Website Privacy Policy

1 · Introduction

1.1 Important information and who we are

Welcome to Mortartec Ltd's Privacy and Data Protection Policy ("Privacy Policy"). At Mortartec Ltd ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. It will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Business contacts
• Third parties connected to your customers
• The end-clients (mortgage and protection applicants) of our subscribing brokers, whose data is processed through our platform

and any other people that the organisation has a relationship with or may need to contact. This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Mortartec Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to privacy@mortartec.com or by post to 57 Kingsland Road, London, E13 9NX, United Kingdom.

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.

1.3 Processing data on behalf of a Controller

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). The responsibilities below may be assigned to an individual or may apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see section 2.2 below);
• Ensure that Processors authorised to process Personal Data have committed to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in fulfilling its obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the GDPR, and allow for and contribute to audits and inspections;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process it except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 · Legal basis for data collection

2.1 Types of data / scope

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you, grouped together below. Not all of the following will necessarily be collected from you, but this is the full scope of data that we collect:

• Profile / Identity Data: your first name, last name, gender, date of birth.
• Contact Data: your phone number, addresses and email addresses.
• Marketing and Communications Data: your preferences in receiving marketing and other information from us.
• Billing Data: your debit and credit card information, such as the name attached to your payment details and your billing address.
• Financial Data: your banking details, e.g. your account number and sort code.
• Transactional Data: details and records of all payments you have made for our services or products.
• Customer Support Data: feedback and survey responses.

We also collect, use and share Aggregated Data such as statistical or demographic data, for example to calculate the percentage of users accessing specific platform features and to generate anonymised industry insights regarding mortgage processing times and software usage. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law, as it will not directly or indirectly reveal your identity. If we combine Aggregated Data with your Personal Data so that it can identify you, we treat the combined data as Personal Data.

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.

2.2 The legal basis for collecting that data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• Consent:certain situations allow us to collect your Personal Data, such as when you tick a box confirming you are happy to receive email newsletters from us, or 'opt in' to a service.
• Contractual Obligations: we may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• Legal Compliance: we are required by law to collect and process certain types of data, such as in relation to fraudulent activity or other illegal actions.
• Legitimate Interest: we might need to collect certain information to meet our legitimate interests, covering aspects that can be reasonably expected as part of running our business and that will not have a material impact on your rights, freedom or interests.

3 · How we use your Personal Data

3.1 Our data uses

We will only use your Personal Data when the law allows us to. The table below sets out the different types of Personal Data we collect and the lawful basis for processing it. Examples are indicative; the purposes for which we use your data may be broader than described, but we will never process your data without a legal basis for a related purpose.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt in. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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, compatible reason. If we need to use your Personal Data for an unrelated purpose, we will notify you and 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.

4 · Your rights and how you are protected

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

• Right to be informed about our purposes for processing your data, how long we store it, and who it will be shared with. We have provided this information in this policy.
• Right of accessto receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it (a "data subject access request").
• Right to rectification of incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide.
• Right to erasure of Personal Data where there is no good reason for us to continue processing it. We may not always be able to comply for specific legal reasons, which we will notify you of where applicable.
• Right to object to the processing of your Personal Data, including for direct marketing, or where we rely on a legitimate interest. This is not an absolute right and only applies in certain circumstances.
• Right to restrict processingin certain circumstances, for example where you contest the data's accuracy or our use is unlawful but you do not want it erased.
• Right to data portability to request the transfer of your Personal Data to you or a third party in a structured, commonly used, machine-readable format. This right only applies to automated information you initially provided consent for, or where we used it to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at privacy@mortartec.com.

4.2 Your control over our use of your data

You may delete your account at any time; this will remove your account page from our systems and related software. We do not guarantee the ability to delete all stored data. If you would like us to delete or correct personally identifiable data, let us know and we will action your request as soon as practicable. You can access information associated with your account by logging in. Your account information is protected by a password; please prevent unauthorised access by protecting your password and signing off after use.

California Privacy Rights: under California Civil Code sections 1798.83-1798.84, California residents may ask us for a notice identifying the categories of personal information we share with affiliates and/or third parties for marketing purposes. If you are a California resident and would like a copy, please submit a written request to privacy@mortartec.com.

4.3 How we protect your Personal Data

We implement a variety of security measures to ensure the security of your Personal Data, including industry-standard encryption for data both at rest and in transit, securing all API endpoints, enforcing strict role-based access controls for platform users, and hosting our infrastructure exclusively on secure, UK-based AWS cloud servers to maintain strict data sovereignty. Any Personal Data collected is only accessible by a limited number of employees with special access rights, bound by obligations of confidentiality. Unfortunately, no transmission of data over the internet is guaranteed to be completely secure, so while we strive to protect your Personal Data we cannot ensure or warrant the security of any data you transmit to us. Any such transmission is done at your own risk.

4.4 Opting out of marketing

You can ask us to stop sending you marketing messages at any time by following the 'unsubscribe' links within any marketing message, or by contacting us at privacy@mortartec.com. Where you opt out, we will continue to retain other Personal Data provided to us as a result of interactions not related to your marketing preferences.

4.5 How to request your data

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, if your request is clearly unfounded, we could refuse to comply. We may need to request specific information from you to confirm your identity and ensure your right to access the data, as a security measure.

5 · Your data and third parties

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it and pursuant to our instructions. We may also share Personal Data with interested parties in the event that we anticipate a change in control or the acquisition of all or part of our business or assets. If Mortartec Ltd is sold or makes a transfer, we may transfer, sell or assign your Personal Data to a third party as part of that transaction. We may share your Personal Data at any time if required for legal reasons or to enforce our terms or this Privacy Policy.

5.2 Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking 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 Site, we encourage you to read the privacy policy of every website you visit.

6 · How long we retain your data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

7 · Age limit for our users

You must not use Mortartec Ltd unless you are aged 18 or older. If you are under 18 and you access Mortartec Ltd by lying about your age, you must immediately stop using it. This website is not intended for children and we do not knowingly collect data relating to children.

8 · International transfer of data

Your information may be stored and processed in any country or jurisdiction where Mortartec Ltd has facilities. By using Mortartec Ltd, you permit and consent to the transfer of information, including Personal Data, in accordance with this Privacy Policy.

9 · Notification of changes and acceptance

We keep our Privacy Policy under review and will place any updates here. This version is dated 19 March 2026. By using Mortartec Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Mortartec Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

10 · Interpretation

All uses of the word "including" mean "including but not limited to", and the enumerated examples are not intended to limit the term they illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right not to respond to emails. You are more likely to get a reply if your request is polite, reasonable, and there is no relatively obvious other way to deal with your concern.

Our staff are not authorised to contract on behalf of Mortartec Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Mortartec Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, the email content will be read down to grant precedence to the latter. The only exception is genuine correspondence expressed to be from the Mortartec Ltd legal department.