1 What Information We Collect

Information you provide directly: When you submit a mortgage enquiry, complete our pre-approval form, or contact us via our website or WhatsApp, you may share:

• Full name, email address, phone number
• Country of residence and nationality
• Property location, purchase price, and loan amount sought
• Employment status and income details
• Any other information you choose to include in your message

Information collected automatically: When you visit tharrosbrokers.com, our systems automatically collect certain technical data including your IP address, browser type, device type, pages viewed, and how you arrived at our site. This data helps us maintain and improve the website.

Cookies and analytics: We use Google Analytics and Google Ads tracking to understand how visitors interact with our site and to measure the effectiveness of our advertising. See Section 5 for full details.

2 How We Use Your Information

We use your information solely for the purpose of providing mortgage brokerage services and communicating with you about your enquiry. Specifically:

• To assess your mortgage eligibility and provide you with a personalised recommendation
• To submit your application to appropriate Spanish lenders on your behalf, with your consent
• To follow up on your enquiry and keep you updated throughout the process
• To send relevant information about Spanish mortgage requirements, rates, or regulatory changes that may affect you
• To improve our website and services using anonymised, aggregated analytics data
• To comply with legal obligations including anti-money laundering (AML) and Know Your Customer (KYC) requirements applicable to Spanish mortgage brokers

3 Who We Share Your Information With

We share your personal data only when necessary, and only with:

• Spanish banks and lenders — to submit your mortgage application. We will always inform you which lender(s) we are approaching before submitting.
• Our technology providers — such as our website host (Hostinger), email provider, and CRM tools. These providers are bound by data processing agreements and may not use your data for their own purposes.
• Google — for analytics and advertising measurement (anonymised and aggregated where possible).
• Regulatory or legal authorities — if required by Spanish law, EU regulation, or a valid legal order.

In the event of a business transfer or acquisition, your data may be transferred as part of that transaction. You will be notified in advance where possible.

4 Categories of Third Parties

• Spanish financial institutions (banks and mortgage lenders)
• Cloud hosting and data storage providers
• Email and communication tools
• Analytics and advertising platforms (Google)
• Legal and compliance advisors (where required)

5 Cookies & Tracking Technologies

We use the following cookies and tracking technologies on tharrosbrokers.com:

• Google Analytics — to understand how visitors use our site (pages visited, session duration, traffic source). Data is anonymised.
• Google Ads conversion tracking — to measure when a website visit results in an enquiry, helping us improve our advertising.
• Google Tag Manager — to manage the above tags efficiently.
• Essential cookies — required for the website to function correctly (e.g. security, session management).

You can control cookies through your browser settings. Disabling non-essential cookies will not affect your ability to use the site or submit an enquiry. To opt out of Google Analytics tracking, visit tools.google.com/dlpage/gaoptout.

6 How Long We Keep Your Information

We retain your personal data for the following periods:

• Enquiry data (no application submitted): Up to 12 months from your last contact, after which it is securely deleted.
• Completed mortgage applications: Up to 7 years, as required under Spanish financial regulations and AML obligations.
• Analytics data: Aggregated and anonymised; retained per Google’s standard retention settings (up to 26 months).

When we no longer have a legitimate reason to hold your data, we delete or anonymise it promptly.

7 How We Keep Your Information Safe

We implement appropriate technical and organisational measures to protect your personal information, including:

• SSL encryption on all pages of tharrosbrokers.com (HTTPS)
• Secure, access-controlled hosting via Hostinger
• Limited internal access to personal data on a need-to-know basis
• Regular security reviews of our website and systems

No method of data transmission over the internet is 100% secure. While we take every reasonable precaution, we cannot guarantee absolute security. If you suspect any unauthorised access to your information, please contact us immediately.

8 Children’s Privacy

Our services are intended exclusively for adults (18+) seeking mortgage financing. We do not knowingly collect personal information from anyone under the age of 18. If you believe we have inadvertently collected such data, please contact us immediately and we will delete it.

9 Your Privacy Rights

As a resident of the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under GDPR and applicable data protection law:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — ask us to correct inaccurate or incomplete data
• Right to erasure — request deletion of your personal data (“right to be forgotten”)
• Right to restrict processing — ask us to pause processing in certain circumstances
• Right to data portability — receive your data in a portable, machine-readable format
• Right to object — object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — where processing is based on consent, you may withdraw at any time

To exercise any of these rights, please use our contact page. We will respond within 30 days. If you believe we are handling your data unlawfully, you have the right to lodge a complaint with the Spanish data protection authority:

10 Do-Not-Track

Some browsers allow you to send a “Do Not Track” (DNT) signal to websites. There is currently no universally accepted standard for how websites should respond to DNT signals. At this time, tharrosbrokers.com does not alter its data collection practices based on DNT signals. If a recognised standard is adopted, we will update this policy accordingly.

11 Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. The “Last Updated” date at the top of this page will always reflect the most recent revision. For material changes, we will notify you directly where possible. We encourage you to review this page periodically.