This Data Protection Information provides information on the processing of your personal data whenever you visit websites of Promo SEO Ltd (hereinafter “Promo SEO”, “we” or “us”).
First Time Buyer Mortgages is controlled and operated by Promo SEO. Promo SEO is a tier 1 ICO company (ID: ZA212962).
1. Scope, data controller, data protection officer and definitions
1.1. Scope of this Data Protection Information
This Data Protection Information applies to the use of the websites of First Time Buyer Mortgages, including newsletter dispatch, further informative emails and customer services, and for our marketing activities on third-party websites. Data processing on websites of other companies within the First Time Buyer Mortgages are not covered by this Data Protection Information.
1.2. The Controller for the processing of your personal data
Unless otherwise specified in this Data Protection Information, the Controller for the processing of your personal data is:
35 Water Lane,
1.3. Contact details of the Data Protection Officer
Data Protection Officer
35 Water Lane,
Email: [email protected] (Please note: For exercising your data protection rights please use the email addresses referred to in Section 5 to 7!).
This Data Protection Information is based on the following terms under data protection law, which we have defined to facilitate understanding.
- GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
- Recipient means a natural person or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by the public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing; Examples of possible recipients: Banks/payment providers, logistic firms and shipping service providers and IT services providers; for more information please refer to Section 4)
- Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Examples of personal data: Name, contact details, bank or credit card details.
- Controller means the natural person or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. For the data processing activities described in this Data Protection Information, the Controller is First Time Buyer Mortgages, unless otherwise specified (Section 1.2.).
- Processing means any operation or set of operations which is on personal data or on sets of personal data, whether or not by automated means such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. Purposes and legal bases of our processing of your personal data
2.1. Processing of your data when you visit our websites
If you visit our websites in order to find out about products and services without registering for a customer account, purchasing products in our online shop or otherwise actively transferring information to us (purely for informational purposes), we process your personal data for the following purposes and by virtue of the following legal bases:
2.1.1. Provision of websites and IT security
We process your personal data that are technically necessary to allow us to provide our websites to you and to guarantee stability and security when you visit our websites. This includes the following personal data:
- IP address
- type and version of browser
- operating system and platform
- the complete Uniform Resource Locator (URL)
These personal data will be stored for security purposes in server log files, which will automatically be deleted after 7 days.
This data processing is necessary for the purpose of enabling you to use our websites (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR) as well as for the purposes of our legitimate interest to guarantee IT security (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
2.1.2. Provision of localised websites
We also process your personal data that are technically necessary to allow us to provide you with a localised version of the websites, in particular with regard to the language.
This data processing is necessary for the purpose of our legitimate interest to adapt our website to your needs (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
2.1.3. Website Analytics
22.214.171.124. Google Analytics
This data processing is necessary for the purpose of our legitimate interest to carry out analyses in order to improve our website and our products, and to advertise our products on the Internet in a customized and efficient way (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
Google Analytics Opt-out:
You can prevent the processing of your usage data (including your IP address) by Google Analytics generally, by downloading and installing the browser add-on available at the following link:
In addition, you can also prevent Google Analytics from collecting your usage data on our websites by clicking on the following link:
In this case, a persistent opt-out cookie (name: “ga-disable-UA-[…]”) is set in your current used browser, that prevents your data from being recorded in the future when you visit our websites with this specific browser. If you use another browser, Google Analytics will be in principle enabled, unless the opt-out cookie is also set in this browser. Please note, that Google Analytics will be enabled again if you delete the abovementioned opt-out cookie in your browser.
2.1.4. Individual recommendations on our websites
This data processing is necessary for the purpose of our legitimate interest to create a better user experience by tailored recommendations (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
Individual recommendations Opt-out:
You can object to this data processing by clicking on the following opt-out link:
Google AdWords: https://adssettings.google.com
2.1.5. Display advertising/retargeting on third-party websites
- Google AdWords: https://policies.google.com/privacy
- Facebook Ads: https://www.facebook.com/about/privacy
This data processing is necessary for the purpose of our legitimate interest to advertise our products on the Internet in a customized and efficient way (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
You can object to this data processing by clicking on the following opt-out link(s) of the respective retargeting provider(s).
- Google AdWords: https://adssettings.google.com
- Facebook Ads: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
2.1.6. Affiliate Marketing/Conversion Tracking
We have also embedded cookies and similar tracking technology from our affiliate (network) partners into our websites. With these tools, our affiliate (network) partners can recognize whether you came from one of our affiliate publishers (i.e. third party websites that advertise Promo SEO products) and then track if you perform a certain predefined “conversion” action (e.g. newsletter subscription or purchase of a product) on our websites in consequence.
This data processing is necessary for the purpose of our legitimate interest in analysing reach and success of our advertising campaigns on third party website (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR) as well as for the legitimate interests pursued by us (as an advertiser), the affiliate (net-work) partners and the affiliated third party website operators (publisher) in success-based billing of First Time Buyer Mortgages advertising measures published on third party websites (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
Affiliate Marketing/Conversion Tracking Opt-out:
2.1.8. Customer care
Depending on the subject matter of your request, we will rely on your personal data that has been stored within the scope of other data processing activities in our systems (e.g. data that you have provided during a purchase, or your score value that we have received from the credit agency as part of the credit assessment process. If and to the extent that this is necessary to answer your query, we will also collect data from external sources (e.g. query with a shipping service provider as part of shipment tracking or an investigation request).
In the context of requests concerning a (pre)contractual relationship with you, this data processing is necessary for the performance of a contract (provision of customer service) with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR). If you wish to exercise your rights with respect to us, the correspondent this data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR). If you would like to receive information or complain about our products and services, the respective data processing is necessary for the purpose of our legitimate interest to respond to your information request/complaint (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
2.2. Email marketing
2.2.1. Email newsletter dispatch to subscribers
If you have subscribed to our email newsletter via the “double opt-in” procedure we will send you from time to time newsletters to inform you about our products, services and promotions.
This data processing is based on your consent (Legal basis: Art. 6 (1) sentence 1, lit. a GDPR).
Withdrawal of consent:
You can withdraw your consent and unsubscribe from our newsletter at any time by sending an email with your unsubscribe request to our customer ([email protected]) and/or by clicking on the unsubscribe link which is contained in every newsletter.
2.6. Other processing
2.6.1. Performance of internal audits
Within the scope of audits within the First Time Buyer Mortgages, both at home and abroad, your personal data may be processed. During this process, we rely also on data from other sources, depending on the case (e.g. credit agencies).
Your data may, under certain circumstances, also be appropriately processed in order to identify and rectify misconduct within the enterprise, and to implement compliance programmes and compliance measures.
This data processing is necessary for compliance with our legal obligations (e.g. under the Stock Company Act) (Legal basis: Art. 6 (1), sentence 1, lit. c GDPR) and/or for the purpose of our legitimate interest to check the processes and efficiency in the Promo SEO, to rectify misconduct and cases of fraud, to enforce and/or defend our rights, as the case may be, and to uncover any criminal offences, (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
2.6.2. Issuing of analyses
On the basis of your data, which we process the meaning of Section 2 of this Data Protection Information, we may issue analyses. These serve as a basis for our business decisions, to improve our products and services, to adapt to the needs of our customers and to carry out marketing activities. The analyses issued on this basis no longer have any personal reference, which means it is no longer possible to trace them back to you.
This data processing is necessary for the purpose of our legitimate interest to improve the products and services we offer and carry out marketing activities (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
3. Retention and erasure of your personal data
We keep your personal data for as long and to the extent required for the purposes named in this Data Protection Information (Section 2).
As soon as the data for the purposes named in Section 2 is no longer required, we keep your personal data for the length of time, during which you can assert claims against us or we can assert claims against you (the statutory period of limitations is generally three years, starting with the end of the year in which the claim arises, e.g. the end of the year of purchase).
4. Transfer of personal data and the categories of recipients
Your personal data may be transferred/disclosed to the following categories of recipients:
- Other companies within the Promo SEO group within the scope of a group-internal, collaborative process. Such data processing, where applicable, is necessary for the purpose of our legitimate interest to run our administration activities efficiently and collaboratively, and to improve our products and services (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
- IT Service providers who prepare the platforms, databases and tools for our products and services (e.g. our website, the sale of goods, the dispatch of newsletters and in-formative emails), issue analyses on user habits on our websites, carry out marketing campaigns and process your personal data during the purchasing process on our behalf.
- In connection with the use of Google Analytics and Google Adwords, including tags and cookies, your personal data may be transferred to the USA. In the case of the USA, the EU Commission has not decided that there is a suitable level of data protection within the meaning of the GDPR; such an adequacy decision (Art. 45 GDPR) has not been taken. Google LLC is, however, subject to the EU-U.S. Privacy Shield. This means that adequate protection of your personal data is guaranteed. You can retrieve the full text of the US Privacy Shield Framework at the following link: https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg
- For the analysis of your behaviour on our website, we transfer your personal data to specialised service providers. Data is transferred to third party countries. In order to guarantee adequate protection of your personal data, EU standard contractual clauses within the meaning of Art. 46 (5) sentence 2 GDPR are used.
- If you purchase or evaluate products on our websites, we will forward your personal data to our third-party service provider of customer feedback platforms, located in the USA. In the case of the USA, the EU Commission has not decided that there is a suitable level of data protection within the meaning of the GDPR; such an adequacy decision (Art. 45 GDPR) has not been taken. In order to guarantee adequate protection of your personal data, we have used EU standard contractual clauses within the meaning of Art. 46 (5) sentence 2 GDPR. You can find information on EU standard contract clauses at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF.
- In the case of legal disputes, we transfer your data to the competent court and, if you have engaged a lawyer, to the latter, in order to conduct the legal dispute. This transfer of personal data is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR) and/or for the purpose of our legitimate interest in the establishment and exercise of legal claims (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
- In addition to this, we only transfer your personal data if we are legally obliged to forward such data (e.g. to the police authorities within the scope of criminal investigations or to the data protection supervisory authorities). This transfer of personal data is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).
5. Right to object to data processing based on legitimate interests
We process your personal data within the meaning of Section 2, based on our legitimate interest, in particular, to guarantee IT security on our websites, to adapt our website to your needs, to carry out analyses and marketing activities, to inform you about our products and services, to remind you of any purchasing processes that have not yet been completed, to increase the coverage of our products and marketing activities, to prevent fraud and abuse, to avoid payment defaults, to care for our customers, to safeguard, enforce and defend our legal interests (also before the courts, as necessary), and to carry out our internal management efficiently and collaboratively. For information about the balancing of interests carried out by Promo SEO please contact [email protected]
Notwithstanding the specific possibilities to object to data processing described in Section 2 (e.g. provided opt-out or unsubscribe links), you have the right to object at any time to the processing of your personal data on the basis of our legitimate interests pursuant to Art. 6 (1) sentence 1, lit. f GDPR on grounds relating to your particular situation by sending an email to [email protected] We will then no longer process your data for this/these purpose(s) unless our legitimate interests in processing overweight or the processing serves to establish, exercise or defend legal claims.
If you object to the processing of your data, we will process any collected personal data in this context in order to respond to your request. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).
6. Right to withdraw consent
If you have given us your consent for the processing of your personal data, you can withdraw this consent at any time. The withdrawal of your consent is effective for the future and shall not affect the lawfulness of processing based on consent before its withdrawal.
Unless specifically regulated in Section 2, please send your withdrawal of consent to [email protected]
If you withdraw your consent, we process your personal data collected in this connection to answer your inquiry. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).
7. Your other data protection rights
In accordance with the GDPR, you may demand at any time that we:
- provide you with information on your personal data that we process (Art. 15 GDPR),
- rectify (Art. 16 GDPR),
- erase (Art. 17 GDPR),
- restrict (Art. 18 GDPR) and/or
- export (Art. 20 GDPR)
- your personal data stored on our systems.
Please send your request, stating at least your first and last name, either by email to [email protected] or in writing, to Promo SEO Ltd, Waterhouse, 35 Water Lane, Wilmslow, SK9 5AR.
If you exercise these rights against us, we will process your personal data in order to respond to your request. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).
Irrespective of your abovementioned rights, you can lodge a complaint with a data protection supervisory authority, if you are of the opinion that the processing of your personal data by Promo SEO violates the GDPR (Art. 77 GDPR).
8. Changes to this Data Protection Information
The provisions of this Data Protection Information, including the referenced Cookie Information, shall apply in the version in force at the time the online shop is used.
We reserve the right to supplement and modify the content of this Data Protection Information. The updated Data Protection Information applies from the time, in which it was published on our websites. In case of substantive or material changes to the Data Protection Information, especially changes that affect the processing of your personal data already collected by us, we will inform you in advance (e.g. by email).
9. How we use your information
We use the information we collect in various ways, including to:
- Provide, operate, and maintain our website
- Improve, personalize, and expand our website
- Understand and analyze how you use our website
- Develop new products, services, features, and functionality
- Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
- Send you emails
- Find and prevent fraud
10. Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
10.1 Log Files
First Time Buyer Mortgages follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
10.2 Cookies and Web Beacons
Like any other website, First Time Buyer Mortgages uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
By using and browsing the https://first-time-buyer-mortgages.co.uk website, you consent to cookies (where appropriate) being used in accordance with our Cookies Policy. If you do not consent, you must disable cookies or stop using our website.
11. Links To Other Web Sites
Our Service may contain links to third-party web sites or services that are not owned or controlled by us.
You should assume all links placed on this website are affiliate links where we get paid a commission if you click through.
We are a professional review site who are independently owned and the opinions expressed here are our own.
This disclaimer is to inform you I have a relationship with a particular product or service and if you choose to purchase that product or service via my affiliate link, I will get a small commission. Of course, this is at no extra cost to you, but it does help keep my candle burning so I can keep bringing you great tips! I truly appreciate your support in this way. Thank you.
12. GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
13. Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
First Time Buyer Mortgages does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
We value your privacy and the security of your personally identifiable information is extremely important to us.
14. Contact Form Submissions
Contact forms completed made on the First Time Buyer Mortgages website can be passed to a third-party company who we feel is best for your given enquiry.
By completing the contact form you agree to us passing your information onto the potential of several businesses who could assist your enquiry.
We have no control over and assumes no responsibility for, the content, privacy policies, or practices of any third-party web sites or services.
You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services.
We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.
15. Governing Law
These Terms shall be governed and construed in accordance with the laws of United Kingdom, without regard to its conflict of law provisions.
The information provided on this website is intended for UK residents only.
Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements we might have between us regarding the Service.
Our website information does not constitute any form of advice or recommendation by our website and is not intended to be relied upon by users in making (or refraining from making) any decisions.
Appropriate independent advice should be obtained before making any such decision.
The site operates a policy of independence in relation to matters where the operator may have a material interest or conflict of interest.
On conflict of interest, such interests may arise from the receipt of advertising income, commissions based on new business introduced to the third party.
A payment for enhanced publication presence and the holding of positions can be received.
All information found on this website, including any ideas, opinions, views, predictions, forecasts, commentaries, suggestions, expressed or implied herein, are for informational, entertainment or educational purposes only and should not be construed as personal advice. While the information provided is believed to be accurate, it may include errors or inaccuracies.
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Service.