Who we are
Really Commercial Ltd trading as Commercial Mortgage Solutions (CMS) are Commercial Finance Brokers. We act as a broker for our customers. CMS are Authorised and Regulated by the Financial Conduct Authority. Our Firm Regulated Number [“FRN”] is 655212.
How we will use the information about you
Here at CMS we take your privacy seriously and will use your personal information in several of ways which will help us approach lenders in order to obtain an offer of finance for any project you instruct us to seek finance for.
We may share your information with, and obtain information about you from, credit reference agencies or fraud prevention agencies.
We may also share details about you and any offer of finance to any lender, guarantor (intended or otherwise), and your legal, property or accounting advisors as well as to any individual or firm who may have introduced you to us in the first place.
In addition to the above, we will not disclose your information to any company or individual other than in connection with obtaining the finance you seek except to help prevent fraud or if required by law to do so.
If you are an introducer we will use your data solely to contact you with information about CMS and the services it can offer. We will never provide your data to 3rd parties.
For further information on how your information is used, how we maintain the security of your information and your rights to access/alter and change information we hold on you, please contact Adrian Coles on 0330 0584079 or at firstname.lastname@example.org.
If you are a customer we will not use your data for marketing purposes. If you are an introducer we will contact you from time to time with details of our services
Your Personal Data:
What we need
CMS will be what is known as the “data controller” of the personal data you provide to us. We collect personal data about you which may also include any special types of information or location-based information.
In order to meet our contractual obligations to you to source an offer of finance for your consideration we will gather information in the following areas:
- Personal information e.g. your name, date of birth, marital status, family status,
- Your contact information e.g. phone numbers, personal and business address, email addresses
- Financial information e.g. bank, credit card and mortgage statements, statements of your assets & liabilities; statements of your income & expenditure, financial information about your business, copies of your credit reports etc
Why we need it
We need to know your basic personal data in order to obtain an offer of finance on your behalf from lenders. We will not collect any personal data from you we do not need in order to provide and oversee this service to you.
Automated Decision Making: Our panel of lenders may use automated decision-making in respect of your application for finance. We will only collect the minimum amount of data needed and have a clear retention policy for the profiles we create.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or any significant effects. You can request human intervention and challenge a decision made this way by contacting us at:
Processing is lawful under GDPR because we have asked you to take specific steps before entering into a contract.
What we do with it
All the personal data we use is controlled by CMS in the UK. However, for the purposes of IT hosting and maintenance, this information may be located on servers within the European Union. No 3rd parties have access to your personal data unless the law allows them to do so. We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
We may pass your data to UK based lenders in order to provide you with offers of loans and mortgages suitable to meet your requirements.
Your data is stored electronically on an encrypted server. This server is backed up to offsite secured storage and a cloud-based facility. We also keep some records in paper format. These files are stored in our locked offices in Fordingbridge. Once your loan has completed and drawn down we will store your information in a secure environment. If you do not complete a loan through CMS, we will destroy all data we hold on you after 6 months.
How long we keep it
We are required to keep your data for a minimum of 6 years after which time it will be destroyed.
What are your rights?
If at any point you believe retained information is incorrect you can request to see this information and even have it corrected and possibly deleted. Providing you with this information is free of charge, but charges may apply for excessive requests.
If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Officer, Ian Monks who will investigate the matter.
Where relevant, you have the right to withdraw consent at any time and this means that we cannot process your data provided once your consent has been withdrawn.
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).
Our Data Protection Officer is Ian Monks and you can contact him at email@example.com or on 0330 058 3981
We will share your details with those banks and other lenders who might be interested in lending money to you, so that they can process your information, allowing CMS to offer suitable and sustainable products that they provide. If you consent to us passing your details for that purpose sign to confirm.