Last updated: August 13, 2025

CW Mortgages (operating as Ian Smith, Mortgage and Protection Advisor) is part of Clarity Wealth Management LLP.

We are committed to protecting your privacy and ensuring your personal information is handled securely and in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and Financial Conduct Authority (FCA) requirements.

This Privacy Policy explains how we collect, use, share, and protect your personal data, as well as your rights under data protection laws.

1. Who We Are and Our Relationship with Clarity Wealth Management LLP

CW Mortgages is a trading style of Clarity Wealth Management LLP, authorised and regulated by the Financial Conduct Authority (FCA).

Clarity Wealth Management LLP is the data controller for most processing activities. CW Mortgages acts as an appointed representative and processes data on behalf of Clarity Wealth Management LLP for the purposes of mortgage and protection advice.

Contact details for data protection enquiries:

Ian Smith
CW Mortgages / Clarity Wealth Management LLP
Registered in England and Wales No: OC371189
Tel: 01708 535 946
Email: iansmith@claritywm.co.uk

If you have concerns about our data handling, you may also contact the Information Commissioner’s Office (ICO) at www.ico.org.uk or call 0303 123 1113.

2. What Data We Collect
– Personal Identification Data – Full name, address, date of birth, contact details.
– Financial and Employment Information – Income, expenditure, credit history, employment details, mortgage details, insurance needs.
– Special Category Data – Health information relevant to protection policies (processed only with your explicit consent).
– Technical Data – IP address, browser type, and other website usage information via cookies.
– Communication Records – Notes from calls, meetings, and correspondence with you.

3. How We Use Your Data
We process your personal data to:
– Provide regulated mortgage and protection advice.
– Arrange and manage mortgage or insurance applications.
– Conduct credit checks and risk assessments (including using lender decision systems).
– Comply with legal, regulatory, and FCA requirements.
– Communicate with you about your application, policy, or enquiry.
– Send you relevant marketing communications (only with your consent).
– Improve our services, website, and customer experience.

4. Lawful Bases for Processing
We rely on the following lawful bases under UK GDPR:
– Consent – For marketing communications and processing special category data.
– Contract – To provide the services you have requested.
– Legal Obligation – To comply with FCA and other regulatory requirements.
– Legitimate Interests – To improve our services and respond to your enquiries.

5. Automated Decision-Making and Profiling
Some mortgage lenders and insurers use automated decision-making tools (such as credit scoring systems) to assess your application.
Where such automated decisions have a legal or significant effect, you have the right to request human review, express your point of view, and contest the decision.

6. Data Retention
We retain your personal data for as long as necessary to:
– Fulfil the purposes outlined above.
– Comply with FCA rules and legal obligations (typically a minimum of 6 years after the end of our relationship, but in some cases longer where required by regulation or for ongoing legal matters).

7. Sharing Your Data
We may share your personal data with:
– Mortgage lenders and insurance providers.
– Third-party service providers who assist in delivering our services (for example, compliance consultants, IT support, or document storage providers).
– Regulatory bodies such as the FCA.
– Legal or professional advisers.
– Clarity Wealth Management LLP group companies for compliance and service delivery.

We will never sell your personal data to third parties.

8. International Data Transfers
Where we use service providers based outside the UK (for example, secure cloud storage or email marketing systems), we ensure appropriate safeguards are in place, such as:
– Adequacy regulations recognised by the UK
– Standard Contractual Clauses (SCCs) approved by the ICO

9. Your Rights Under UK GDPR
You have the right to:
– Access the personal data we hold about you.
– Request correction of inaccurate data.
– Request deletion of your data (where legally possible).
– Restrict or object to certain types of processing.
– Withdraw consent for marketing at any time.
– Request your data in a portable, machine-readable format.

10. Marketing Preferences
We will only send marketing communications if you have given us your consent. You can opt out at any time by:
– Clicking the unsubscribe link in our emails.
– Contacting us using the details above.

11. Data Security and Breach Notification
We have implemented appropriate technical and organisational measures to protect your data from loss, misuse, unauthorised access, or disclosure.
In the event of a personal data breach that poses a high risk to your rights, we will notify you and the ICO in accordance with legal requirements.

12. Changes to This Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated to you, and the latest version will always be available on our website.

Cookies Policy

Our website uses cookies and similar technologies to enhance your browsing experience, analyse site traffic, and support marketing activities.

1. What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They can be “session cookies” (deleted when you close your browser) or “persistent cookies” (stay until they expire or are deleted).

2. Types of Cookies We Use
– Essential Cookies – Required for the operation of our website (e.g. secure log-in).
– Analytics Cookies – Help us understand how visitors use our site so we can improve it.
– Functionality Cookies – Remember your preferences to personalise your experience.
– Marketing Cookies – Track browsing behaviour to deliver relevant adverts.

3. Consent for Non-Essential Cookies
We will only use non-essential cookies (such as analytics and marketing cookies) with your prior consent.
When you first visit our website, you will see a cookie banner where you can accept or manage your preferences.

4. Managing Your Cookie Preferences
You can change your cookie preferences at any time by:
– Using our cookie settings tool on the website.
– Adjusting your browser settings to block or delete cookies.

Please note: blocking certain cookies may affect website functionality.

5. Third-Party Cookies
Some cookies are placed by third-party services we use, such as Google Analytics. We recommend reviewing their privacy policies for more information on how they handle data.

Cookie Table

Cookie Name	Provider	Purpose	Type	Expiry
_ga	Google Analytics	Registers a unique ID used to generate statistical data on how the visitor uses the website.	HTTP	2 years
_ga_*	Google Analytics	Used to persist session state for Google Analytics.	HTTP	2 years
_gid	Google Analytics	Registers a unique ID used to generate statistical data on how the visitor uses the website.	HTTP	24 hours
_gat	Google Analytics	Used to throttle request rate.	HTTP	1 minute
_gcl_au	Google Tag Manager	Stores and tracks conversions for Google Ads.	HTTP	3 months
CONSENT	YouTube	Stores user consent settings for embedded YouTube videos.	HTTP	2 years
VISITOR_INFO1_LIVE	YouTube	Tries to estimate the users’ bandwidth on pages with integrated YouTube videos.	HTTP	6 months
YSC	YouTube	Registers a unique ID to keep statistics of what videos from YouTube the user has seen.	HTTP	Session
wordpress_logged_in_*	WordPress	Indicates when the user is logged in and who they are.	HTTP	Session
wp-settings-*	WordPress	Stores user interface customisation preferences.	HTTP	1 year
CookieConsent	CookieBot	Stores the user’s cookie consent state for the current domain.	HTTP	1 year
mailpoet_subscriber	WordPress Email Signup	Stores information about a subscriber who signed up for email newsletters.	HTTP	Persistent