1. WHICH PERSONAL DATA DO WE USE ABOUT YOU?
Personal data, or personal information, 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 which include the following:- identification information (e.g. full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph);
– contact information (e.g. postal address and e-mail address, phone number);
– family situation (e.g. marital status, number of children and, if relevant, their ages and what schools they attend or wish to attend);
– economic, financial and tax information (e.g. tax ID, tax status, income and other revenues, value of your assets);- education and employment information (e.g. level of education, employment, employer’s name, remuneration);
– banking, financial and transactional data (e.g. bank account details, credit card number, money transfers, assets, declared investor profile, credit history, debts and expenses);
– data relating to your habits and preferences (e.g. what is important to you in relation to your property search e.g. proximity to restaurants, gym etc)
– data which relate to your use of our products and services in relation with banking, financial, transactional data and any other real estate data; and
– technical data (e.g internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website).
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. HOW DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through data from your interactions with us (e.g.: via our website, our social media pages, meetings, emails, phone conversations, correspondence, and requests for information or documents). This includes personal data you provide when you make an enquiry, become a client or provide us with instructions, request marketing or information to be sent to you or sign up for, or meet us at, one of our events.
The data we use about you may either be directly provided by you or be obtained from other sources in order to fight against fraud, money laundering and terrorist financing. For example we may obtain data from:
– HM Land Registry; and;
– third parties such as credit reference agencies and fraud prevention agencies
3. SPECIFIC CASES OF PERSONAL DATA COLLECTION, INCLUDING INDIRECT COLLECTION
In certain circumstances, we may also collect information about you where you have no direct relationship with us.
For instance, this may happen when your contact details are provided by one of our clients if you are (for example):
– Family members;
– Co-borrowers / guarantors;
– Legal representatives (power of attorney);
– Beneficiaries of payment transactions made by our clients;
– Beneficiaries of insurance policies and trusts;
– Ultimate beneficial owners;
– Client debtors (e.g. in case of bankruptcy);
– Company shareholders;
– Representatives of a legal entity (which may be a client or a vendor);
– Staff of service provider and commercial partners.
4. WHY AND ON WHICH BASIS DO WE USE YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into, or have entered into, with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Purposes for which we will use your personal data:
a. We use your personal data to enter into and perform our contracts, including to:
· register you as a new client
· manage your property sale or purchase
· provide you with information regarding our properties and our services; and
· deal with enquiries
b. We use your personal data to fulfil our legitimate interests, including to:
· send you details of properties we think may be of interest to you
· invite you to our events
· to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
c. We use your personal data in order to comply with our legal and regulatory obligations, including to:
· comply with real estate regulations
· prevent money-laundering and financing of terrorism
· comply with relevant legislation relating to sanctions and embargoes
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or have used our services and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at email@example.com.
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In order to fulfill the aforementioned purposes, we only disclose your personal data to:
– Service providers which perform services on our behalf;
– Independent agents, intermediaries or brokers, banking and commercial partners, with which we have regular relationship;
– HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.;
– Certain regulated professionals such as lawyers, notaries or auditors;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We carefully choose which third parties we work with, some of whom may be based outside the European Economic Area (‘EEA’). Any transfers of your personal data outside the EEA take place only subject to appropriate safeguards as provided in data protection law. These safeguards are intended to secure your rights as a data subject with respect to any relevant non-EEA domiciled entities.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to comply with applicable laws and regulations or another period with regard to our operational requirements, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will 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. In certain circumstances you can ask us to delete your data (see section 9 below for further information).
9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. They include:
– To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
– To rectify: where you consider that your personal data that we hold is inaccurate or incomplete you can request that such personal data be modified accordingly.
– To erase: you can require the deletion of your personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
– To restrict: you can request the restriction of the processing of your personal data in specific circumstances.
– To object: you can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
– To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
– To data portability: in certain circumstances you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.
If you wish to exercise the rights listed above, please send a request to the following address: The Country House Department Limited, Pound Court, 14 Pound Street, Newbury, RG14 6AA. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 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
We invite you to review the latest version of this notice online and we will inform you of any material changes through our website or through our other usual communication channels.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
11. HOW TO CONTACT US?