Protecting your personal information
We’re committed to protecting you and your family’s personal information. This policy applies to any personal information or “personal data” that we collect from you. It covers how we:
• Store; and
• Destroy/Remove your personal data.
We sometimes use your information to provide additional marketing services, but only if you have consented to this, or – in circumstances where your consent is not required – you have not opted out. For more information, see Section 6 When will we contact you below.
1. Our commitment to you
We are committed to safeguarding your personal information and we comply with all relevant data protection laws including:
• The Data Protection Act 2018;
• The UK GDPR – General Data Protection Regulation; and
• Any regulations made under or to supplement either of the above, relating to the personal information that we collect about you.
2. When do we collect personal information about you, and what types of personal information do we collect?
We collect personal information when you:
• Visit/access one of our websites or platforms¹.
• Contact us, or otherwise engage with us by telephone, email, SMS, letter, social media or any other form of messaging.
• Visit any of our offices or developments.
• Complete any of our website forms for a service request.
• Access information about our developments and/or new homes via a third-party provider, such as a property portal e.g. Rightmove or others.
• Enter into any transaction with us, whether it’s in person or any other way.
• Request information from us with a view to entering into a transaction with us.
• Tag our social media accounts on social media platforms or use hashtags that are relevant to us and our business.
• Engage in any consultation exercises with us in relation to any proposed new developments.
• Your name;
• Your email address;
• Your postal address;
• Your telephone or mobile number;
• Information you provide when you complete forms provided by us (such as, in our reservation agreement);
• Your Internet Protocol (IP) address;
• Correspondence between you and us;
• Any updates to information provided to us;
• CCTV recordings, if you visit one of our sites; and
• Information and images in your social media posts that we repost.
As well as information about:
• Your use of our website; and
• The purpose of your visit to our website or the reason you made contact with us.
Requests for additional information
Sometimes we will require you to provide further personal information. This may be if you are purchasing or thinking about purchasing a home from us, or if you ask us to contact you with properties/developments that may be of interest to you. Whenever we do this, we will tell you why we are collecting this information and how we will use it.
Identity verification and anti-money laundering
One of the circumstances in which we may request additional personal information from you is when you are thinking about purchasing a home with us and, before you can do so, we need to verify your identity and comply with our anti-money laundering obligations.
To carry out those checks, we may use a system provided by a third party, Credas Technologies Limited (Credas). We will provide certain personal information to Credas (your name, address and contact information). Credas will then contact you to ask you to download the Credas mobile application and to provide certain additional personal information via that mobile application (this may include, for example, your financial data, your photo and passport information). Credas will verify the information you have provided against other databases that they have access to (such as the full electoral roll, and information held by credit reference agencies), before providing us with the results of those searches to allow us to decide whether we can progress with your house purchase. In carrying out these checks Credas may handle certain special categories of personal information; in particular, biometric data (if they need to scan the photo on your passport) and information about any criminal convictions or offences you have committed.
Where Credas needs to verify your information against databases held by credit reference agencies – because it cannot verify that information by reference to the full electoral roll – then those checks will leave what’s called a “soft footprint” on your credit record; a soft footprint has no negative effect on your credit rating.
Queries via social media
Our social media pages, such as Twitter and Facebook, are monitored by a third-party company. They pass any customer queries, questions or complaints onto the most appropriate person in our team, so that we can respond accordingly.
If you contact us online, we may monitor the type of device used by you. This may include specific identification, such as your IP address².
CCTV and call monitoring
Our developments and Sales Offices use CCTV to make sure we provide a safe and secure environment for all visitors to our premises and to ensure the protection of our employees and property. We also record calls to and from our Customer Services Helpline for training, monitoring and quality purposes.
4. How will we use this information?
We do not sell customers’ personal information to third parties and will only use your personal information to provide you with details of our own products, properties or developments which we believe will be of interest to you. In addition, we may use your information to:
• Contact you. If you have indicated a specific interest in a property/development, or a particular area in which we have properties/developments available.
• Provide a relevant service. If you have contacted us for a specific purpose or accessed our services by completing a website form and not opted out, we’ll take into account your perceived preferences for a specific property type or location. In the event that you do not wish to receive this personalised service, you can unsubscribe from our emails or similarly contact us as set out in Section 12 of this policy.
• Tailor our service to your location. With your permission, we may use IP addresses and device identifiers to identify your location. We will use this for general, depersonalised statistical purposes. We may also use this information to direct you to specific developments/properties in your area.
• Improve and promote our products, services, properties or developments. Where it is in our legitimate interests to do so, we provide information to third parties for research, market research and analytical purposes. These activities will be undertaken to help us to improve and promote our products and services and provide consumer insight. We also use personalised online advertising to tell you about products, properties or developments which we believe will be of interest to you. This means that after visiting our websites, or otherwise engaging with us, you may see advertising for our products, services, properties or developments on other third-party websites. No personal information will be publicly available (unless made publicly available by you).
• Advertising on social media, TV and other platforms.
o We share your personal information with social media, TV and other platforms, on the basis of our legitimate interests, so that they can show you (and others like you) adverts about us, our properties and our services, if we (and they) think you will be interested in seeing them. For example, when we use Facebook’s Lookalike tools, we share your e-mail address in a protected format with Facebook so that we can create an audience of other Facebook users based on the information Facebook holds about you.
o We will use your personal information with those platforms to measure the effectiveness of, and engagement with, the advertising.
o We will also share your personal information with those platforms to try to make sure that you do not see adverts from us at a time when you are unlikely to be interested in them; usually, because you have just purchased from us. After a period of time, you may start seeing more of our adverts, in case you are thinking about moving again.
o Those platforms’ use of your personal information is governed by their own privacy policies, which you should read carefully. We cannot be responsible for any personal information about you that is collected and stored by those third parties.
o We may use your social media post on our social media account page when your post has some relevance to our business and only with your permission.
Please rest assured that any personal information given to us for a specific use or purpose will not be used for any other incompatible purpose without your notification and (where appropriate) permission. See Section 12.
5. Legal basis for use of your personal information
b) our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
i. run, grow and develop our business;
ii. operate our websites;
iii. ensure a safe environment for our residents and suppliers;
iv. carry out marketing, market research and business development; and
v. for internal group administrative purposes.
If we rely on your consent to use your personal information in a particular way (for example, for marketing), but you later change your mind, you may withdraw your consent by contacting us at firstname.lastname@example.org (or, in relation to marketing, you can choose to unsubscribe).
6. When will we contact you?
We may contact you:
• For legitimate purposes aligned with our reservation agreement.
• In relation to a previous communication from you. This includes any comment or complaint concerning us, our services, properties or developments, or any previous contact we may have had with you.
• If you requested further information or signed up to a product, property or development, whether directly through us or via a third-party provider, such as a property portal.
• To provide you with additional information concerning a specific property/development, type of property/ development or similar properties/developments to those in which you have expressed an interest.
• For public consultation via online platforms or third parties to assist with canvassing the views in relation to any proposed new developments.
• To obtain your permission to use your social media post on our own social media account page (i.e. reposting your photo/ video on Instagram).
• For marketing purposes via email, SMS, phone or post, if you have agreed to this or where you have requested a service from us and not opted out. You can easily unsubscribe from any of those sources at any time. We will deem a service request to be any of the following:
– Online appointment booking – using our appointment tool on the website to select a date and time to visit one of our developments.
– Arrange a viewing – to request a viewing. In this instance we will call you to arrange a suitable time for an appointment for you to visit one of our developments.
– Call-back request – when you request us to call you back to find out more about one of our developments.
– Keep me informed – this is where you ask us to keep you updated on a development that has not launched yet (coming soon site).
– Download brochure – when you request to download a brochure of one of our developments.
– Registration – when you register on our website with an account to store your searches, etc.
Marketing and tailoring our service to you
We may personalise our communications with you based on the information you provide to us and the information we obtain when you use our websites and platforms.
Marketing and third parties
We do not allow the information we hold about you to be shared with third parties for them to use for marketing their own products and services. However, if you show an interest in a specific property/development or type of property/development via a third-party website, such as a property portal, this is outside of our remit – we have no control over who else can contact you.
We may send you articles, guides and information in relation to household related topics that have been produced in conjunction with one of our carefully selected charitable partners in order to provide you with inspiration and guidance.
7. Service Communications
We offer regular information by emails, telephone and SMS communications concerning our properties and developments, including changes to any terms or conditions.
8. Sharing your personal information
We will retain your information within our group of companies, except:
At your request: If you have requested that we share your personal information with a third party, or have given your consent for us to do so.
To fulfil our legal obligations or our contractual/similar obligations to you: For example, in connection with any property you are in the course of purchasing or have purchased from us, or which you had previously sought to purchase from us. This could include sharing your personal information with the following third parties or categories of third parties:
• To our solicitors, your solicitors or other advisers for the purposes of progressing a sale or dealing with any issue you may have.
• To a third party for the purposes of carrying out a survey in relation to your experience with us.
• With a consultant or a subcontractor appointed to carry out/required to carry out work to a property which you have purchased.
• To any of your advisers in connection with any contract or transaction entered into with us for the purposes of performance of our obligations.
• For statistical or similar analysis in relation to purchase or use of our properties, products or any service we provide.
• To third parties (including Credas) for the purposes of verifying your identity and complying with our anti-money laundering obligations (as described in more detail in Section 3).
• To third parties for the purposes of destroying or deleting any personal information.
• To third parties for the purposes of supporting our public consultation process in relation to any proposed new developments.
• To our followers on our social media accounts in the case we repost your social media post, with your permission.
Keeping you in the know
When you enter into a contract with us, we will set out, as comprehensively as possible, the purposes for which we may use your personal information in order to fulfil our contract with you and address any issues relating to our performance.
9. Transfers of personal information outside the UK
9.1 Your personal information may be used, stored and/or accessed by staff or suppliers operating outside the UK.
(a) ensuring that there is an adequacy decision by the UK Government, which means that the recipient country is deemed to provide adequate protection for such personal data (this applies in relation to transfers of personal information to the European Union, for example); or
(b) where we have in place standard model contractual arrangements with the recipient which have been approved for use in the UK. These model contractual clauses include certain safeguards to protect the personal data.
9.3 Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us by email at email@example.com at any time.
10. Is there an age restriction to who we can contact?
If you are under the age of 18, you should obtain your parents’ or guardians’ permission before you contact us. It is unlikely that we will be in a position to provide you with any information which may assist you, or be relevant to you, until you reach the age of 18 – this is simply because of the nature of the legal obligations you will enter into when purchasing a property.
If you are under the age of 18 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
Please contact us at firstname.lastname@example.org if you are aware that we may have inadvertently collected personal information from someone under the age of 18.
11. How long do we store your information?
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. This is dependent upon its purpose, the amount of time set out in the contract you enter into with us, and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. In particular:
• Purchasing a property: If you enter into a contract with us to purchase a property, we will hold your information for a maximum of 12 years from the date of completion of that purchase.
• Anti-money laundering: In the event that you provide us with personal information so that we can fulfil any anti-money laundering obligations, we will retain such information for a period of 5 years – this is to fulfil our legal obligations.
• If you contact us: If you get in touch regarding any of our properties/developments or types of property/developments or the services we provide – whether we receive such contact directly from you or via a third party – we will retain your personal information until whichever of the below happens first:
o You request that we delete it: We will need to retain a record of your request to be deleted.
o A maximum period of 2 years: From the date that you last made contact with us – directly or via a third-party – in relation to any of our properties or developments.
12. Your rights
Right of access to your personal information
You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom.
Deletion of personal information “Right to be forgotten”
It is your right to request the deletion of your personal information from our records, except (as explained above) if it is necessary for us to perform our legal obligations or contractual obligations to you or another third party.
We will use all reasonable efforts to delete (aside from the note of your request to be deleted) all information in our possession which constitutes, in our reasonable opinion, personal data information belonging to you.
Within reason, we will aim to make anonymous and/or delete any of the personal information which we hold in relation to you. It is in the nature of digital or computer records that we cannot guarantee that every trace or record of your personal information will be removed, but we will delete it as far as it is reasonably possible for us to do so.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
Right to object
You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest (for example, where we use your personal information for the purposes of advertising our properties or developments on social media and other platforms, including telecommunications channels).
Other rights include the right to:
• update any of your personal information which is out of date or incorrect;
• restrict the way that we process your personal information;
• prevent the processing of your personal information for direct marketing purposes; and
• request that we provide your personal information to a third party service provider (the right to data portability).
Sending and responding to a request
A request to exercise your rights in relation to your personal information should be addressed to the Data Protection Manager at London Realtors at our registered office, or by email to email@example.com
Please note that while we always strive to comply with any requests you make, we cannot guarantee to action any request if it is not made using the method outlined above. We will consider all requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law).
Certain personal information may be exempt from such requests in certain circumstances; for example, where we need to keep using your personal information to comply with our own legal obligations or to establish, exercise or defend legal claims.
We don’t generally charge a fee for responding to a request by you to exercise your rights. However, we may require you to prove your identity (with two documents of approved identification) before searching our records. The following are examples of the type of identification that we can accept in order to process your information request:
• Driving licence.
• Birth or marriage certificate.
• Utility bill (from the past 3 months).
• Current vehicle registration document.
• Bank statement (from the past 3 months).
• Rent book or similar tenancy agreement (that covers the past 3 months).
Please note, if we have previously established your identity and it matches the information you provide, this may be sufficient for the purposes of actioning your request. If you have not previously provided us with identification, then we may require you to provide copy documentation of the examples listed above in order to process your request.
The amount we charge and the period of time in which we are able to action your request may alter by law. If so, this policy will be amended.
Third party platforms
13. Accessing our platforms from outside the UK.
Depending upon your location, different privacy rules may apply as a matter of law. Any personal information that we use or process is done so in accordance with the law applicable in England, Wales or Scotland, as appropriate.
14. Web browser cookies.
What is a cookie?
A cookie contains a small amount of data and (typically) a unique identifier. When you access any of our websites or platforms (or those of third-party providers) a cookie will be sent to your device. The cookie records information about your online preferences and therefore allows us to tailor our websites and any contact with you to your specific interests.
The information we obtain by monitoring all visits to our websites enables us to improve, through anonymous analysis, our services to our customers and visitors.
Your web browser may also provide us with information concerning your device, such as an IP address or details about the browser you are using. For example, if you are looking at a specific location or property, we may use your location to ensure that any web pages or communications are tailored to you.
Information about other websites
We cannot control any information concerning websites other than those operated by us. You must refer to those websites for their terms and conditions and privacy policies.
15. Mobile applications.
We occasionally release mobile applications to complement specific developments. Use of these mobile applications is set out in the terms and conditions, which you will need to accept in order to load and access the app on your device.
16. Changes to our privacy and cookies policy.
We may make changes and update our privacy and cookies policy from time to time and in accordance with updated legislation. Any such changes will be shown here as part of our privacy and cookies policy and will apply from the date that they are published. Please check back frequently to see any updates or changes to this policy.
Where appropriate, we will notify you of any changes by post or email; in certain circumstances, we may also need your consent to those changes.
17. Contacting us concerning our privacy and cookies policy.
Any contact you wish to make with us concerning this policy or how it works in practice should be directed to the Data Protection Manager. Please either write using the email address provided, or via post to our registered office:
The Suite: B5-21 Room 21 Floor 5 Block B
The Vista Center, 50 Salisbury Road
Hounslow London TW4 6JQ
You may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
¹ Platforms are the means by which we establish digital contact, including websites operated by us.
² IP addresses are specific to any device used. This could be a laptop computer, tablet or phone.
³ Similar developments may include developments in similar locations. Properties may include other properties within our range, which we consider relevant based on previous contact with you.