Privacy policy
About us
This section tells you about us and how you can contact us
The Introducing Broker Finance Hub Ltd is a limited company registered in England & Wales. Our registered office is 39 High Street, Orpington, BR6 0JE and trading address is: Unit 4 Cumbrian House, 217 Marsh Wall, Canary Wharf, London, E14 9FJ.
To help ensure we meet all our legal and regulatory obligations, we have appointed a Data Protection Officer. If you have any questions or concerns about how your personal information is being used, you can contact our data protection officer using the below details:
Telephone: 020 3962 5000
Email: compliance@tibfinancehub.com
Or by writing to:
The Data Protection Officer
Unit 4 Cumbrian House,
217 Marsh Wall,
Canary Wharf,
London,
E14 9FJ.
You can also obtain advice and support from The Information Commissioners Office (ICO) who is the independent regulator appointed by Parliament to oversee the compliance with data protection and information rights. You can visit the website here: https://ico.org.uk.
The Introducing Broker Finance Hub Ltd is registered with the Information Commissioner Office with the registration number: ZB673579.
- What information we collect and how we use it
- What are the legal grounds for handling personal information?
- Who we share your personal information with
- Where in the world do we send information
- Your information rights.
- How we keep your personal information secure
- How long do we keep your personal information for?
- Use of Cookies
- Changes to this notice
1. What information we collect and how we use it
This section summarises what information we collect from you when you contact us, what information we collect from elsewhere and how this information is used.
Mortgage Customers
At The Introducing Broker Finance Hub Ltd., our core business is acting as a mortgage broker. This involves searching among the lenders we work with to find the mortgage that best fits your individual circumstances. To do this, we gather a range of information when you contact us, such as your identity and contact details, product preferences, property and tenancy history, and details about the occupants of your property. We also ask about your lifestyle, nationality, residency status, employment, income, expenses, and other financial circumstances. The specific questions we ask depend on your responses, as different lenders cater to different segments of the market and have varying eligibility criteria.
We will always explain the process to you and answer any questions you may have regarding the types of information required and why it is needed.
When you apply for a mortgage through us, we collect your direct debit details to pass on to your lender. If the product requires an upfront cost, such as a valuation fee, we will request your payment information.
Please note that mortgage lenders act as data controllers in their own right and have their own privacy policies. As lenders may automatically profile your information against their lending criteria and check it with Credit Reference Agencies, which may affect your credit score, we will always make you aware of this in advance. Additionally, we will notify you ahead of time if lenders are likely to debit funds from your accounts.
Insurance Customers
We routinely offer our mortgage customers life insurance and buildings and contents insurance as part of our service. If you’re interested in life insurance, we may need to collect additional health information, which is necessary for the insurers to determine appropriate cover and premiums.
In addition to offering insurance alongside mortgages, we also provide standalone protection advice. Whether you’re seeking life insurance, critical illness cover, income protection, or business protection policies independently of any mortgage application, we will work with a wide range of insurers to find the most suitable cover for your needs.
We may also record information about potential vulnerabilities if we believe it’s appropriate, ensuring we meet our obligations to vulnerable customers as required by the Financial Conduct Authority (FCA). You can learn more about those obligations here.
Business Finance
In addition to mortgages and protection services, we also offer business finance solutions. This includes advising and sourcing finance for businesses, such as development finance, bridging finance, commercial mortgages, and other tailored financial solutions. Whether you are a limited company, LLP, or larger enterprise, we can help you explore funding options to support your business goals.
We work with a variety of lenders who specialise in different areas of business finance. When you approach us, we’ll ask for details about your business structure, financial standing, and funding requirements to ensure we recommend solutions that align with your specific needs and objectives. We will explain each stage of the process and answer any questions you may have, ensuring you’re fully informed.
If you select a finance product through us, we will also collect your payment details to pass on to the lender or finance provider, should any fees or charges be associated with the product.
Updating Your Details
If you are a returning client of The Introducing Broker Finance Hub, we may use the information you provided previously to assist you in future interactions. This allows us to streamline the process and save you from re-entering your details. Rest assured, we will always verify that the information is accurate and up to date before proceeding.
Telephone Calls
We record incoming and outgoing phone calls to ensure the accuracy of information provided and for training and monitoring purposes. This helps training and development needs and helps prevent fraud and resolve disputes when they arise.
Profiling, Marketing, and Market Research
We may use your information to offer other products that align with your profile. If we ask for consent to contact you about these products, we will clearly explain the methods of communication and ensure you can opt out at any time using your preferred method.
Separately, if you have taken out a mortgage or insurance product with us, we will contact you before your product expires to ensure you can access the best rates on a new deal. If you prefer not to be contacted for this purpose, simply inform us, and we will update your records accordingly.
To improve our targeting for online audiences, we work with organisations like Experian and platforms such as Facebook. These partners help with data matching, segmentation, and profiling, ensuring any data used for marketing remains anonymised. We ensure that third parties do not use our customer data to enrich their own databases. Online platforms also allow you to control marketing preferences via their privacy settings.
We may also contact you for market research purposes, and while we occasionally run promotions or competitions, we will not use your contact details for marketing unless you consent separately.
Money Laundering and Preventing Unlawful Acts
As required by law, we submit Suspicious Activity Reports to the National Crime Agency when detecting risks of money laundering or fraud. We are also obligated to disclose personal data where required by law or court order. Additionally, we may disclose personal data where necessary to protect the public against dishonesty.
Cookies, Email Tracking, Pixel Data and Analytics
We use services like Google Analytics and the Meta Pixel to track visitor activity on our website and/or social media to understand trends and improve user experience. These reports do not identify individuals.
Our Cookies Policy details the specific cookies we use and how you can control advertising cookies via your browser.
We also use email tracking technology to capture information such as when emails are opened, the type of device used, and which links are clicked. We share this information with relevant third parties, such as mortgage lenders or protection providers, but ensure your details are not used for marketing without your consent.
Similarly, we use telephone tracking technology to capture information like call times, device types, and the webpage a customer called from.
Social Media
We monitor public comments about The Introducing Broker Finance Hub Ltd. on platforms like Facebook and Twitter to help improve our products and customer service interactions.
Information Collected Indirectly
When you apply for a product, we are legally required to confirm your identity, which helps prevent financial crime and identity theft. We may verify your details using databases from credit reference agencies and the electoral roll. If this isn’t possible, we may ask for additional documents. This verification process does not affect your credit history.
For joint mortgage applicants, we will record any information about others linked to the application.
If you are referred to us by an estate agent, our data collection forms may include comments about potential purchases, which agents sometimes provide.
Ancillary Services
We use the information we collect to ensure a seamless customer experience, such as sending renewal reminders and resolving complaints or investigations.
We may also disclose information were allowed by law to resolve legal disputes and pursue legal rights.
Automated Decision-Making
We do not engage in fully automated decision-making. Instead, we provide lenders and insurers with the necessary information to make decisions about the products you’ve selected.
Reviews
If you provide us with a positive review, we may ask your permission to share it publicly.
2. What are the legal grounds for handling personal information?
To comply with the law, we must meet at least one of the six standard conditions to process your personal information. Additionally, when processing special category data, such as health information, stricter conditions apply.
The law requires us to have a legal basis for processing personal data. There are six main grounds or conditions for doing so. When it comes to special category data (e.g., health, genetic, or biometric data), we must also satisfy a specific condition for that type of processing.
We rely on the following conditions, depending on the activity:
Legitimate Interests | In most cases, you provide personal information because you wish to use our services. While many businesses rely on a contractual basis for data processing, we cannot, as intermediaries, rely on this condition. Instead, we rely on legitimate interests. This means we process your data in ways that you would reasonably expect, with minimal impact on your privacy, unless your privacy rights override our interests. We use this condition for the purposes listed in Section 2, except where another condition is more applicable. |
Consent |
Your consent must be freely given, specific, informed, and unambiguous. We rely on consent for:
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Explicit Consent |
For special category data (e.g., health data or trade union membership revealed through income proof), we require explicit consent. This applies to:
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Legal Obligation |
We process personal data to comply with legal obligations, such as:
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Public Interest |
We process personal data in the public interest when necessary, such as:
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Substantial Public Interest |
For specific situations of substantial public interest, such as:
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Contractual Obligation | When processing personal data for contracts with contractors, suppliers, or staff, we rely on contractual necessity. (Note: We have a separate privacy notice for employee data processing.) |
3. Who we share your personal information with
Find out who we need to share information with to deliver our services to you and when you have a choice about who we share your information with.
To fulfil our contractual obligations, we’ll also share your personal data with the following third parties (privacy policy links provided where not provided at a later stage):
- Mortgage Lenders
- Life Insurers
- General Insurance Providers
- Business Finance Lenders
- Uinsure/The Source for building and contents insurance intermediaries
- Estate agents (if you were introduced to us by one of our estate agent partners)
- Lead suppliers (if you were introduced to us by a third party)
- Our personally recommended conveyancers where you wish to proceed with a quote.
- Experian for AML Checks, profiling, and segmentation (https://www.experian.co.uk/privacy)
To help you benefit from the services of our expert partners, we’ll also share your personal data with the following organisations – but only with your consent (privacy policy links provided):
- Brickflow commercial, Development and bridging finance enquiries
- Berkley Alexander for commercial and personal protection needs (https://www.baonline.co.uk/toba)
- Brilliant Solutions for credit impaired mortgage enquiries, case packaging, advice if you are living abroad or complex case enquiries (https://brilliantsolutions.co.uk/)
- Mortgage Broker Tools to check lenders’ affordability calculators (https://w3.mortgagebrokertools.co.uk/privacy-policy)
- Unsure for building and contents insurance (https://uinsure.co.uk/customer-privacy-notice/)
- Buildstore for self-build or development mortgage finance (https://www.buildstore.co.uk/privacy-policy)
If you no longer wish us to share your data with any of these organisations, you may withdraw your consent at any time.
Both the above sets of organisations are each data controllers in their own right and will have their own Privacy Notices that will tell you about how your personal data will be used by them.
We’ll also share your personal data with the following data processors where necessary to fulfil our services and regulatory obligations (privacy policy links provided):
- Finova – Customer Relationship Management and Compliance Software (https://www.finova.tech/privacy-policy)
- IRESS to provide life insurance quotations and process mortgage applications (https://www.iress.com/resources/legal/privacy-policy/)
- XPlan to provide mortgage illustrations (https://www.iress.com/resources/legal/privacy/)
- CircleCloud who provide our telephone and call recording software (https://circle.cloud/privacy-policy/)
- Survey Monkey to conduct market research (https://www.surveymonkey.co.uk/mp/legal/privacy/)
- Underwrite me for life insurance (https://www.underwriteme.co.uk/protection-platform-privacy-policy/)
- CI Expert for Critical Illness cover (https://ciexpert.uk/legal/privacypolicy/)
- reviews.co.uk for customer reviews (https://www.reviews.co.uk/front/user-privacy-policy)
- Trust Pilot for customer reviews (https://uk.legal.trustpilot.com/for-reviewers/end-user-privacy-terms)
- Online Advertising Platforms such as Linkedin, Facebook, Bing, and Google. (https://www.linkedin.com/legal/privacy-policy, https://www.facebook.com/privacy/explanation, https://privacy.microsoft.com/en-us/privacystatement, https://policies.google.com/privacy?hl=en-GB&fg=1)
- Kratos IT for managed IT, data backup and restore services (https://kratosit.co.uk/privacy-notice/)
Sharing information with these organisations allows us to better understand your needs.
4. Where in the world do we send information?
As a UK-based company, the majority of our personal data processing takes place within the United Kingdom and the European Economic Area (EEA), which maintain strong data protection standards under UK and EU law.
However, on limited occasions, your personal information may be transferred outside the UK and the EEA. When this happens, we ensure that the necessary safeguards are in place to protect your data, as required by data protection laws. Where relevant, we will always work with trusted providers that meet the required standards of data protection to ensure your personal information is treated securely and in accordance with this privacy policy.
5. Your Information Rights
This Section summarises the legal rights you have to protect your personal information and how you can exercise them and find impartial advice and further information.
The following is a list of the rights you have under Data Protection legislation. Not all these rights apply in all circumstances, but we will be happy to explain this to you at the time you ask. Independent advice about your rights can be obtained from the Information Commissioner.
All these rights can usually be exercised free of charge and generally speaking we must respond within one month. If we need longer to respond we will explain why this is necessary within the one-month period and tell you more about any rules that affect how you can exercise your rights.
Informed | You have the right to be informed in a concise, transparent, intelligible, and easily accessible way about how we use your personal information. We will explain why we need information (in particular any uses that are not obvious) at the time we collect information from you and make sure that all our data collection forms and letters point you to this Privacy Notice. |
Access |
You can make what is called a subject access request for a copy of the information we hold about you. We must also tell you why we have the information, what types of information we collect; who we share it with and whether, in particular, any of those recipients are outside the European Economic Area; how long we will keep your information for; where the information came from, if we didn’t collect it from you directly; the details of any automated decision making and about your rights of complaint to the Information Commissioner. |
Portability | You have the right in some circumstances to have the data you have provided to us sent to you or provided to another person or business in an electronic machine-readable format. Where this applies, we will download the information and send it as a CSV file. |
Correction | You have the right to have inaccurate information corrected and incomplete information completed. If the information we need to deliver our services to you changes, please tell us about this as soon as possible. |
Object |
You will normally have the right to object to how we intend to use your information based on your individual circumstances. You have an absolute right to object to us using your personal information for the purpose of direct marketing at any time. |
Restriction | If you have objected or complained about how we have used your information or its accuracy, you may not want it to be deleted until your complaint has been resolved. In certain circumstances you can ask for your data to be restricted or not used until these issues are resolved. |
Erasure | You have a right to have some or all of the information we hold about you erased in some circumstances. This is known as the right to be forgotten. |
Automated Decision Making |
This right only applies where a decision which has a legal or similar effect is taken about a person by automated means without any human intervention. Where such decisions are made individuals have a right to ask for the decision to be reviewed and the data controller must make sure appropriate safeguards are in place. However, L&C does not make automated decisions about any of its clients. |
Consent | If we are processing your personal information on the basis of your consent you have the right to withdraw that consent at any time. |
Complaint |
You have a right of complaint to the Information Commissioner (the Supervisory Authority) if you consider any aspect of L&Cs use of your personal information infringes the law. Section 1 provides the contact details. However, L&C will want to put matters right wherever we can, and we would hope that you will contact us in the first instance. You can exercise your data protection rights or complain about how we are processing your personal information by contacting the Data Protection Officer as set out in Section 1. If your complaint is about the administration, or terms and conditions of a product sold by us but provided by a lender/insurer, you may need to contact them about it. If needed, we’ll forward details of your complaint to the lender/insurer concerned, as well as giving you their contact details. |
6. How we keep your personal information secure.
At The Introducing Broker Finance Hub Ltd, we are dedicated to safeguarding your personal information. This section outlines the robust security measures we implement to protect our customers’ data.
We understand the critical importance of keeping your personal information secure. To prevent accidental or unlawful breaches of security, we employ a variety of technologies and procedures, including physical, organisational, and technological measures.
All information we process is encrypted in transit, ensuring that your personal and financial details remain secure. For instance, when you share information with us online or we forward it to other organisations, we utilise HTTPS to protect your data. If you create an online account with us, you will need to set up a username and password. We encourage you to choose a strong password, and we have also implemented two-factor authentication to further enhance your account’s security.
We may need to share your information with third parties, such as lenders and insurers, to provide our services. We require all third parties we work with to apply appropriate security safeguards and adhere to all necessary laws and standards for protecting personal information.
7. How long do we keep your personal information for:
Data Retention Policy
We only retain your personal information for as long as necessary. This section explains the retention periods for different types of records. To ensure we meet our legal, regulatory, and customer obligations, The Introducing Broker Finance Hub Ltd will retain client information for the following timeframes:
- Client of a Lender/Insurer: If you become a client of a lender or insurer as a result of our advice, we will keep a full record of your interactions with us for the duration of the product term, plus an additional 6 years. This enables us to meet our regulatory obligations to demonstrate that we provided suitable advice and to address any complaints that may arise.
- Application Without Becoming a client: If you apply to a lender or insurer based on our advice but do not become a client of that institution, we will retain a complete record of your interactions for 6 years to comply with UK Money Laundering Regulations.
- Advice Without Application: If we provide advice on a financial product but you do not engage our services to apply to a lender or insurer, we will keep a full record of your interactions for 3 years. This helps us meet our regulatory record-keeping obligations regarding the suitability of our advice.
- Personal Information Collected Without Suitable Advice: If we collect personal information from you but are unable to provide suitable advice, we will retain a complete record of your interactions for 1 year. This allows for easier communication should you choose to re-engage our services within that time.
- Contact Requests: If you request us to contact you regarding our services by providing your name and contact information (e.g., phone or email) through an enquiry form (either on our site or a third-party site), we will make every effort to reach you as soon as possible. If we cannot contact you, we will retain this information for 180 days from the time we deactivate your lead in our database to fulfil our contractual obligations to our lead partners.
- Marketing Subscriptions: If our retention schedules indicate that a record is no longer required, but you are subscribed to our marketing communications, we will delete the associated event records and attachments while maintaining the case record itself. This allows us to know which messages are relevant to you.
We anonymise data in accordance with these retention periods on a programmed basis. A backup copy of the data is retained for a specified period to validate the anonymisation process.
8. Use of Cookies
A cookie is a small data file that a website asks your browser to store on your device, helping to remember information about you during your visits. At The Introducing Broker Finance Hub Ltd, we use cookies to enhance your experience on our website.
Types of Cookies We Use:
- Essential Cookies: These are necessary for the website to function properly and cannot be disabled. They enable services such as logging in and setting your privacy preferences.
- Performance Cookies: These help us understand how visitors use our site and improve its functionality.
- Functional Cookies: These enable enhanced personalisation and may be set by us or third parties.
- Marketing Cookies: These are used by our advertising partners to build a profile of your interests and display relevant ads across the web.
Your Consent: Essential cookies are always active. We will seek your consent for non-essential cookies, which you can manage via the ‘Shield’ icon on our site. Please note that disabling non-essential cookies may affect your experience.
Cookie Lifespan: Most cookies have a limited lifespan and will be automatically deleted after a set period. You can also manually remove cookies from your device at any time.
For more detailed information about the specific cookies we use, please refer to our cookie policy.
9. Changes to this policy
This policy was last updated 21/10/2024.
You can review this Privacy Notice for any updates regarding our processing of your personal information.
We are committed to regularly updating this Privacy Notice to ensure it remains clear, concise, and accessible, in line with our transparency obligations. If we make changes to how we process your personal information in ways that may not be reasonably expected, we will inform you and highlight these changes.