When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
What type of information will we collect from you?
The personal information we collect from you will typically include the following:
• Full name and contact details (including your contact number, email and postal address)
• Information relating to your identity where we are required by law to collect this to comply with the Money Laundering Regulations 2017 and the Immigration Act.
• Information on your close connections where we are required to conduct conflicts of interests under regulatory obligations.
• Your banking details where required such as where you are letting a property or, where renting, to set up an approved tenancy deposit account for you and arrange for rental payments.
• Information on any access requirements you have necessary to enable us to find suitable properties for you, which may consist of special category personal data comprising details of any disability or other health information about you.
• Details about your areas of interest where we wish to send you marketing information about similar products and services.
• Other technical information, including what devices you use to connect to our App, device location data where this function is not disabled by you on your device, [the Internet protocol (IP) address used to connect your computer to the Internet,] [your login information,] [browser type and version,] [time zone setting,] [browser plug-in types and versions,] [operating system and platform]
• Your communications with us, including a record of the email or telephone correspondence created when you contact us as part of a product or service query.
Where we need to collect personal data by law (for example to meet our obligations to prevent fraud and money laundering) or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
On what basis can we process your information?
The legal grounds under the General Data Protection Regulations for processing your personal data are as follows:
It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, for us to provide you with our products and services.
You have given us explicit consent to the processing of your personal data namely to receive electronic marketing by us. You do not need to provide us with marketing consent in order to receive our services.
It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests include processing necessary data to improve and to promote our services and products and to better understand our customers’ interests and knowledge of the property market and to administer the technical aspects of our service and products.
Where we need to comply with a legal obligation; or in rare circumstances:
Where we need to protect your interests (or someone else’s interests); and/or
Where it is needed in the public interest or for official purposes.
What are we going to do with your information?
We will hold and use personal information about you in the following ways:
• To fulfil our obligations to you when providing you with our property services
• To share your information with others where necessary to fulfil our property services for you or where acting as agent for a third party on your behalf
• To comply with our statutory and regulatory obligations, including [verifying your identity, prevention of fraud and money laundering and to assess your credit worthiness
• Communicate with you during the course of providing our services, for example with your enquiries and requests
• Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future
• To provide you, or to enable third parties to provide you, with information about goods or services we feel may interest you, where you have provided permission for us to do so or, if you are an existing customer only, where we choose to contact you by electronic means (including e-mail or SMS) with information about our own goods and services similar to those which you have already obtained from us or negotiated to obtain from us . For those marketing messages you can unsubscribe at any time
• Track your use of our service including your use of our App in order to improve these
• To notify you about changes to our service
• To ensure that content from our site is presented in the most effective manner for you and for your computer
How long we keep your data for
We will retain your personal data for different periods depending on the service you have chosen to use us for, which may be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period or need to retain it in the event of a legal claim or complaint.
Who your information will be shared with
We will pass your details to the following organisations (our “data processors”) who carry out certain activities on our behalf as part of us providing our services. These include, but are not strictly limited to: utility providers, property maintenance contractors, credit reference and fraud prevention agencies, solicitors, cloud computing host providers, technical support service providers.
We will also pass your details where necessary to your property solicitors and those of the other party to your transaction. We will also disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If our company or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will not share your information with third parties for marketing purposes without first obtaining your prior consent.
Security of your data
Your data will be held on secure servers within the European Economic Area ("EEA") with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.
If we have given you a username and password which enables you to access certain parts of your matter on our systems, you are responsible for keeping it confidential. Please do not share it with anyone.
How you can access and update your information
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to Data Protection Officer, Harringtons Services Limited, The Old Timbers, The Square, Wickham, Fareham, PO17 5JG.
How you can request erasure of your data:
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
How you can withdraw your consent
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time by contacting us on 01329 834835, emailing us at email@example.com or in writing to: Data Protection Officer, Harringtons Services Limited, The Old Timbers, The Square, Wickham, Fareham, PO17 5JG.
How you can restrict or object to us using your data
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to firstname.lastname@example.org or in writing to: Data Protection Officer, Harringtons Services Limited, The Old Timbers, The Square, Wickham, Fareham, PO17 5JG.
Moving your information to another organisation
In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information please let us know by email. We will respond to you within one month after assessing whether this is possible, taking into account the technical compatibility with the other organisation in question.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
How to contact us
Our contact details are shown below:
Address: Harringtons, The Old Timbers, The Square, Wickham, Fareham, PO17 5JG
Email address: email@example.com
Telephone: 01329 834835
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