Dashly is committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Notice explains the measures we take to fulfill these commitments and describes the manner in which we collect, use, discloses and otherwise treats personal information through our website available at dashly.com, including all subpages and successor pages (collectively referred to as the “Website”) as well as through other interactions with our clients and prospective clients.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
Purpose of this privacy notice
This privacy notice aims to give you information on how Dashly collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our service, newsletter, mailing list or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Dashly Ltd is the controller and responsible for your personal data (collectively referred to as "Dashly", "we", "us" or "our" in this privacy notice). We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise (your legal rights), please contact the data privacy manager using the details set out below.
Joint Data Controller
In certain circumstances, there may be more than one Controller processing your information. If you have been invited to use Dashly by a Third Party, for example, your Financial Adviser or Employer, by accessing a Dashly Site that is co-branded with the Third Party, such Third Party will become a Joint Controller and will be jointly responsible for your personal data.
The Joint Controller has their own obligations under applicable information privacy laws. Dashly is not responsible for the processing of a Joint Controller (including our customers). You are advised to view the Privacy Notice of the Joint Controller on their website, where there will be information on the Joint Controllers data privacy officer who is responsible for overseeing questions in relation to their privacy notice.
This Privacy Statement does not apply where Dashly processes personal data as a service provider (or equivalent role under data privacy laws, such as data processor) on behalf of a customer or entity who acts as the Controller, for example, the customers of our regulated mortgage advisers. When we act as a service provider, the privacy statement of the relevant Controller and our agreements with such business or entity will govern our processing of such personal information.
Dashly Ltd, 5th Floor, The Glassmill Building, 1 Battersea Bridge Road, London, SW11 3BZ.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK 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 please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 5th April 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We ask our clients for no more personal information than necessary
Dashly needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal and regulatory obligations. Understanding a customers needs and wants, financial position and family circumstances enables us to ensure that all recommendations are suitable. This is both a regulatory requirement and good business. Dashly is committed to protecting our customers privacy and the confidentiality of their personal information in our possession. We may collect process store and transfer the following information about you;
The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone numbers, email addresses, birth date, investment knowledge and objectives. We also collect optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, optional government issued identifiers for I.D. verification purposes such as national insurance, passport and driving licence numbers.
Contact Data includes address history, email address and telephone numbers.
Financial Data includes bank account details, residential status, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, account details of any mortgages held, property and asset values, and, if the lender requires, direct debit details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
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 and our third parties and your communication preferences.
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 is not 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 privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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 by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
sign up for our services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
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, Mixpanel and FullStory based inside and outside the EU;
advertising networks or providers such as Facebook, DoubleClick based inside the EU; and
search information providers based the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Identity and Contact Data from CallML (as part of the anti-money laundering checks we’re required to undertake).
Joint Mortgage applicants. If you’re a joint mortgage applicant, please ensure that any other joint applicants have given their consent to their personal data being processed as set out in this Privacy Notice. Whenever a joint application is made, we will assume that the main applicant has secured the express consent for any necessary processing set out in this Privacy Notice, from all other joint applicants.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, 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 have 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 purpose for which we are 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.
- Marketing and Communications
- Manage payments, fees and charges
- Collect and recover money owed to us
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
- Asking you to leave a review or take a survey
- Marketing and Communications
- Performance of a contract with you
- 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)
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
- 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 reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
- Marketing and Communications
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can control your choices through the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on 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 will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you 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'll always treat your data and privacy with respect. This applies where we need to share this to provide you with the best possible service.
Who we disclose personal data to:
External Suppliers: Specialist IT and data capture service providers who facilitate our mortgage monitoring web services and support technical issues. 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 Dashly. Lead suppliers (if you were introduced to us by a third party) including “refer a friend”. Social media platforms we use for marketing purposes.
Mortgage Advisers: If you have enquired about a mortgage or other financial product, we will share your personal data with an affiliated adviser who is able to provide financial advice in relation to your mortgage application.
Professional Advisers: Including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
Regulators: In order to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise cooperate with law enforcement, legal proceedings or regulatory authorities.
Other Third Parties: To whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We don't allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We abide by the UK data protection laws. And, if we ever have to send data outside the UK, we take care that it's covered by the same high standards.
Some of the businesses we work with are based outside the UK so we need to transfer your personal data to them. Whenever we transfer your personal data out of the UK, 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 the UK and Europe.
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 to personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal 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 are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
More information on your rights may be found at www.ico.org.uk If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 may refuse to comply with your request in these 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 that 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 will notify you and keep you updated.
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of our Site;
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
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 the 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 able 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 at any time 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.