1. Why we have a Privacy Notice
We are committed to respecting and protecting your privacy. This Privacy Notice sets out the type of information we collect from you and what we do with that information.
2. About us
For the purpose of this Privacy Notice, Sprive Limited, a company incorporated in England and Wales with registered number 12102682 whose registered office is at Cannon Place, 78 Cannon Street, London, EC4N 6AF is the ‘Data Controller’. Sprive Limited are registered with the Information Commissioner’s Office. Our registration can be seen at https://ico.org.uk/ESDWebPages/Entry/ZA551896
Sprive has appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice, including any requests to exercise your legal rights. To contact our Data Protection Officer, please address:
(a) emails to firstname.lastname@example.org; or
(b) postal correspondence to the Data Protection Officer, Sprive Limited, Cannon Place, 78 Cannon Street, London, EC4N 6AF
We will ensure your query is responded to by our Data Protection Officer.
3. Other relevant policies and terms
4. Information we may collect:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data whether the identity has been removed (anonymous data).
4.1 Information you give us
During the course of creating an account with Sprive, the information you give to us may include:
Identity Data - such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, address and employment history, and citizenship
Contact Data - such as your address, email address and telephone number
Financial Data - such as your bank account details, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, mortgages held, and, if the lender requires, direct debit details, for instance if your chosen mortgage product requires any payment for things such as valuation. As an optional opt-in service, we obtain your credit score and credit report from one of the UK leading Credit Reference Agencies (CRA) on your behalf and refresh the report on a monthly basis.
Transaction Data - such as your bank account transaction information - but not your login or password - for example, purchase item, price, location, date. This data is provided with your consent through a third party Open Banking provider.
You may also provide us with certain information by filling in other forms, entering competitions or promotions or by corresponding with us by phone, email, text message or through our live in-App chat function.
Sprive does not collect any special categories of personal data about you (this includes details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or your biometric or genetic information). However, this may be subject to change if Sprive begins to sell mortgage protection insurance, which may require us to ask health related questions.
4.2 Information that Sprive collects or receives from other sources
We work closely with third parties (for example: business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies) and may receive the following information about you when you visit our website or use our App:
Technical Data - such as your IP address, URL, browser information, plug-in types, operating system and platform as well as your login information to the Sprive app.
Profile Data - such as your preferences, feedback and survey responses.
Usage Data - such as information about how you use our website, App, products and services.
Marketing and Communications Data such as your preferences in receiving marketing from us and your communication preferences (which we may also collect directly from you).
We may use the following cookies:
- Strictly necessary cookies required for the operation of our products or services (including, for example, cookies that enable you to log into secure accounts and use interactive features);
- Analytical/performance cookies that allow us to recognise and count the number of visitors and users and see how they use the products or services (e.g. (without limitation) to help us improve the way our products or services work or are provided, by ensuring that users are finding what they are looking for easily);
- Functionality cookies to help us recognise you when you return to our website (this enables us to e.g. (without limitation) personalise our content for you, greet you by name and remember your preferences, such as choice of language or region).
- Tracking cookies. These enable us to track use of content from the Platform (on third party services, such as posts on social media networks), in accordance with your third party settings.
- Targeting cookies to record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our products and services and the information displayed on it, which we reasonably think is more relevant to your interests. We may also share this information with third parties for this purpose.
4.4 Links to other websites
Our website or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
4.5 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract with you, and you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.
We may 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 does not directly or indirectly reveal your identity.
5. 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:
(a) to provide you with the products and services you have selected;
(b) 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; and
(c) where we need to comply with a legal or regulatory obligation.
We have set out below 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. We have also identified what our legitimate interests are where appropriate.
Type of data
Lawful basis for processing
To register you as a customer
To process and deliver selected products and services, including mortgage switching and facilitating mortgage overpayments
To monitor your mortgage and let you know when a better deal becomes available
To manage our relationship with you which will include:
To administer and protect our business, App and website), including, security, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting
To deliver relevant App and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
To use data analytics to improve our App, website, products, services, marketing, customer relationships and experiences
To de-identify your data (anonymise or aggregate)
To make suggestions and recommendations to you about products or services that may be of interest to you, via electronic means or otherwise such as email, SMS, pop ups or push notifications, targeted social media and our in-App secure notification centre
6. Disclosure of your personal data
We may share your information with selected third parties including:
- Albany Park Finance
- Prepay Technologies Ltd
- Aggregation Providers
- KYC Providers
- Payment services providers
- Mortgage lenders
- Lead suppliers (if you were introduced to us by a third party including refer a friend)
- Credit Reference Agencies (CRA) for identity checking and to obtain your credit score and credit report on your behalf and to provide our services to you
- Mailchimp and advertising and distribution providers for marketing campaigns
- Trustpilot, Facebook, SurveyMonkey and Google for customer feedback and reviews.
- Social media platforms such as Facebook for marketing
- Support and analytics services to help with technical issues
It's important to note that mortgage lenders and other third parties are also data controllers in their own right, and have their own privacy notices.
Credit Reference Agencies (CRA) - If you provide us consent to obtain your credit score and credit report to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated Credit Reference Agencies. In order to provide these services to you, we will share your information with such Credit Reference Agencies.
The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.
If you choose to apply for a mortgage via Sprive, the lender will undertake a full credit check and provide you with further privacy information for that product.
More information about each CRA and what it does with personal data is available here.
Mortgage advisers: If you have enquired about a mortgage or other financial product, we will share your personal data with an affiliated adviser who is able to provide financial advice in relation to your mortgage application.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We don't 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.
We'll also share your personal data with the following data processors where necessary to fulfil our services and regulatory obligations:
- Amazon Web Services to provide our web services
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK in instances where such professional services are required.
7. Storing your information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 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 legally required to do so.
Where we have given you, or where you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our website or App, you are responsible for keeping this password or PIN confidential. We ask you not to share this password or PIN with anyone.
7.2 Out of the EEA
Some of our external third parties are based outside the European Economic Areas (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:
(a) only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
(b) using specific contracts approved by the European Commission which give personal data the same protection is has in Europe (known as ‘model contracts’); or
(c) 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.
7.3 Data retention
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements - as documented in Sprive’s data retention policy. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
8. Your rights
8.1 Access to your personal data
You have the right to request access to your personal data (commonly known as a data subject access request. If you would like a copy of the information held on you, please contact our Data Protection Officer (see above for details).
8.2 Correction of your personal data
You have the to request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
8.3 Erasure of your personal data
You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
8.4 Objection to processing of your personal data
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
8.5 Restriction of processing your personal data
You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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.
8.6 Transfer of your personal data
You have the right to request the transfer of your personal data to you or to a third party. Subject to the rules and regulations that govern the products and services we provide, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
8.7 Withdrawing consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
8.8 Withdrawing consent to marketing
By submitting your personal information, you agree that Sprive may use your information for marketing purposes (including electronic marketing). Sprive will not disclose your information to any third party for marketing purposes, without your further consent. You have the right, at any time, to ask us not to process your personal information for marketing purposes.
8.9 Lodging complaints
You have the right to lodge a complaint with the Information Commissioner’s office for any processing carried out by Sprive. You can contact the ICO or telephone: 0303 123 1113.
If you wish to exercise any of the rights above, please email us at email@example.com
9. Changes to this Privacy Notice
We may make changes to this Privacy Notice, so please review it every now and then. If appropriate we will notify you by email about changes. Remember, you will be bound by this notice.