Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

Ever North Limited is registered with the Information Commissioner's Office (ICO) as a data controller under UK GDPR.

2. What Personal Data We Collect

We may collect the following categories of personal data:

3. Lawful Basis for Processing

We rely on the following lawful bases for processing your personal data:

• Contract: Processing necessary to perform a contract with you (e.g. mortgage advice, AR agreement).
• Legal obligation: Processing required to comply with FCA rules, HMRC requirements, or other legal obligations.
• Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention, business analysis, and marketing to existing clients — where these interests are not overridden by your rights.
• Consent: Where we send marketing communications to non-clients or process special category data, we will seek your explicit consent. You may withdraw consent at any time.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

• ›To provide mortgage advice and arrange mortgage products
• ›To manage your appointed representative relationship
• ›To process introducer referrals and pay referral fees
• ›To conduct due diligence and regulatory checks
• ›To comply with FCA regulatory requirements (file reviews, SMCR, RegData)
• ›To communicate with you about your mortgage or our services
• ›To send regulatory updates and compliance information (ARs)
• ›To detect and prevent fraud
• ›To improve our website and services
• ›To respond to complaints
• ›To send marketing communications (where you have given consent or we have a legitimate interest)

5. Sharing Your Personal Data

We may share your personal data with the following categories of third parties:

• Mortgage lenders: To process mortgage applications on your behalf.
• Mortgage Magic™: Our technology platform provider, for CRM, case management and compliance tools. Acts as a data processor under our instructions.
• The FCA: As required by our regulatory obligations, including AR notifications and RegData submissions.
• Professional advisers: Including solicitors, accountants and auditors under appropriate confidentiality obligations.
• Credit reference agencies: Where relevant to assessing mortgage affordability (via lenders).
• The Financial Ombudsman Service: In the event of a complaint referred to FOS.
• HMRC: Where required by law.

We do not sell personal data to third parties. We do not share personal data for third-party marketing purposes without your explicit consent.

6. International Data Transfers

We store and process your data primarily in the UK and European Economic Area (EEA). Where data is transferred outside the UK/EEA, we ensure appropriate safeguards are in place in accordance with UK GDPR Chapter 5, such as standard contractual clauses or adequacy decisions.

7. Data Retention

We retain personal data for as long as necessary to fulfil the purpose collected and as required by law and FCA rules:

8. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access:Request a copy of the personal data we hold about you (subject access request).
• Right to rectification:Request correction of inaccurate or incomplete personal data.
• Right to erasure:Request deletion of your personal data where there is no legal reason to continue processing it.
• Right to restrict processing:Request that we limit how we use your data in certain circumstances.
• Right to data portability:Request a copy of your data in a structured, machine-readable format.
• Right to object:Object to processing based on legitimate interests, including direct marketing.
• Rights related to automated decision-making:Request human review of automated decisions that significantly affect you.
• Right to withdraw consent:Where processing is based on consent, withdraw consent at any time.

To exercise any of these rights, please contact us at info@ever-north.com or by writing to our registered address. We will respond within one calendar month.

9. Cookies

Our website uses cookies to improve functionality and analyse usage. We use Google Analytics (anonymised) and may use remarketing pixels. By using our website, you consent to the use of cookies in accordance with this policy. You can manage your cookie preferences through your browser settings.

10. Data Protection Contact

For all data protection queries, subject access requests, or to exercise your rights, please contact:

11. Right to Complain to the ICO

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “last updated” date at the top of this page indicates when the policy was last revised. We will notify you of significant changes by email or by a prominent notice on our website.