” and some change each time “Dynamic IP”.)
  • Any data added to the Chat window
  • Operating System and version of Chat end user
  • Internet Browser and version of the Chat end user
  • Date and time of events as perceived by the app
  • Any data in attachments.

If you use the Live Chat service and you request to speak to a member of our advisor team we may ask you for your name, telephone number and email address in order to arrange contact with our advisor team. This is optional.

The details of your Live Chat conversation reside on Zopim servers. Zopim operates in a number of countries worldwide, for this reason your personal data may be processed outside the European Economic Area (EEA). Furthermore, Zopim may use “sub-processors” (third parties) to help them in the conduct of providing their service.

Wherever and however your data is processed, Zopim adheres to processes and measures necessary to adequately protect your data.

For information on how Zopim secures the data that exists on the Zendesk Live Chat platform, visit these pages of their website: https://www.zendesk.co.uk/product/zendesk-security/

Your Live Chat conversation will also be passed to the advisor team so that they understand the nature of your enquiry.

Advisors usually save chat interactions with your client records on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data – retention periods / how we keep your data”).

Telephone calls

All of our calls are recorded and may be monitored to resolve queries or complaints, improve our service quality and to detect or prevent fraud or other crimes. Telephone calls may also be monitored for staff training purposes.

SMS, Email, Letter or other correspondence

If you make your first enquiry with us via SMS, Email, Letter or any other means, we will attempt to call you to resolve your request.

This is because we have to have first-hand contact with you to conduct our service compliantly and we have to verify your identity.

Where you are engaged in ongoing dialogue with our staff, regarding a case we are handling for you, we keep copies of SMS, Emails and Letters between us, in order to efficiently and accurately conduct our service on your behalf.

Interactions regarding our service

If you have made an enquiry to our company regarding our broker service, we will attempt to contact you up to three times a day for seven days, to ensure we have made every effort to respond to your request for information.

Our team may use telephone, email, SMS or letter to contact you regarding our service.

Gathering information from you, beyond initial enquiry

What information do we collect from you?

During the enquiry/application process we will collect personal and financial information (including but not limited to):

  • Name, address and postcode
  • Employment type and income
  • Contact information including telephone numbers and email addresses
  • Date of Birth
  • Address (residential history)
  • Property details
  • Credit history
  • Details of existing credit commitments (including car finance and hire purchase)

We do not request or process ‘sensitive’ information (such as medical records) during the application process. If sensitive information is provided to us, we will ask for your explicit consent prior to recording it.

Legal basis for processing personal data

When we process your personal data, including performing credit searches with one or more lenders, we do so because this is required to progress your mortgage enquiry and potential mortgage application. Such processing is a requirement of the service you have requested.

How we use the information we collect from you

The information gathered is used to:

  • Process your application
  • Assess your needs and make an appropriate recommendation
  • To keep your broker (if any) informed about the progress of your loan application
  • Keep you updated on the progress of your application
  • Electronically verify your identity
  • Administer your application
  • Record and respond to complaints
  • Improve our services
  • Statistical analysis, research and behavioural analysis.

Consequences of processing – credit decision

As your mortgage broker, we will discuss your personal circumstances with mortgage lender/s, in order to determine the most appropriate product for your needs. In order to make a recommendation we will complete a credit search with one or more lenders. These searches may be seen by other organisations searching in the future. Details of the search will be recorded whether you proceed with the application or not.

Legal basis for processing personal data – Anti fraud

When Commercial Trust process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with the laws that apply to us. Such processing is also a contractual requirement of the services you have requested.

We may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data, and if you are considered to pose a fraud or money laundering risk, they could hold your data for up to six years.

Consequences of processing – Anti Fraud

If fraud or money laundering is identified, details will be passed to fraud prevention agencies to prevent fraud or money laundering. If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or to employ you or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or employment to you. If you have any questions about this, please contact us on the details above.

How we check your identity

We will search credit reference agency files who, will provide details and information from the Electoral Register to verify your identity. The agency keeps a record of the search, whether or not your application proceeds with us. Our search is not seen or used by lenders to assess your ability to obtain credit in the future.

We may also request physical forms of identification to enable us to proceed with your application.

Information sharing with brokers and others who introduce business to us (if applicable)

If you have been introduced to Commercial Trust by a broker (intermediary) or someone else, we may tell that person about our contact with you, the progress of any mortgage application that you may make with our help, and whether or not any such application is successful. We may also tell them about relevant dates, the type of loan we have helped you with and the loan amount.

This will be for the purposes of establishing whether any payment may be, or become, due to that person (or someone associated with them), the amount and timing of any such payment, for assessing their effectiveness in identifying suitable clients for us, for monitoring our relationship with that person and shaping their future conduct in identifying and referring to us possible new clients). We will not pass on to them details about the nature of any help we may have given to you.

Our commitment to you about your personal information

We will treat all your information as private and confidential (even when you are no longer a client).

We will not give your data to anyone else unless we have your express consent, except where we are required to do so by a court or regulator, or where disclosure is made at your request or with your consent in relation to arranging your mortgage.

Your rights

Your personal data is protected by legal rights, which include your rights to:

  • Object to our processing of your personal data
  • Request that your personal data is erased or corrected
  • Request access to your personal data.

Stopping attempts at contact

If you change your mind and are no longer interested in our service, you can:

  • Tell our representative when they contact you

Or contact our Data Protection Officer using your choice of the following options:

Data Protection Officer

  • Call 01603 896 878
  • Email dpo@commercialtrust.co.uk stipulating your first and last name and the telephone number you supplied so that we can identify you and update our records
  • Write to: Data Protection Officer, Commercial Trust, Norfolk Tower, 48-52 Surrey Street, Norwich NR1 3PA

Your right to erasure

In certain circumstances you have the right to have personal information erased. Any request for erasure will be dealt with in conjunction with our retention period table (below).

Accuracy of the data we hold about you

If you have reason to believe that the data we hold about you is inaccurate, please write to the Data Protection Officer at the address provided, detailing the error. We will promptly any information confirmed to be incorrect.

Future Marketing

If you have provided your consent, we will keep you informed of the latest products and industry news.

Future marketing contact may be made by letter, telephone email or SMS.

If you prefer not to be contacted by us, please e-mail your name, address and postcode to:

dpo@commercialtrust.co.uk or write to the Data Protection Officer informing us which communication channels you wish to restrict (i.e. telephone, text, e-mail).

If you wish to unsubscribe from all channels, please confirm that you wish to cease all future marketing.

Your right to access information that we hold about you (Subject Access Request)

Under General Data Protection Regulation, you have the right to have access to certain information we hold about you. Any request should be made to our Data Protection Officer.

There is no charge for submitting a Subject Access Request.

Upon receipt of a Subject Access Request Commercial Trust Ltd has one month to respond.

Other technology we use on our website

Google Analytics

Google Analytics software helps us analyse and report on website traffic, through the use of cookies, so that we can better understand visitor experience and to monitor the performance of our marketing activities.

More information about Google Analytics is available on the pages of their website: https://www.google.com/analytics/analytics/

Google Analytics cookies do not gather personally identifiable information about you.

For more information about cookies on our website, view our Cookie Policy.

Hotjar

Hotjar software helps us monitor how people use our website, through the use of cookies, by observing mouse movements and click interactions. We use this data to constantly improve the functionality of the website with you, the end user, in mind.

Hotjar assigns their own unique identifier to each website visitor, so personally identifiable data is not used.

Hotjar records the first three parts of a website visitor’s IP address, but not fourth part. This is so that the country you are in can be identified, but no more specific geographical data is recorded. As such, your anonymity is maintained.

More information about Hotjar is available on the pages of their website:

https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar

In accordance with General Data Protection Regulation, Hotjar made it possible to suppress entries into website form fields from being recorded.

We have implemented this change and as a result, our use of Hotjar does not gather personally identifiable information about you.

For more information about cookies on our website, view our Cookie Policy.

StackPath

Stackpath is the Content Distribution Network we use to help our website load more quickly within the internet browser of anyone visiting it.

Stackpath hosts cached versions of our website on various servers within its network, and the shortest route to those cached versions is used to load the website.

More information about Stackpath is available on the pages of their website: https://www.stackpath.com/ 

Stackpath cookies do not gather personally identifiable information about you, they only gather browser validation information.

For more information about cookies on our website, view our Cookie Policy.

Web server logs

Most website providers record what happens when their websites are accessed. This is done automatically and the result is saved and retained in what is known as a web server log.

This is a practice that is followed too for our website and, as a result, your IP address is amongst the data recorded and held in the web server logs for our website. The IP address recorded is specific to the device you are using to access our website.

Other information, such as the pages visited, the date and time of the visit and the technical specification of your device is also captured with, and is attributable to, the IP address of your device. This is recorded and held in the web server logs. Personal data that you type in is not captured in the web server log.

Our website is managed and maintained for us by a sister company, Norfolk Capital Management Services Limited, which produces and holds the web server logs for us.

We have a legitimate interest in producing and retaining web server logs. Web server logs are used by us to troubleshoot problems with our website, to help us determine which devices people are most commonly using to access our website, and to make improvements to the website as a result. We may also use the web server logs to identify and investigate suspicious activity and malicious attacks on the website.

We may provide information in our web server logs to people we have asked to help us maintain and develop our websites and to assist us in making our websites available to internet users.

We may also provide information in our web server logs to the police and other law enforcement agencies if we suspect criminal activity and, if they approach us, to assist them in the prevention, detection and investigation of criminal activity.

Our web server logs are deleted after a year. This mirrors the period for which internet service providers (ISPs) are legally required to retain their own logs.

For more information about web server logs, visit online encyclopedia Wikipedia.

Google reCAPTCHA

Google reCAPTCHA is a piece of security software provided by Google Inc. (Google). You will encounter it, if you submit a form on our website. The software is designed to identify that interactions with our forms are by a human and not an automated machine. This is done by asking you to complete a task or tasks, prior to being able to submit a form.

If you are not logged into a Google Account:

“The information we [Google] collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.”

Of this data, IP address is the only personally identifiable data recorded.

If a website visitor is logged into a Google Account:

Google also collects “information that we store with your Google Account, which we treat as personal information”.

For Google’s Privacy Policy visit: https://www.google.com/intl/en/policies/privacy/

For more information regarding reCAPTCHA, visit: https://www.google.com/recaptcha/

Third party licences for code

To build parts of the functionality on the Commercial Trust website, our development team have used a variety of code libraries. The details of the authors and the copyright associated with these libraries, can be found here.

Security of your data

Commercial Trust is committed to ensuring that your personal information is held securely. We have put in place various controls and procedures to protect and keep secure the information we collect online, on a recorded call or hold separately.

If you contact Commercial Trust you will be asked a number of security questions before we will discuss your application.

Questions about our privacy policy

If you have any questions or comments regarding our privacy policy, please contact our Data Protection Officer.

Your data - Retention periods / how we keep your data

Data type /information held Retention period Basis for retention

If you provide us with your details but do not progress as far as a credit search.

Mortgage application details including personal information (name, address, postcode)/documents submitted by you/correspondence/recorded telephone calls/IP address


12 months from the last contact with you*


*unless we have an overriding obligation to retain your details longer

Legitimate interest/regulatory requirement


May include:
Processing and assessing your application
Dealing with complaints
Respond to requests from various agencies such as Police and National Crime Agency

If you provide us with your details and we conduct a credit search and you decide not to progress with the application or the lender is unable to provide you with a suitable finance.

Application details including personal information (name, address, postcode)/documents submitted by you/correspondence/recorded telephone calls/IP address/credit history /bank accounts details /quotes.

12 months from the last contact with you*

*Unless we have an overriding obligation to retain your details longer.

Legitimate interest/regulatory requirement


May include:
Processing and assessing your application
Dealing with complaints
Respond to requests from various agencies such as Police and National Crime Agency

If you provide us with your details and we conduct a credit search and you obtain finance.

Application details including personal information (name, address, postcode)/quote documents/documents submitted by you/correspondence/recorded telephone calls/IP address/credit history/bank account details.

Proof of identification and proof of address will be held for 5 years from the end of the recommended finance term.*

Name, address, postcode, credit history, mortgage documents will be held for 6 years from the end of the recommended finance term*

*unless we have an overriding obligation to retain your details for longer

Legitimate interest/regulatory requirement


May include:
Processing and assessing your application
Dealing with complaints
Respond to requests from various agencies such as Police and National Crime Agency

Complaints data

Mortgage application and complaints information including personal information/application documents/correspondence/telephone call recording/date of complaint/redress paid/market consent and preferences

6 years from the date our recommended mortgage expired

Legitimate interest


May include:
For responding to the subject matter of a complaint
To avoid duplication of complaints

Consent to receive marketing from Commercial Trust

Your preferences , as recorded through communications through you

Retained until you ask to be deleted from marketing preferences Consent

Complaints

To register a complaint with Commercial Trust Limited, please visit our complaint page.

If you are not satisfied with our response or believe, we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

To register a complaint with the ICO, please visit https://ico.org.uk/make-a-complaint/for additional information.

Cookie Policy

This website uses cookies.

Cookies are text files containing small amounts of information which are downloaded to your device (e.g. computer, tablet, mobile phone) when you visit a website.

Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.

Cookies are useful because they allow a website to recognise a user's device.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improves the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

You can find more information about cookies at:

https://ico.org.uk/for-the-public/online/cookies/

For a video from Google that explains cookies visit: https://www.youtube.com/watch?v=TBR-xtJVq7E

Remarketing

Google remarketing is a method of advertising.

If you visit our website, you may subsequently see adverts from us when you navigate the internet.

Google works with a large number of websites across the internet that you may visit. To help us reconnect with you, Google can re-display our adverts to you via these websites.

Cookie list

Below is a list of the cookies used on this website.

Cookies for website delivery and functionality

The cookies described below contribute to how our website is displayed and your experience of it when navigating between pages.

Cookie list and descriptions
Cookie origin: Microsoft 
Cookie name Cookie duration Cookie description
ASP.NET_Sessionid Browser session Used to ensure that, for every browsing session, visitor page requests are routed to the same server. This helps ensure a smooth experience when using our website.

This cookie does not collect any personally identifiable data.

For more information, visit the Microsoft website: https://msdn.microsoft.com/en-us/library/ms178194.aspx

Cookie list and descriptions
Cookie origin: Stackpath 
Cookie name Cookie duration Cookie description
SPSI
PRLST
adOtr
UTGv2
Browser session Stackpath is a Content Distribution Network, it hosts cached versions of our website on a number of its servers. Your ASP can then find the best route for serving our website, in order to load it as quickly as possible.

This cookie does not collect any personally identifiable data.

For more information, visit the Stackpath website: https://www.stackpath.com/

Cookie list and descriptions
Cookie origin: Commercial Trust
Cookie name Cookie duration Cookie description
ctrustcookiepolicy 1 year, or until deleted Our cookie policy pop-up is displayed to website visitors. This cookie stops the pop-up reappearing if a website visitor navigates away from the page they arrive at. This cookie stops the policy pop-up reappearing when a visitor re-visits the website within one year of a previous visit, unless cookies are deleted.
ctrustinterstitial 30 days, or until deleted Website visitors may be asked, via a website pop-up, whether they would be interested in receiving landlord news and lender deals from us. This cookie ensures the pop-up is only displayed once.

These cookies do not collect any personally identifiable data.

Cookie list and descriptions
Cookie origin: Cloudflare
Cookie name Cookie duration Cookie description
__cfduid 1 year Speeds up web page load times.

This cookie does not collect any personally identifiable data.

For more information, visit the Cloudflare website: https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do-

Cookies for website monitoring and marketing performance

The cookies described below relate to our use of:

Google Analytics – used to track and report on traffic that visits our website
Hotjar – used to monitor mouse clicks and screen scrolls so we can understand how visitors use our website
Commercial Trust tracking – used to both personalise a visitor’s experience of our website and to record which of our advertising campaigns is driving traffic to our site.

Cookie list and descriptions
Cookie origin: Google Analytics
Cookie name Cookie duration Cookie description
_ga 2 years Used to distinguish users
_gid 24 hours Used to distinguish users
_dc_gtm_<property-id> 1 minute Restricts the number of calls made to the Google Analytics API
AMP_TOKEN 30 seconds to 1 year Contains a token that can be used to retrieve a Client ID from AMP (Accelerated Mobile Page) Client ID service. Accelerated Mobile Pages are those designed to load quickly on a mobile device.
_gac_<property-id> 90 days Contains marketing campaign related information for website visitors.
_utma 2 years from set/update Tracks the first and last visit of each visitor to our website
_utmb 30 mins from set/update Sets a timestamp when a visitor enters our website
_utmc Expires at end of browser session Sets a timestamp after 30 minutes, if another page view does not occur. Works with _utmb to work out how long a visitor is on our website.
_utmt 10 minutes Restricts the number of calls made to the Google Analytics API
_utmz 6 months from set/update Stores the traffic source or campaign that explains how a visitor has reached our website.
_gaexp Typically 90 days Google Analytics enables experiments to be run which seek to demonstrate how website visitors respond to different pages, page layouts, or content. This cookie is used to determine a website visitor's inclusion in an experiment and the expiry of experiments a user has been included in. Duration is determined by the length of the experiment, but this is typically 90 days.
_gali Browser session Improves accuracy of analytics reports.
_gat_UA 45 seconds Restricts the number of calls made to the Google Analytics API.
1P_JAR 1 month Registers statistical data
DSID Browser session to 6 months Links user activity across devices, if you are signed into a Google account.

Not logged in to a Google account: May record IP address.
Logged into Google account: Any data you have already shared with Google.

For more information:

Google Analytics website: Google Analytics cookie usage

Google privacy policy: https://privacy.google.com/your-data.html

Cookie list and descriptions
Cookie origin: Hotjar
Cookie name Cookie duration Cookie description
_hjIncludedInSample 365 days Hotjar software lets us monitor mouse movements, clicks and screen scrolls, so that we can assess how successfully website visitors find using our website. In order to identify the country a website visitor is in, the first three parts but not the fourth part of a user’s IP address is recorded. Data collected by Hotjar from our Website is for our internal use only. The information collected is used to improve website usability and is stored and used for aggregated and statistical reporting.

This cookie does not collect any personally identifiable data.

For more information, visit the Hotjar website: https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar

Cookie list and descriptions
Cookie origin: Commercial Trust tracking
Cookie name Cookie duration Cookie description
ctrustspotcode 30 days, or until deleted or overwritten Website visitors may reach our website having clicked through from an advert we have paid for. This cookie records a code we refer to as a “spotcode” that indicates to us which advertising source has generated the visit. This helps us optimise our marketing campaigns.
ctrustcampaign 30 days, or until deleted or overwritten Website visitors may reach our website having clicked through from an advert we have paid for. This cookie records the campaign name we assigned to the advertising that has generated the visit. This helps us optimise our marketing campaigns.
ctrustterm 30 days, or until deleted or overwritten Website visitors may reach our website having clicked through from an advert that we have paid to appear on a search engine when specific search phrases are used. This cookie records the search phrase that has generated the visit. This helps us optimise our marketing campaigns.
ctrustcmsid 10 days, or until deleted or overwritten If a website visitor interacts with a rates table, this cookie records the page the table is on. This helps us understand how visitors are using our website.
Ctrustpid 10 days, or until deleted or overwritten If a website visitor interacts with a product within a rates table, this cookie records the product in question. If the visitor submits an enquiry form, the details of the most recent product the user was looking at is passed on to the advisor handling the enquiry. This helps us understand how visitors are using our website and the type of product they are interested in when enquiring.
Ctrustuniqueid 10 days, or until deleted or overwritten If a website visitor requests a free download, this code is generated and added to a link sent to the individual by email. When the individual clicks through to the website, the code enables the document to be downloaded.

These cookies do not collect any personally identifiable data.

Cookies for security and consents

Cookie list and descriptions
Cookie origin: Google
Cookie name Cookie duration Cookie description
APISID 2 years Used for security purposes.
CONSENT 20 years Used for cookie consent.
HSID 2 years Used for security purposes.
SAPSID 2 years Used for security purposes.
SID 2 years Used for security purposes.
SIDCC 3 months Used for security purposes.
SSID 2 years Used for security purposes.

Not logged in to a Google account: May record IP address.
Logged into Google account: Any data you have already shared with Google.

For more information:

Google privacy policy: https://privacy.google.com/your-data.html

Cookies for advertising personalisation and preferences

Cookie list and descriptions
Cookie origin: Google
Cookie name Cookie duration Cookie description
DV Browser session Google ad personalisation.
IDE 1 year Google ad personalisation.
NID 6 months Used to remember your preferences and other information, such as your preferred language settings.
OGPC 2 months Used by Google to save user settings when the user views pages with embedded content from Google Maps.
Cookie list and descriptions
Cookie origin: Microsoft
Cookie name Cookie duration Cookie description
MR 6 months Used to store your preferences and settings, help with sign-in, provide targeted ads, and analyze site operations.

Cookie information and privacy statement: https://privacy.microsoft.com/en-us/privacystatement/

How to delete cookies

Below you can access information on private internet browsing and how to delete cookies within some commonly used internet browsers.