This Policy covers our collection, processing and use of personal data when you use our Website.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. We have divided this Policy into several sections:
It is important that you read this Policy so that you are fully aware of how and why we are using your data.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let our clients and users of this Website know. However, it is your responsibility to check this Policy each time you use this Website or wish to transfer personal data to us.
Who is responsible for managing my information?
What is personal data and what do we collect?
Where this Policy refers to “personal data” it is referring to data about you from which you could be identified – such as your name, your contact details and your IP address.
If you are a potential purchaser, we collect the information that you have provided in relation to an enquiry or enquiries you have made. Information held is likely to include your name and contact details and any additional information we may need to help meet your specific requirements.
If you are selling your property we will collect details such as your name, contact details and information on the property or properties you wish to sell.
By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the “Your Rights” section of this Policy.
Data we collect from you:
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you; request property information, send correspondence to us, or engage in similar activities in which you volunteer data about yourself, we may collect, store and use the personal data that you disclose to us.
The information we collect from you may include your title, name, address, e-mail address, company, job title, date of birth, phone number but it will depend on precisely what details you volunteer to us.
Automated Collection of Data
We may also collect information about you when you visit the Website through the use of technologies such as cookies. The following are examples of information we may collect:
- information about your device, browser or operating system
- your IP address
- information about links that you click and pages you view on our Website
- length of visits to certain pages
- subjects you viewed or searched for
- page response times
- records of download errors and/or broken links
- page interaction information (such as details of your scrolling, clicks, and mouse-overs)
- methods used to browse away from the page
- the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time)
We use the data described above for different reasons: to ensure that the Website works properly and that you are able to receive the full benefit of it; also we may use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.
Third Party Resources
We may also use the services of third parties to help us to collect various data about you and the way that you use the Website.
How and why do we use/share your information?
The information you provide may be used in a number of ways, for example:
- to enable us to guide you in the purchase or sale of a property
- to enable us to advertise your property, transfer payments due to you and to provide related support services (if you are selling your property through us)
- to tell you about other properties and services which we feel may be of interest to you
- to contact you to send you property updates and other relevant information
- to help us to provide details or information you may have requested
Sharing your information
Depending on how and why you provide us with your personal data we may share it in the following ways:
- with any member of our staff within our company group
- with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality
- with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above
- your legal representative with your consent
- your insurance company with your consent
- to the prospective buyer of your property
- to the prospective vendor of the property you wish to buy
- Platforms as set out under “Legitimate Interest” (below)
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder
We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which you have been notified of, and you have indicated that you wish to receive communications about it.
We may also disclose your personal information to third parties in the following events:
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose.
Links to third party sites
Where we provide links to third party websites such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
On what legal basis will we process your information?
We will always process your personal information on lawful grounds and in particular on the grounds set out below:
- If you are a potential purchaser, we collect the information that you have provided in relation to an enquiry or enquiries you have made. Information held is likely to include your name and contact details and any additional information we may need to help meet your specific requirements.
- If you are selling your property we will collect details such as your name, contact details and information on the property or properties you wish to sell.
- If you do not provide us with the information set out in this paragraph, then we may not be able to provide you with all the information you are requesting.
We may use your name and email contact details you have given us to tell you about our own products and services which we think may be of interest to you. You may contact us at any time to request that your details are removed from our records by emailing us at firstname.lastname@example.org.
We may share your email address with Facebook or other web based advertising platforms (“Platforms”), who act as data processors for them to use on our behalf in connection with the creation of marketing and promotion for us. This may include the Platforms using socio-demographic information about you to identify other people like you, with similar interests to present our marketing to. This socio-demographic information is not used for any other purpose nor shared with any other party. No information about other individuals identified from these Platforms is shared with us at any time.
The Platforms may also use your personal data to serve targeted advertising or content to you via their Platform. You can control what advertisements you receive via the privacy settings on the relevant platform.
The above are done on the basis that they are in the legitimate interest of our company.
We may ask your consent to use your name, email address and phone number(s) in order to tell you about our own products and services which we think may be of interest to you.
You can withdraw your consent at any time.
We will hold your personal information on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you engage us to help you sell or buy a property, we are entitled to hold your personal data as part of our records after you have ceased dealing with us. We hold that data because we have a legitimate interest in keeping accurate records of the services which we have provided. However, we do not store your data indefinitely. Accordingly, you can expect us to dispose of your data approximately seven years after you cease dealing with us.
Where you approach us to enquire about employment opportunities or to apply for an advertised vacancy we will keep your details and your application on file irrespective of whether you are successful or not. We do this on the basis that we have a legitimate interest in ensuring that we are able to contact you should a suitable vacancy arise in the future. However, we will not keep your details on file indefinitely, and you can expect us to dispose of your details within a year of your original application.
Where you sign up to receive e-mail marketing from us we will retain your e-mail address on file should you ever ‘opt-out’ of receiving those e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.
In some circumstances you can ask us to delete your data: see “Your rights” below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Please note that some of our service providers may be based within or outside of the European Economic Area (the “EEA”). By submitting your personal information to us, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely, that your rights as a data subject are upheld, that we are satisfied that this is lawful and that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy laws.
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you. This right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us at email@example.com and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may ask us to correct any inaccuracies in your personal data and to add relevant details where the personal data we hold is incomplete. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. You can exercise this right at any time by writing to us at firstname.lastname@example.org and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You can exercise this right at any time by writing to us at email@example.com and make a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using emailing us at firstname.lastname@example.org or clicking the ‘unsubscribe’ link that appears in the footer of each communication. However please note that we may continue to send you service-related (ie, non-marketing) communications, such as property updates or other informative correspondence.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
Where we process your personal data on the basis that you have given us your consent to do so then you may contact us at any time to withdraw your consent
If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at email@example.com or at the address given below:
Data Protection Co-ordinator, Sunshine Villas Ltd 35 Ballards Lane, London N3 1XW.
When do you monitor telephone calls?
We never record telephone calls you have with our staff.
We keep our privacy notice under regular review and we will place any updates on our web page. If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above, please contact us at firstname.lastname@example.org.