Effective as of 13 July, 2018

Mount Street Mortgage Servicing Limited together with its affiliates (“Mount Street”, “we”, “us” or “our”) is committed to protecting your privacy. The following discloses the information gathering and dissemination practices for Mount Street.

Please carefully review this policy, and if you have comments, concerns, or questions regarding this Privacy Policy, please contact us at Compliance@mountstreetllp.com.

Pursuant to the European Union General Data Protection Regulation (GDPR), we function in the capacity of a “processor” for the services we provide. The scope of applicable data protections and processing for those services are set forth in contractual agreements covering the relevant data processing.

Controller versus Processor:
We may process certain personal information in order to maintain and provide the services to our clients, such as names, addresses, email addresses, and other contact information for designated client representatives or personnel (“Client Relationship Data”). In addition, we may send marketing materials or communications to potential or existing clients (“Marketing Activities”). For purposes of Client Relationship Data and Marketing Activities, we function as a “data controller” under GDPR.

Information You Provide:
You may provide us with your personal information when you visit our Websites and express interest in obtaining information from us or in engaging with us. “Personal Information” is defined as 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.

In some cases, we will ask for your consent so that we may process your personal information. However, in certain circumstances, applicable data protection laws allow us to process your personal information without needing to obtain your consent. Those situations might include:

For the performance of a contract. To perform our contractual obligations to you, including our fulfilling orders or requests you have made, contacting you in relation to any issues with your order or use of our services, or where we need to provide your Personal Data to our service providers related to the provision of the services.

To comply with legal obligations. To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.

Legitimate Interests.
To operate our business and provide our services (other than in performing our contractual obligations to you) for our “legitimate interests” and for the purposes of applicable law, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Legitimate interests may include:To operate our business and provide our services (other than in performing our contractual obligations to you) for our “legitimate interests” and for the purposes of applicable law, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Legitimate interests may include:

To communicate with you regarding our services, including to provide you important notices regarding changes to our operations and to address and respond to your requests, inquiries, and complaints.
To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
To develop, provide, and improve our services.
To enforce our terms of use, license agreements and customer contracts, or this Privacy Policy, or agreements with third parties.

The information you provide may include the following:

Information you provide to us voluntarily, such as your first and last name, email address, street address, phone number, title, company name, country and area of interest when you register with the Website to request additional information from us, download thought leadership content, or for client services or events.
Information you post or provide when using the Websites, including comments or feedback you may provide.
Information you may choose to provide in response to an email or phone contact with us that you have requested.
Information obtained from satisfaction and product surveys that you may have opted in to receive.
Information you provide when you submit an application for a position, or query about a job opening.

Visitors who provide information to us about the company for which they work are presumed to have the authority to provide such information.

Registration
To use certain portions of our Sites and to access certain requested content and information, a user must first complete registration and request forms. During registration and requests, users are required to provide personal information.

Information We Collect Automatically:
Like most websites, we also automatically collect and store certain anonymous information from visitors on our Sites. This may include the Internet Protocol (“IP”) address or device ID, operating system, browser type, traffic, the pages of the Sites that you visit, the time spent on those pages, access dates and times, and location data.

Do Not Track
Our web servers do not change the way they respond to your browser when they receive a “do not track” signal.

How We Use Your Information:
We use contact and other information obtained through our Websites to deliver, maintain, develop and monitor the Websites and to enhance user experience on our Sites and/or Websites by personalizing the experience. Information we collect may also be used in the following ways:

To register you as a user of the Website(s) and/or products/services.
To identify you when you visit the Websites, including assisting you with logging in.
To provide our services and Information to you and to notify you about changes to our services and/or the Websites.
To ensure the content on the Websites is presented in the most effective manner.
To help administer our Websites, and services generally.
To plan future content, services and events based on users’ interests and our assessment of important trends and issues in the industries we serve.
We may use a visitor’s IP address to determine roughly where users are located, so that we can deliver advertisements to them while they are on our Websites.
We may create de-identified or anonymous data from your information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Policy.

Who Else May Use Your Data
We and our affiliates may share personal information with each other and use it consistent with this Privacy Policy and with applicable laws and regulations. They may also combine it with other information to provide and improve our products, services, content and advertising. We may share aggregated demographic information and user data with our partners. This data/information is not linked to any personal information that can identify any individual. In addition to the purposes described above, we may share your personal information with third parties in the following circumstances:

To third-party vendors, consultants or other service providers in connection with the operation of the Websites and our business, who need access to such information to carry out their work for us. This may include cloud computing companies, cloud communications platform as a services (PaaS), web analytics services, employment-related service providers, and mailing and emailing services. For example, we may use credit card processing or verification service companies to verify credit card information.
To our affiliated companies with proper consent.
As required by law to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
To protect the rights, property or safety of Mount Street or other of its Websites’ users.

In addition, we may offer various features through service providers. When visitors use these services they are leaving the Website(s) (oftentimes via a link on our Website) and are providing information directly to the provider of these services. However, any information transferred outside of the Websites will remain subject to this privacy policy at all times.

Social Media:
You may log onto third party social networking websites via social network sharing widgets to share, comment or recommend our blog posts. The social network sharing widgets may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy policies to learn what information they collect, use, and share.

Your Access, Opt-Out and Other Data Rights:
You have the right to request confirmation from us as to whether or not we are processing your Personal Information in our capacity as a Data Controller. Where we are processing your Personal Information as a Data Controller, you also have the right to request access to, modification of, or deletion of such Personal Information.

You also have the right in certain circumstances to receive the Personal Information concerning you that you provided to us, to restrict processing of your Personal Information, or to transmit such data to another data controller.

To exercise these rights with respect to your Personal Information, please contact us at Compliance@mountstreetllp.com.

At any time, you may withdraw the consent you provide for the processing of your Personal Information for the purposes set forth in this Privacy Policy by contacting us at Compliance@mountstreetllp.com, provided that we are not required by applicable law or professional standards to retain such information.

You may inquire about these rights as follows:

You can call the following telephone number: (+44) (0) 207 659 7000
You can send an email to: Compliance@mountstreetllp.com

Security:
We are committed to protecting the security, integrity and confidentiality of the data through the use of a variety of commercially reasonable, industry standard physical, administrative and technical safeguards. This includes, but is not limited to, access controls, employee training, industry-standard encryption, firewalls, and server authentication technology to protect data when the Sites are accessed using a supported web browser. We host data in cloud-based environments including Amazon Web Services (AWS), Google Cloud Platform (GCP), and EMC that use intrusion protection and intrusion detection systems and other industry-standard technology in an effort to prevent access from outside intruders.

It is your responsibility to keep confidential the user name and password provided to you by Mount Street at the time of your registration on the Website. If you become aware of any unauthorized use of an account, loss of your account credentials or suspect a security breach, notify us immediately.

The Internet, however, is not perfectly secure and we are not responsible for security incidents not reasonably foreseeable or reasonably within our control.

Data Retention:
We retain data for as long as necessary to provide access to the Websites to you or as long as legally permissible in accordance with applicable law, including as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, comply with applicable industry standards, and in accordance with disaster recovery procedures.

Children:
We do not direct any Sites or Websites to, nor do we knowingly collect any Personal Information from children under thirteen.

Changes to this Privacy Policy:
We keep this Privacy Policy under review and may occasionally make changes to it (including if necessary as a result of development of the Websites or services, changes to technologies, legal or regulatory changes). We reserve the right to change the provisions of this Privacy Policy at any time by posting a revised Privacy Policy on the Site and indicating on the Privacy Policy the date it was last updated. Visitors’ use of the Sites or Websites following the posting of such changes or revised statement shall constitute their acceptance of any such changes. Visitors who do not wish to accept the revised Privacy Policy should not use or access (or continue to use or access) the Sites, Websites and/or services. In some cases, we may request your consent to certain changes, and in certain circumstances and as required by law, if we have an email address on file for you, we may notify you about certain changes via email.

We encourage visitors to review our Privacy Policy whenever they visit our Sites and Websites to determine if any changes have been made and to make sure that they understand how any personal information they provide will be used.

Contact Us:
If you have any questions about this privacy statement, the practices of this Website, or your dealings with this Website, you can contact:

Mount Street Mortgage Servicing Limited, Woolgate Exchange, 25 Basinghall Street, London EC2V 5HA
Compliance@mountstreetllp.com

If you have concerns or complaints regarding this Privacy Policy, you may have a right to lodge a complaint with a supervisory authority.