1. Important Information And Who We Are
It’s important to know who’s handling your data. Here we set out who we are, why we have this policy in place, and how you can contact us if you have any questions or would like to talk to us about your data.
Personal data we hold about you may be processed by approvU and, where necessary, shared with third parties, such as mortgage lenders and credit reporting agencies, to process your application, assess the risk to grant you products, and for regulatory purposes.
This website is not intended for children. We do not knowingly collect data relating to children unless explicitly requested by a lender in a minimal number of cases.
Who We Are
If you want to talk to us about your data, we’re here to help. Email us at XXX@approvu.com
2. What Data Do We Collect
We’re transparent about the sorts of information we’re collecting and how it enables us to provide you with the best possible service while protecting your interests as a customer.
Personal data is any information that can identify you. It doesn’t include information where you can’t be identified (anonymous data).
As a mortgage recommender and processor, we want to tailor suitable recommendations for your personal circumstances. We, therefore, ask you for a variety of information to be able to provide personalized service. Your responses to the questions you provide directly impact what further details we may need from you, as different lenders require different information. The information collected helps us ensure we can select from the broadest range of products to provide you with the most appropriate recommendation. We’ll always explain this to you, and you can ask us any questions about the data we’re collecting at any time.
We may collect, use, store and transfer (‘Transfer’ means sending your information somewhere else) different kinds of personal data about you, which we have grouped into several categories:
- Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, address and employment history, and citizenship.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account details and bank statements, salary and other income information, and payment-direct/debit details.
- Credit information includes credit history, details of any history of collections, bankruptcy or court judgements, and mortgage products held.
- Credit eligibility information includes your credit reporting information produced by and supplied to us by a Credit Reporting Bureau (CRB) and any information that we derive from it.
- Special Category/Sensitive Data includes physical and mental health conditions, racial/ethnic origin, criminal offences and convictions.
- Transaction Data includes details about the products and services you may have benefitted from using approvU.
- 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 this website.
- Profile Data includes your username and password, feedback and survey responses.
- Job Application Data includes data submitted throughout the recruitment process, i.e. name, email address etc.
- Employment Data includes any personal information you provide to approvU as part of the recruitment process or throughout your employment at approvU should you be a permanent employee, contractor, or 3rd party provider.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us, our business partners and your communication preferences.
- Criminal offence data include information about criminal convictions and offences that you may have, for example, for fraud detection.
Data About Dependents
We collect data relating to the number of dependents as this affects our affordability calculations to provide you with the most appropriate recommendation. However, we’ll only ask for further data relating to dependents if requested explicitly as part of an application to be submitted to a lender. We’ll only request this data if necessary. This data will be treated sensitively, and we won’t use this data for marketing purposes or creating personality or user profiles.
Apart from the information customers provide to us directly, we may also record information about potential vulnerabilities where we think this is appropriate to meet the obligations placed on us by the Financial Regulatory Authorities of your respective province or territory.
We 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 isn’t considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this policy.
Updating Your Details
If you are an existing customer, we may use the information we have on you to pre-fill forms when you apply for a new product, but we’ll always check that these details are accurate and up to date.
3 How We Collect Your Data
You’ll communicate with us throughout your approvU journey, so it’s essential to understand what happens to your personal information along the way.
We use different methods to collect data from and about you, including through
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or corresponding with us by post, SMS, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website
- contact us by email, phone or live chat
- apply for a mortgage through us
- subscribe to our newsletter or tell us you’re OK with getting marketing from us
- enter one of our competitions or promotions
- give us feedback or take part in a survey
Information received from a joint applicant. If you are included on an application but are not the main applicant, approvU receives information about you that has been provided in the application. You will receive a notification from us when the main applicant submits the online form and at key milestones in your application.
Submitted via a job application. If you submit a job application to us, we will collect all the data submitted in the application form to process your application successfully. The data we will collect will include information shared in a CV, cover letter, job application questions and/or notes made by the hiring manager during the interview process. We will also use 3rd parties to complete the necessary background checks, only passing the required information to them in accordance with our regulatory requirements. Previous employers will be contacted to request references as information.
Employment Data. Additional information will be collected from you at the start of, and throughout your employment term, for example, your next of kin details. approvU may request additional information from you throughout your employment in line with any changes to applicable laws and regulations.
In some instances, we may collect data about you from third parties, such as employment agencies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers and website experience recording services such as Google, social media and advertisement network providers
- Identity and Contact Data from publicly available sources
- Real estate agents with whom you may be interacting, but only with your consent;
- Solicitor with whom you may be interacting, but only with your consent;
- New home builders, as a legitimate interest of the builder in order to assess affordability for the property;
- Enquiries you may perform on third-party mortgage sourcing websites.
- Your financial information from your bank is available via Open Banking with your consent
How We Use Your Personal Data
We’ll only use your personal data when the law allows us to. Most commonly, we’ll use your personal data in the following circumstances:
- Where do we need to perform the contract we’re about to enter or have entered with you?
- Where it’s necessary for our legitimate interests (or those of a third party), your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided your consent
To find out more about the types of lawful basis that we’ll rely on to process your personal data, please email firstname.lastname@example.org. Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw consent at any time by contacting us at email@example.com.
Purposes We’ll Use Your Personal Data For
Here’s 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’ve also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific reason we’re using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing, including basis of legitimate interest|
|To initially engage with you to discuss your requirements||(a) Identity|
|Performance of a contract with you|
Necessary for our legitimate interests
|Processing of a job application, i.e. Carrying out vetting and background and right-to-work checks, ongoing employment||(a) Identity|
|Legitimate Interest for approvU to assess and validate candidate suitability and capability to carry out the duties assigned to the prospective role|
Necessary for our legitimate interests
|To source products, provide indicative quotes, and process & deliver your application for a mortgage||(a) Identity|
(f) Special Category/ Sensitive Data
|Performance of a contract with you|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to recover debts due to us)
|To monitor your mortgage, let you know when a better deal becomes available and if relevant products are available through approvU.||(a) Identity|
(e) Marketing and Communications
|Performance of a contract with you|
|To manage our relationship with you, which will include:|
(a) Create and maintain access to your customer portal account
(c) Asking you to leave a review or take a survey
(d) Notifying you when your product is near expiry or when changes occur that would merit our re-engagement.
(d) Marketing and Communications
|Performance of a contract with you (including to re-engage with you to review your existing mortgage needs and to maintain and improve customer service standards)|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)|
|To respond to case enquiries & support any complaints||(a) Identity|
(f) Special Category/ Sensitive Data
|Necessary to comply with a legal obligation and for our legitimate interests (to ensure that complaints can be responded to accurately)|
Regulatory requirements such as; the FSRAO Mortgage Conduct of Business
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to understand how our customers use our platform)|
Consent (for cookies which provide insight into how visitors use our website, so we can keep our content relevant and inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|Necessary for our legitimate interests (to meet your customer needs and inform you about key areas of the mortgage process)|
|To request feedback or to ask you to participate in user testing or surveys to improve our website, products/services, marketing, customer relationships and experiences||(a) Identity|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To take set up payment for financial product providers to facilitate the payment of services provided by an employee, contractor or 3rd party.||IdentityFinancial||Performance of a contract with you|
To protect against money laundering, we’re required to conduct customer identity screening. We’ll try to verify your name and address by ch as part of this process by checking your details against databases held by credit reporting agencies. If we can’t verify your name and address, we may ask you to provide other documents to confirm these details. This does not affect your credit history or status.
If you’re a joint mortgage applicant, we’ll record any information you give us about any other persons joining the application.
4 Marketing And Feedback
We strive to provide you with choices regarding certain personal data uses, particularly marketing and advertising.
In addition, we value all feedback our customers provide to help us build our business and improve our product. If you leave us a review, we may contact you to ask you if you would like to publicize your review or offer you follow-up assistance with any difficulties encountered. We may also follow up for feedback or to ask if you are willing to contribute to marketing material.
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You’ll receive marketing communications from us if you’ve requested information from us or used our services or if you provided us with your details when you created an account and, in each case, you’ve opted to receive that marketing. We may also send you information about products we think you would be interested in based on your purchased services via approvU. Our emails always include a link that lets you unsubscribe if you’d rather not receive marketing.
You can opt-in to the sign-up process to receive marketing information and related products and services. You can opt-out of receiving these types of communications at any time by contacting our team at data.protection@approvU.com or by clicking on the relevant link in the email communications you receive from us.
Please note that your personal information will not be passed to any third-party organization for marketing purposes.
We’ll always ask your permission before we share your personal data with any company outside approvU for the third party’s marketing purposes. If you later change your mind, you’ll need to contact them directly to ask to be unsubscribed (but their emails should also contain an unsubscribe link)
We will only use your personal data for the purposes we collected it for unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to explain how the new purpose’s processing is compatible with the original purpose, don’t hesitate to get in touch with us. If we need to use your personal data for an unrelated purpose, we will let you know, and we ‘will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent in compliance with the above rules where this is required or permitted by law. We will not use any special categories of personal data provided for any other purpose than the completion of the provision of services under your insurance policy.
When we send you an email, it may contain a small snippet of code called a tracking pixel which allows us to collect certain information about your interaction with the email.
Through this tracking, we may record your IP address, the date & time that you opened the email and any links you may click. We use this to understand what emails or services were of interest to you and if the campaigns are effective. We also do this to better tailor our messages to you and optimize your approvU experience.
By setting your email client to display HTML emails as text only, you may be able to prevent the use of some email tracking. Please consult the “Help” section of your email client for more information.
Change Of Purpose
We will only use your personal data for the purposes stated above unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
5. Disclosures Of Your Data
We’ll always treat your data and privacy with respect. This applies to sharing this to provide you with the best possible service. More details are set out below.
Who we disclose personal data to
|Type of recipient||Reason|
|Mortgage Lenders||To source and submit applications in order to conclude the contract for the mortgage application and the ongoing servicing of these contracts.|
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. You may be required to agree to their privacy notices upon application, if applicable.
|External suppliers||Specialist, IT system providers to facilitate the sourcing of products, provide our web services, technical support issues, provide continuing advice, introduce specialist mortgage to inform you about relevant products and services, complete due diligence and oversight, and request feedback and reviews on customer service standards. |
It may also be necessary to share your personal data with non-affiliated companies who perform support services on our behalf, including those that provide professional, compliance, legal or accounting advice to approvU.
Lead suppliers (if you were introduced to us by a third party, including “refer a friend”. Social media platforms we use for marketing purposes.
|Solicitors||To update the firm of solicitors with whom you are interacting about the progress of your application and confirm your identity/proof of deposit.|
|Real estate agents||To update the real estate agents with whom you are interacting about the results of affordability checks and the progress of your application.|
|Regulators||To fulfil our legal obligations as a regulated profession to verify your identity and comply with Anti Money Laundering legislation and otherwise cooperate with law enforcement, legal proceedings or regulatory authorities.|
We abide by The Personal Information Protection and Electronic Documents Act (PIPEDA). And, if we ever have to send data outside Canada, we take care that the same high standards cover it.
Some of the businesses we work with are based outside Canada, so we need to transfer your personal data to them. Whenever we transfer your personal data out of Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We’ll only transfer your personal data to countries that have been deemed to provide an adequate level of protection
- Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Canada.
- Where we use third parties based anywhere else in the world, we use specific contracts and conduct a due diligence check to ensure that the country provides adequate protection for personal data,
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Canada.
6. Data Security
More information on how we work hard to keep your data secure.
We understand how important it is to keep your personal data secure and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your 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 they 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 we’re legally required to do so.
approvU will always attempt to deliver emails on the highest encryption level that your email provider can accept. However, if your email provider does not support encryption using TLS, we will be unable to encrypt the email we send you during transit. Therefore, we suggest you check with your email provider that they support SMTP-SSL or SMTP with STARTTLS. If they do not, we suggest creating an email account with an email provider that does.
7. Data Retention
We won’t hold your data for any longer than we need to to make sure you’re getting the maximum benefit from our services.
How long will you use my personal data?
We’ll only retain your personal data, including call recordings, for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. As well as making sure you’re always on the most suitable deal for your circumstances, this enables us to adhere to our regulatory requirements, ensure we provide suitable advice and answer any questions you may have later down the line. If you don’t transact with us, depending on the stage of your application, we may delete your information sooner in accordance with our data retention policy.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 requirements.
|Purpose of processing||Retention|
|Successful mortgage||For the full mortgage term plus a further 7 years|
|Withdrawn, stalled, incomplete and failed mortgage applications||7 years from the date the latest application was started, or 7 years from the application submitted date if the application was submitted and subsequently rejected or from the creation date if advice has been provided but not pursued|
|Customer Profile Data||7 years from the date of the last login. If not, proceed to the full application|
|Affordability Checks||7 years from the affordability check was made if it did not proceed to a full application|
|Job Application||The successful applicant: the life of employment plus 7 years after the employment terminates.Unsuccessful candidate: up to one year|
You can ask us to delete your data in some circumstances: see Request erasure below for further information. In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
- Request access to your personal data
- Request correction/rectification of your personal data
- Request erasure of your personal data, a right to be forgotten
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
Right To Withdraw Consent
If you wish to exercise any of the rights set out above, please get in touch with us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we are allowed and may refuse to comply with your request in these particular circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to any 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 speed up our response.
Time Limit To Respond
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’ll notify you and keep you updated.