Privacy Notice
Last updated: 8 October 2026
About this notice
This notice explains how Smart Mortgages Ltd collects and uses personal information when you visit our website, contact us, make an appointment, use our referral or enquiry services, or receive mortgage or protection advice. It also explains who may receive your information, how long we keep it, and the choices and rights you have.
Who we are and how to contact us
Smart Mortgages Ltd is responsible for the personal information covered by this notice. Our address is 2 Columba Terrace, Waterside, Londonderry BT47 6JT. We are authorised and regulated by the Financial Conduct Authority (FRN 912358).
For privacy questions or to exercise a data protection right, contact Vicky@smart-mortgages.co.uk.
What information we use and why
The information we use depends on how you interact with us. It may include your name, address, telephone number, email address, appointment and referral details, information you enter in a website enquiry form, and information relevant to mortgage or protection advice. We use it to respond to enquiries, arrange and manage appointments, provide advice and related services, maintain appropriate records, meet legal and regulatory duties, and operate and improve our services.
For the referral system, an introducer may provide a person’s name and telephone number so we can route the referral and make contact about an appointment. Referral-system appointment records are retained for 12 months.
Our lawful bases
- Enquiries, appointments and advice: taking steps requested before entering a contract and, where applicable, performing a contract with you.
- Legal and regulatory records: complying with legal obligations and, where appropriate, pursuing legitimate interests in maintaining accurate records and operating our business responsibly.
- Referral administration: pursuing legitimate interests in receiving, allocating and following up referrals and keeping an accurate referral record.
- Meta campaign measurement: pursuing legitimate interests in understanding whether our advertising leads to appointments. You can object to processing based on legitimate interests.
- Optional cookies or direct marketing: where required, we will ask for consent or provide an opt-out in accordance with applicable law.
Special category information and information about other people
Mortgage or protection advice may sometimes involve information that data protection law treats as special category information, such as health information relevant to a protection enquiry. We will only use such information when it is relevant, necessary and supported by an appropriate legal condition. Please do not provide another person’s information unless you are entitled to do so. If you give us information about a partner, dependant or other person, please make sure they are aware of this notice.
When we record or monitor communications
We keep appropriate records of communications so we can respond to you, manage your enquiry or case, and meet our record-keeping responsibilities. If we record or monitor a particular communication, we will provide information about this at the relevant time.
Who may receive your information
We may share relevant information with the adviser or team member handling your enquiry, an introducer where appropriate to manage a referral, lenders and insurers when you ask us to provide advice or arrange a product, and professional advisers or regulators where needed. We also use service providers to host or operate our website, referral and appointment systems, email and messaging services, and automated enquiry tools.
For Meta campaign measurement, our server-side integration may send Meta a “Schedule” appointment event, booking time, a pseudonymous event identifier, and hashed email and, if provided, telephone number. Hashing does not make these identifiers anonymous. The event is used to measure advertising effectiveness, not to send marketing messages or assess mortgage eligibility. The integration is not designed to send your name, mortgage answers, income, property details, advice notes or mortgage case details to Meta. Meta may process Event Data under its Business Tools Terms, which incorporate a UK data transfer addendum. Meta’s privacy information is available at Meta’s Privacy Policy.
Cookies and similar technologies
Our website may use cookies or similar technologies for website operation, preferences, analytics or advertising. Where consent is required for non-essential cookies, we will seek it through the cookie controls. You can use those controls to change your choices.
Online enquiry and appointment services
If you complete an enquiry or referral form, we use the details you submit to respond and, where requested, arrange an appointment. If you book online, the booking service shares the appointment details needed to create and manage that booking with us. The referral system may also route the enquiry to an adviser and send service messages about the appointment.
Automated tools and AI
We may use automated tools to help manage enquiries, provide initial responses, route a referral or support administrative tasks. These tools are not intended to make decisions about whether you qualify for a mortgage or protection product. An adviser remains responsible for providing regulated advice and reviewing information relevant to a recommendation.
How we protect information
We use appropriate organisational and technical measures designed to protect personal information against loss, unauthorised access, alteration or disclosure. Access is limited to people and service providers who need the information for their role or the service they provide. Information is handled in line with our security and data-protection procedures.
International transfers
Some service providers may process information outside the UK. Where personal information is transferred internationally, we use an appropriate transfer mechanism and safeguards required by data-protection law. These may include an adequacy regulation, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. You can contact us for further information about the safeguards relevant to a particular transfer.
How long we keep information
Referral-system appointment records are kept for 12 months. We keep other information for as long as needed for the purpose it was collected, including any applicable legal or regulatory record-keeping requirements, and then securely delete or anonymise it in line with our retention schedule. Meta may retain Event Data under its own terms; this is separate from Smart Mortgages’ retention of referral records.
Your rights
Depending on the circumstances, you may have the right to ask for access to your information, have it corrected, request erasure or restriction, receive certain information in a portable format, or object to processing based on legitimate interests. To make a request, contact Vicky@smart-mortgages.co.uk. You can also complain to the Information Commissioner’s Office.
If something goes wrong
Please contact us at Vicky@smart-mortgages.co.uk if you have a concern about how we have used your information. You also have the right to raise a concern with the Information Commissioner’s Office.
Changes to this notice
We may update this notice when our services or data practices change. The latest version will be published on our website with its review date. Where a new use of your information needs to be brought to your attention, we will provide that information as required by law.
