Privacy Policy

Last Updated: May 29, 2026

Data Privacy Notice

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.

Who we are

ITM Capital Limited collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation, and we are responsible as a data controller of that personal data for the purposes of those laws.

When we mention “Alphakey Mortgages”, “we”, “us” or “our” we are referring to ITM Capital Limited.

ITM Capital Limited is a company registered in England and Wales (company number 15075995) whose registered office is at 20 Wenlock Road, London, England, N1 7GU.

ITM Capital Limited is an appointed representative of Cornerstone Finance Group Ltd, which is authorised and regulated by the Financial Conduct Authority. Financial Services Register number is 767202.

The personal data we collect and use

In the course of providing our service to you we may collect the following personal data when you provide it to us:

  • Contact information
  • Identity information
  • Financial information
  • Employment status and employment information
  • Lifestyle information
  • Health information
  • Data about criminal convictions or offences
  • Details of any vulnerability
  • Details of your dependents and/or beneficiaries under a policy
  • Products details

Note: If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns, please contact us in one of the ways described below.

Information collected from other sources

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

The personal data we obtain from other sources may include the following:

  • From lenders and/or product providers: product details
  • From identification and verification checking agencies: identity information, sanction check information
  • From credit agency (Equifax): Credit scores and CIFAS returns

How we use your personal data

The below table sets out how we use your personal data, the lawful bases upon which we collect and use your personal data, and who we routinely share your personal data with.

Rationale/Reason for Processing Lawful Basis for Processing Third party recipients linked to that activity
To apply for decisions in principle for mortgage products and/or quotations for protection and/or general insurance products on your behalf

To apply for products on your behalf		 Performance of a contract Lenders and product providers
To refer you to third party advisers to provide you with advice in relation to estate planning, conveyancing, overseas mortgages, currency advice, and specialist advice on second charges. Consent Preferred partners who specialise in financial and legal services not offered by Cornerstone Finance Group Ltd.
To retain records of any services or advice provided to you by us in order to defend potential legal claims or complaints Legitimate interests External supplier (B2B) of data storage and data hosting services to retain records on our behalf.
To provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences. For more information see ‘Marketing’ below. Consent

Special category data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

We may process:

  • Health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
  • Criminal conviction or offence information when providing intermediary services in relation to a general insurance product.
  • Criminal conviction or offence information when providing intermediary services in relation to a mortgage product.

In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging, or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.

Marketing

We may use personal data we hold about you to help us identify, tailor, and provide you with details of products and services from us and third parties that may be of interest to you. We will only do so where we have obtained your consent and have a legitimate business reason to do this. We will do so in accordance with any marketing preferences you have provided to us.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us:

  • By phone: 02921 660550 (option 2)
  • By email: admin@cornerstonefinance.co.uk
  • By Post: Unit E Copse Walk, Cardiff Gate Business Park, Cardiff, CF23 8RB

In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email.

Whether information has to be provided by you, and if so why

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.

How long your personal data will be kept

We will hold your personal data for differing periods of time depending upon the reason we have for processing it. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Cornerstone Finance Group Ltd will not keep data any longer than 6 years from the date you last interacted with us for intermediary services. This is to meet the requirements of the Financial Ombudsman Service in investigating complaints.

Transfer of your information out of the EEA

We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

  • To access personal data
  • To correct / erase personal data
  • To restrict how we use personal data
  • To object to how we use personal data
  • To ask us to transfer personal data to another organisation
  • To object to automated decisions
  • To find out more about how we use personal data

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you, or in certain other circumstances.

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances (for example where you think the information is inaccurate and we need to verify it).

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

To contest decisions based on automatic decision making

If we made a decision about you based solely by automated means and the decision produces a legal effect concerning you, you may have the right to contest that decision.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office (www.ico.org.uk). We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us

Please contact our Data Protection Officer and/or Head of Risk and Compliance if you have any questions about this privacy notice or the information we hold about you.

If you would like to exercise any of the above rights, please email or write to our Data Protection Officer at:

Email: compliance@cornerstonefinance.co.uk
Post: Unit E Copse Walk, Cardiff Gate Business Park, Cardiff, CF23 8RB