Mortgage Miles Trading as Corporate Finance (Lon) Limited (we) are committed to protecting and respecting your privacy. In order to provide the best possible service to you when you are using the services provided by our Website though, we need certain data from you otherwise we cannot give useful offers and ways to provide Rewards.
We collect and process data that relates to you (called "personal data") for the purposes of the following Mortgage Miles Services:
• The Mortgage Miles cashback service for web-based transactions
• The Mortgage Miles cashback service for in-store purchases
• The Mortgage Miles Reward service for gift card exchange services, PayPal & Bank Transfers
Scope of Policy
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected, handled and/or processed by us.
For the purpose of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) we as a “data controller” have to give you the following information:
• Our Sites addresses are https://www.mortgagemiles.com
• Our company name is: Mortgage Miles Trading as Corporate Finance (Lon) Limited
• Our registered address is: C/o, Atkins & Partners, 4th floor, Suite 2B, Congress House Lyon Road, Harrow, Middx HA1 2EN
• Our nominated representative can be contacted at firstname.lastname@example.org
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
• You have given consent to the processing of your personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of your prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is necessary to protect the vital interests of your or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
Information we may collect from You
We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Claims Data includes data you provide concerning a purchase made from a merchant as part of the process of raising and processing a cashback claim on your behalf.
• Contact Data includes postcode, address, email address and telephone numbers.
• Customer Service Contact Data includes records of your contact with our customer care team, including live chat, telephone conversations, online tickets raised, emails and contacts through any other customer contact channels.
• Financial Data includes bank account, PayPal account and payment card (including Identifier Card and Cashback Reward Method) details.
• Identity Data includes first name, last name, username, date of birth, postcode or similar identifier.
• Marketing and Communications Data includes your preferences for receiving marketing from us and your communication preferences.
• Profile Data includes your username and password, purchases or orders made by you, cashback allocated to you, your interests, preferences, feedback, reviews and survey responses.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Mortgage Miles
• Transaction Data includes details about Cashback payments that may be due to you and details of transactions that may give rise to Cashback.
• Usage Data includes information about how you use Mortgage Miles and about the websites that you accessed prior to accessing Mortgage Miles.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is put together in an aggregated and anonymous manner (so that your identity and personal data are not accessible) and does not constitute personal data for legal purposes. For example, we may aggregate your Usage and Transaction Data and (a) use it for internal management purposes, and (b) share it with current or prospective merchants. This type of information includes, for example, usage of an Account Holder's Reward Method, including the types of product that the individual Account Holder purchases, the value of those purchases and the channels through which the purchases are made.
How long will we keep your personal data for?
We keep your personal data for as long as is necessary:
• to address relevant legal, tax or accounting requirements, including potential claims by and against us.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of that data, the purposes for which we process it, whether we can achieve those purposes through other means, as well as legal, taxation and accounting requirements. When the need to keep your personal data ends, we either delete or anonymise it.
Information we receive from other sources (Third Party Information)
We work closely with third parties (including, for example, affiliates, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. We may also use additional methods to collect your information when you are physically visiting the store of one of our participating Merchants. If you do not wish to have your personal information collected by these methods, you may not be able to earn and redeem rewards as part of the Services.
We may enable cookies or storage to help us collect, maintain and use the information in order to distinguish you from other users of our website. This will help us to provide you with a good experience when you use the Services or browse any of the sites and also will allow us to improve Our Service.
Usage Tracking allows us to count users who have visited certain web sites and pages within web sites, or used applications or features, to analyse the behavior of users of Our Site, in order to improve Our Site and associated Services, and to personalise and determine the effectiveness of promotional or advertising campaigns.
Uses made of the information
We use information held about you in the following ways:
1. Submitted and Service Information (personal): We use your such information only for the following purposes: (i) to provide, improve, change and optimise the Services, (ii) to personalise your experience, (iii) to provide you with software updates and/or product announcements, (iv) to better understand yours and other users' needs and interests, and (v) to provide you with further information, offers and promotions from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns. We may match data from your transactions and usage with our Merchants and partners and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or provide targeted offers and/or rewards or discounts to you. We will use your personal data for marketing purposes only with your prior consent.
2. Submitted and Service Information (not personal): We use information about our users generally, for purposes including but not limited to: (i) improving features and functionality of the Website and associated Services and to make these more relevant and up-to-date, (ii) analysing trends through aggregated demographic and personality-linked offers to users, (iii) sharing such information with our Merchants and other affiliates to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, offers and other incentives to you when you use the Website and associated Services (Any information shared with Merchants and other affiliates in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism)
3. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Whom will we share your personal data with?
We will share your personal data with members of our group of companies that provide services to group members, and to various third parties, but in each case always for the uses referred to above. These third party businesses are:
• Affiliate networks that are involved in the transaction and cashback-allocation process
• Payment and transactional service providers
• Advertising service providers, such as Google Ad Manager, providing cookie display advertising on Mortgage Miles and on other sites you visit
• Businesses through which we carry out, or which assist us to carry out, marketing campaigns
• Merchants, listed on our site
• Businesses we engage to process data on our behalf, including: Research and profiling services We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
2. If Mortgage Miles Trading as Corporate Finance (Lon) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
3. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
Where We store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Site and therefore any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Under the law, you have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of new data you provide to us.
• 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 in a position to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object 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.
• 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.
• Request the transfer of your personal data to you or to a third party. 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.
• Withdraw consent 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 wish to exercise any of the rights set out above, please contact us by email at email@example.com. You will not have to pay a fee to exercise any of your legal rights as specified above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the relevant personal data (or to exercise any of your other legal rights). This is a security measure we take to help avoid your personal data being disclosed to a person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to help speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to ask us not to process your personal data for marketing purposes. We will obtain your consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can also exercise the right at any time by contacting us at MortgageMiles.com P.O. Box 76969, London, N14 9FX or by email at firstname.lastname@example.org
If you believe we have not processed any of your personal data in accordance with the GDPR and other applicable data protection legislation or you have been affected by non-compliance you can make a complaint to email@example.com
Access to information
The GDPR gives you the right to access information held about you. Your right of access can be exercised by emailing us at firstname.lastname@example.org. Repeated access requests may be subject to an administrative fee that we will advise you of in advance of providing information to you to meet our costs in providing you with details of the information we hold about you.
All personal information can be accessed, changed and deleted in the profile section of the Application.
Automated Decision-Making and Profiling
We may use your historical transaction data to segment our customers into different categories of shoppers. This process is automatic and helps us predict where our customers are likely to shop in future so that we can tailor our services. You may ask us to stop this type of profiling by contacting us at email@example.com but we will not be able to continue providing our services to you in that case as this is an integral part of our services.
In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so would request that you contact us in the first instance.