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Leamington Spa | Privacy Policy

BELVOIR LEAMINGTON SPA PRIVACY POLICY - 2018

At Belvoir, Leamington Spa we are committed to protecting and respecting your personal information and privacy.

This policy explains when and why we collect personal information about you, we may change this policy from time to time.

This privacy notice was last amended 17th May 2018.

WHO ARE WE?

We are Torwell Limited trading as BELVOIR, LEAMINGTON SPA, a company registered in England with company number: 04645145

Any questions regarding this Policy and our privacy practices should be sent by email to: leamingtonspa@belvoir.co.uk or by writing to SUE WARBURTON, BELVOIR, 22-23 Denby Buildings, Regent Grove, Leamington Spa, Warwickshire, CV32 4NY

1. WHAT INFORMATION WE MAY COLLECT AND HOW WE USE IT

As a business we collect, use, store and transfer different types of personal data depending on who you are.

If you are purchasing, renting, selling or letting a property through Belvoir or purchasing, renting, selling or letting a property from one of our clients, we collect and use your personal data in order for us to provide you with our services. The personal data we collect and use may include:

• Identity Data (name, marital status, title, date of birth, gender, username and password, purchases made by you, your interests and preferences, feedback and survey responses)
• Contact Data (billing address, delivery address, email address and telephone numbers)
• Financial Data (bank account and payment details)
• Transaction Data (details about payments to and from you and other services you have purchased through us)
• Marketing and Communications Data (your marketing preferences from us and our third parties and your communication preferences)
• To carry out your references and our obligations arising from any contracts entered into you by you or which it is contemplated will be entered into.
• To seek your comments on the services we have provided.
• To notify you of changes to our Agency services.
• To send you communications which you have requested or that may be of interest to you.
• To process your application.
• For administrative and business purposes.
• For advertising and analytical purposes.
• In connection with our legal rights and obligations.
• For certain additional purposes but only with your consent.

WHO HAS ACCESS TO YOUR INFORMATION?

We will not sell or provide your information to third parties other than to information processors with whom we have entered into written contracts which require the information processors to comply in all respects with the requirements of this Privacy Policy and all legal requirements relating to information privacy.

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. You can ask us to rectify or update your personal information at any time by email to leamingtonspa@belvoir.co.uk or by writing to SUE WARBURTON ,BELVOIR, 22-23 DENBY BUILDINGS, REGENT GROVE, LEAMINGTON SPA, WARWICKSHIRE, CV32

2. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• contact us through social media;
• walk-in to our branch offices or telephone
• enter a competition, promotion or survey; or
• give us some feedback.

Third parties or publicly available source

We may receive personal data about you from various third parties and public sources as set out below:

Contact, Financial and Transaction Data from providers of payment services such as Mastercard based inside the EU.
Identity and Contact Data from data brokers or aggregators such as:
• Rightmove based inside the EU
• Zoopla Property Group based inside the EU
• Facebook based outside the EU
• Instagram
• You Tube
• Twitter
• CFP Software
• Vebra
• Fix-Flo (on-line maintenance reporting portal)

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

If you make a payment to us your payment details are not held by us but are collected by our third-party payment processors, who specialise in the secure capture and processing of such transactions.

3. HOW WE USE YOUR PERSONAL DATA

In the table below we summarise the ways that we plan to use your personal data and the purposes for which we will use your personal data. We will only use your personal data for the purposes for which we have collected it. If we need to process your personal data for a different purpose that is not compatible with the original purpose that we collected your personal data, we will let you know.

We may process your personal data for a different purpose and without your consent where it is necessary for us to comply with our legal obligations.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To contact you Identity
Contact Financial Transaction Marketing and Communications
Performance of a contract with you Necessary for our legitimate interests (for running our business, to recover debts due to us, to keep our records updated and to study how customers use our products/services)
To carry out our obligations arising from any contracts entered into between you and us and to provide with you the information, products and services you request from us Identity
Contact Financial Transaction Marketing and Communications
Performance of a contract with you Necessary for our legitimate interests (for running our business and to recover debts due to us)
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To provide you with information about other goods and services that we offer which we feel may interest you Identity
Contact Technical Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)
To permit selected third parties: • to provide you with information about goods or services which we feel may interest you • to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website
Identity Contact Technical Usage
Consent (in relation to SMS and email marketing communications) Necessary for our legitimate interests (to develop our service offering)
To assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website
Identity Contact Financial Transaction Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)
To notify you about changes to our service
Identity Contact
Performance of a contract with you Necessary to comply with our legal obligations Necessary for our legitimate interests (to keep our records updated)
To ensure that content from our website is presented in the most effective manner for you and your computer
Identity Contact Financial Transaction
Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)
To verify your identity
Identity Contact Financial Transaction
Necessary to comply with our legal obligations Necessary for our legitimate interests (for running our business and to prevent fraud and money laundering)
As part of our efforts to keep our site safe and secure and to prevent or detect fraud
Identity Contact Financial Transaction
Necessary to comply with our legal obligations Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
reorganisation or group restructuring exercise)
To provide customer support
To provide maintenance support at your property as and when requested by giving your contact details to relevant contractor
Identity Contact
Performance of a contract with you
Performance of a contract with you
To comply with the requirements imposed by law or any court order
Identity Contact Technical Usage
Necessary to comply with our legal obligations

Marketing

You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. You also have the right to withdraw consent for us to pass your information to third parties for marketing purposes. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.

You can ask us to stop sending you marketing messages at any time by:

• E-mailing: leamingtonspa@belvoir.co.uk or by calling us : 01926 422251
• If you do withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations.

If you no longer wish to be contacted by third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies about how to unsubscribe.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Belvoir, Leamington Spa for marketing purposes.

Cookies

The Belvoir website and applications may automatically collect data about how you use our services in order to help us improve future functionality ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. Cookies collect statistical information about your browsing actions and patterns and do not identify you as an individual. We use cookies to improve our website and provide you with a better, more personal service.

The cookies on the Belvoir website do not track, collect or upload data such as your name, email address or billing information.

You may switch off cookies.

To read more about our use of cookies on the Belvoir website, please consult our cookie policy.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the "Purposes for which we will use your personal data" table above. We have agreements in place with our third parties that restrict their use of your personal data. We only allow third parties to use your personal data for specified purposes and in accordance with our instructions

Category
Explanation
Related Third Parties
THE MORTGAGE ADVICE BUREAU (where you have consented for us to do so).
FRANKLYN FINANCIAL MANAGEMENT (where you have consented for us to do so).
LET ALLIANCE ( for referencing purposes)
ITTRIA ( for the setting up of utilities)
THE TENANT SHOP ( for the setting up of utilities)
VIRGIN MEDIA ( where you have consented for us to do so)
CONTRACTORS ( for the purpose of any relevant maintenance issues)

External Third Parties

Service providers acting as processors based in the United Kingdom who provide IT and system administration services, anti-money laundering service providers, tenancy deposit administrators (such as the Tenancy Deposit Scheme, both Insured & Custodial) and services to enable us to perform our contract with you. Advertisers and advertising networks (including social media) that require the data to select and serve relevant adverts to you. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accountancy services. HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. We will refer your personal information to the following third parties, but only where you have consented for us to do so.

Category
Explanation
If you are a tenant and we are helping you with the administration in moving, we will refer your personal information to either Ittria or Tenant Shop Limited which acts on our behalf to provide these services. These both contact the utilities companies on your behalf at no cost to yourselves. The Tenant Shop Limited or Ittria may contact you about the other services that they provide if you consent for them to do so.
Anti-Money Laundering

Belvoir is committed to operating its business in a transparent and open manner consistent with our legal and regulatory obligations. We are aware that the estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity. We always seek to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to the National Crime Agency.

As part of this commitment, we adopt a strict compliance of all Anti-Money Laundering rules, with specific emphasis on the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010 and the Terrorism Act 2000.

Belvoir policy commitment is applicable to all of our customers, including vendors, buyers, landlords and tenants. As a result we obtain and hold for a period of at least six years evidence pertaining to our customers' identity and, where appropriate, we obtain proof of ownership of property and source/destination of funds. We will be unable to proceed with any work on behalf of our customers if we are unable to obtain this information. Customers' identity will be subject to an electronic identity check, which may also include a credit check.

Belvoir Leamington Spa is registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017.

5. DATA SECURITY

Once we have received your personal data we will use reasonable and necessary procedures and security features to try and prevent unauthorised access. For example, we limit who can access your personal data to those individuals and third parties who need to know it and who are subject to a duty of confidentiality. If we become aware of a data breach we will notify the Information Commissioner's Office. If we believe that the data breach is serious, we may notify you in accordance with our legal requirements.

We dispose of data that is no longer required by shredding with a certificated disposal company who provide us with a certificate of destruction.

6. TRANSFERRING YOUR INFORMATION OUTSIDE OF THE EU

The information which you provide to us may be transferred to countries outside the European Union (“EU”) if any of our servers or our processors’ servers are located in such a country. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.

7. OTHER WEBSITES

Our website may contain links to other websites which we do not own but this privacy policy only applies to our website. We cannot be responsible for the privacy policies and practices of other sites whether or not you access them using links from our website.

8. TELEPHONE AND WEBSITE RECORDING

We may record telephone calls. We may also use web site recording services which may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal information. Information collected in such a fashion is for our internal use only. The information is used to improve our website usability and is stored and used for aggregated and statistical reporting.

9. DATA RETENTION

We hold on to your personal data whilst you use our services (or whilst we provide services connected to you) and for at least six years thereafter, for legal, regulatory and accounting purposes

10. YOUR LEGAL RIGHTS

Under data protection laws you have the right to protect and look after your personal data. You have the right to:

• ask us for the personal data that we hold and process about you (this is commonly known as a data subject access request). You have rights to the following information:

o the purpose(s) for which we are processing your information;
o the categories of personal information we hold about you
o the recipients or categories of recipient to whom the personal data have been or will be disclosed;
o the period for which we will store your information, or the criteria used to determine that period;
• prevent the use of your personal data for marketing purposes by
o informing a Belvoir telephone operator; or
o by ticking the relevant boxes on the data collection forms; or
o by checking or unchecking relevant boxes to adjust your marketing preferences; or
o by emailing: leamingtonspa@belvoir.co.uk

Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions.;

• ask that any inaccurate information we hold about you is corrected;
• ask that we delete the personal data we hold about you in certain situations;
• ask that we stop using your personal data for certain purposes;
• ask that we do not make decisions about you using completely automated means; and/or
• ask that personal data we hold about you is given to you, or where technically feasible a third party chosen by you, in a commonly used, machine-readable format.

The rights listed above may apply in certain circumstances, and so we may not always be able to comply with your request to exercise these rights. We will usually respond to a request from you to exercise your rights within 1 month of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests. Please be aware that we may need to process your personal data and/or request specific information from you to help us comply with your request. You will not usually have to pay a fee to exercise these rights, but we reserve the right to if your request is clearly unfounded, repetitive or excessive, alternatively we may refuse to comply with your request.

OUR PREMISES

We have alarms at our premises.

UNDER 18?

We are especially concerned to protect the privacy of children. If you are under 18 years of age, please ask your parent/guardians permission before providing any personal information and ask them to help you whenever you provide us with any personal information.

Complaints and Feedback

If you would like to speak to us about how we handle your personal data, please contact SUE WARBURTON in the first instance at leamingtonspa@belvoir.co.uk.

You can also complain to the Information Commissioner's Office who is the UK supervisory authority for data protection issues.