This privacy policy explains how we collect, use, transfer, share and protect your personal information. That includes information you give us when you visit our website, sign up for a Habito account, or buy one of our products or services. This also includes information we collect from you or other sources when we provide our services. We’ll also explain your privacy rights and how the law protects you.
When we use the words ‘we’, ‘us’, ‘our’, or ‘Habito’ in this policy, we’re talking about Hey Habito Ltd. And when we say ‘you’ or ‘your’, we’re talking about anyone whose personal information we process.
Habito is registered with the Information Commissioner’s Office (ICO) under registration number ZA153186.
Habito is the data controller for the personal information we collect and use about you. That means we determine the purpose and means of processing your personal information.
We might also act as a processor in some instances. In all cases, we’ll treat your personal information as confidential and in accordance with the applicable data protection legislation, your personal information will only be shared as per this privacy notice.
We might make changes to this privacy policy from time to time. If we make substantial changes, we’ll let you know, usually by email. If you’d like a copy of a previous version, email us at [email protected].
We collect, use, store and transfer two types of data.
Personal data is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which allow us to identify you.
Special Category data is information which is classified as ‘sensitive’ under data protection legislation. This could include health data, religion or sexual orientation. There are also special conditions for the use of criminal conviction data. This special category data requires us to have additional lawful bases under the Data Protection Act 2018 to collect, store and process.
If you’re enquiring about, or applying for a mortgage or protection through Habito, we’ll collect personal information from you, as laid out in the table below.
We may request additional information from you which is relevant to the service being provided.
If you’re making a joint application, we’ll also collect some of this information about the person you’re applying with, such as your spouse. Make sure you have their agreement before you give us their data.
If you’re applying for a company buy-to-let mortgage, we’ll collect some of this information about the people you have a financial link with. For example, the directors or certain employees of your company. Make sure you have their agreement before you give us their data.
We don’t offer products or services to children, but in some instances, we may need to collect the name and date of birth of children and share this with the selected mortgage or protection provider.
Any telephone calls made to or from you may be monitored and recorded for training, compliance and security purposes.
If you’re a returning Habito customer
We’ll use some of the personal information you gave us last time to help you the next time. That way, you don’t have to type in all your info again. If we do this, we'll always check that your information is accurate and up to date
Here’s how we might collect personal information on our website, over live chat, on the phone, or from other companies and places.
You might give us data (for example about your identity) when you do any of these things:
Our website automatically collects technical data – things like the equipment you’re using, as well as a record of what pages you’re visiting. We use cookies for this, and we have a delicious cookie notice where you can find lots more details.
Sometimes we get personal information from somewhere outside Habito, like:
We can’t control how those other places use the data, and we’re not responsible for their privacy policies. Please be aware they may collect and process data about you in a different way than we do. You should read their privacy policies if you’d like more information about how they do that.
We use your personal information for one or more of the reasons we’ve listed below. We will only use your personal information when the law allows us to. No surprises there.
Companies can’t use your personal information without having a legal basis for using it. This reason is called a “lawful basis”. Here are the lawful bases we rely on:
Where we need to process special categories of personal information and criminal conviction information, we only do so when you have provided explicit consent.
If you’d ever like more details about the lawful bases we use to process your personal information, just ask. We love talking about data and are always happy to help.
We might share your information with other companies. But we make sure they treat it as well as we do, and (of course) in line with the law. These other companies can’t just use your information for any reason – it has to be for a specific purpose.
Here’s a list of the people and companies we might share your data with:
Habito group companies
These are companies that are controlled by Habito. We might share your data with other Habito group companies if they provide services to us. We might also do this for marketing where you’ve agreed.
Third parties
We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities, courts, tribunals and arbitrators as may be required to comply with our regulatory and legal obligations.
We may also engage with third-party service providers to provide products or other business services on our behalf. We only provide them with the personal information they need to perform the service we request. This includes IT systems providers and IT contractors as well as third-party referencing or screening agencies for the prevention and detection of crime. We contractually require them to securely protect information, and not use it for any other purpose.
An example of some third-party service providers that Habito uses and the purpose of sharing personal information with them are listed below.
Automated decision-making is when companies use computers to make decisions without humans being involved. For example, a bank might use it to approve an online loan.
We don’t do this at Habito – that’s why it’s not in the glorious table above. But we wanted to make you aware of it, because some of the companies involved in your mortgage or home-buying process might. It will be in their privacy policies if they do.
While we do not use automated decision-making at Habito, we may use AI tools to support our internal compliance processes. These tools do not make decisions about individuals and are always subject to strict human oversight.
You can ask any lender or protection provider who uses automated decision-making to give you the actual reason behind their decision (or we can ask them for you). Here’s more information on automated decision-making and your rights.
We are based within the UK, but we work with partners in the UK, in the European Economic Area (EEA), and in countries outside the EEA as well.
If we transfer your data to anyone outside the EEA, such as the Philippines, where some of our team members are located, we’ll take extra steps to protect it.
We’ll make sure the country has adequate levels of personal data protection, as determined by the European Commission.
Or, we’ll put robust contracts in place with whoever we’re transferring data to. These contracts offer the same level of protection as the UK and the EEA. For example, we rely on a contract called the Standard Contractual Clause transfer mechanism to transfer data to the US.
Get in touch if you’d like to know more about how we protect your data across borders.
Only a limited and authorised number of people can ever access your information, on a business need to know basis only.
We want to make sure your information isn’t accidentally lost, used, accessed, changed or shared in an unauthorised way. We’ve put robust security systems in place to make sure of that.
If we ever think that something’s gone wrong, we have procedures in place to deal with it. If something does go wrong, we’ll tell you – and sometimes the regulator – where we’re legally required to.
We’ll only keep your data for as long we need it to do the thing we collected it for. Or where laws and regulations tell us we need to keep it for a specific amount of time.
Usually, information is kept for 7 years, but the period may vary depending on the type of service or product you have requested from us and will be dependent upon any legal or contractual obligations we have. In certain circumstances, we may also have a statutory obligation to keep your personal information for a set period, for example, financial information for financial auditing purposes.
Sometimes we anonymise your personal data (so it can’t identify you anymore) for research or statistics. We keep that data for as long as we need it.
You can talk to us about how long we keep your data, or ask us to delete your data, by talking to us on live chat or emailing [email protected]. But sometimes, laws or regulations tell us we have to wait a certain amount of time before we’re allowed to delete your data. If we have to wait, or if we can’t delete your data, we’ll let you know the reasons why.
You have rights under the UK GDPR when it comes to your personal information. You have the right to:
If you’d like to make a request, or exercise any of your rights, email us at [email protected]. Upon receipt of your request, we’ll carry out a review and respond to confirm our decision within the relevant timeframe.
If you want to talk to us about your data or make a complaint, we’re here to help. Email us at [email protected] or write to Habito, WeWork, Moor Place, 1 Fore Street Avenue, London, EC2Y 9DT.
You have the right to contact the Information Commissioner’s Office (ICO) which is an independent organisation that protects people’s data and privacy rights. If you have a complaint, we’d love the chance to help you first, but you can also complain to the ICO at anytime.
