This website www.commercialtrust.co.uk
('website') is owned and provided by 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.
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.
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.
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.
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, 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.
The policy was last updated May 2018.
About Commercial Trust
- 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
You can contact us by telephone, email or post at:
Commercial Trust Limited, St Crispin’s House, Duke Street, Norwich, NR3 1PD
01603 896 878
Data Protection Officer
You can contact our data protection officer by telephone, email or post at:
Data Protection Officer, Commercial Trust, ST Crispin’s House, Duke Street, Norwich, NR3 1PD
01603 896 878
Gathering information from you at initial enquiry
There are a number of ways contact between us may arise, these are described below.
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. 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”).
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.
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 firstname.lastname@example.org 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, St Crispin’s House, Duke Street, Norwich, NR3 1PD
Other technology we use on our website
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.
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:
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.
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.
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.
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 (if applicable)
If you have been introduced to Commercial Trust by a broker (intermediary), we will inform them about the progress of the mortgage application and whether you have been successful.
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 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.
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.
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.
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/for-the-public/raising-concerns/ for additional information.
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.
Please refer to our Cookies page.
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
6 months from the last contact with you*
Legitimate interest/regulatory requirement
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
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 five years from the end of the recommended finance term.*
Name, address, postcode, credit history, mortgage documents will be held for six 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
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 years from the date our recommended mortgage expired||
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|