1.Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Andrew Grant Sales Ltd & Andrew Grants Lettings Ltd
Email address: firstname.lastname@example.org
Postal address: Cupola Court, Spetchley Park Estate, Worcester WR5 1RS
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.
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.
2.The data we collect 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 we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, nationality, tax status and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account, tax URN number and income/expenditure details where we manage a financial transaction for you, set up and standing order and payment card details, mortgage or insurance, licensing documentation and service contracts, proof of funds and evidence of source of funds.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Property Information includes details relating to your property including photographs, floor plans, energy performance certificate ratings/home reports, property description and survey results when you engage us to market a property for you. Photographs of your property when we market your property for sale or to let, prepare an inspection report on the condition of your property, or when we prepare an inventory to record the condition of your property at the start or end of a tenancy. Your contact details, move in and move out date, utility meter serial number and meter readings where you are a landlord or tenant, prior to a tenant moving in to a property and when the tenant moves out. Your move in and move out date and details of the deposit you have paid where you are a tenant when registering or releasing any deposit from a deposit protection scheme. Your client reference number and the balance of any debt which you owe if we are required to take steps to collect a debt or take possession of a property; and references relating to you, or information required to prepare a reference for you where you are a tenant.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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. If you fail to provide personal data
Where we need to collect personal data by law, 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3.How is your personal data collected?
The majority of the personal information which we collect will have been voluntarily provided by you, however we may also obtain your personal data from other sources including:
- Our Estate Agents;
- Third parties including credit reference agencies, law enforcement/regulatory bodies, companies providing commercially available databases, social networks (such as Facebook), introducer companies who have referred you to us for the delivery of services, your employer, your solicitor, trustees or your attorney;
- Online property portals; and
- Other publicly available sources such as the electoral roll and HM Land Registry.
4.How 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:
helping you to sell your property, or to find a property to purchase;
- valuing your property; and
- letting services;
- conveyancing services;
- referring you to our mortgage and insurance partners; and
- progressing any mortgage and/or insurance transaction you may have commenced using our services.
- To fulfil our legal obligations to ensure Identity checks and Anti-Money Laundering checks are undertaken;
- To complete other property or personal checks required to progress the transaction for which you have engaged our services;
- To protect a tenant’s deposit by registering it with a deposit protection scheme;
- To take payment from you for the services which we provide;
- To arrange and carry out viewings;
- To process the receipt and payment of rent, maintenance and tax for you if a property is being let;
- To arrange an energy performance certificate or home report inspection for you;
- To arrange an inventory check or to prepare a report on the condition of a property if it is being let;
- To ensure that utilities are in place and that utility companies and local authorities are able to contact you for billing purposes when you move in to a property;
- To carry out tenant referencing and credit checks to assess if you are creditworthy before you move in to a property. To carry out such checks, your personal information may be shared with credit referencing companies;
- To better understand your requirements and provide you with services specific to your needs;
- To improve the services we and Our Estate Agents offer by analysing your personal information so we better understand how you use our services;
- To keep client records up to date;
Marketing of Our Services to You:
- To provide you with general updates in relation to the property market, in accordance with your preferences;
- To provide you with information which we reasonably believe may be relevant to you based on the services we are providing to you or to whom we can introduce you to including conveyancing and financial services products;
- To carry out targeted advertising to you on social media websites such as Facebook where you have already shown an interest in our services. This is done through analysing information we collect about your interactions on Our Site and making this available to social media networks;
- We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing);
- You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing;
- We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Responding to Your queries:
- To help answer any questions which you have asked one of our agents or staff members;
- To provide you with a quote for our services;
Improving our site:
- To analyse cookie and website usage data to keep improving Our Site;
- To allow us to customise the content which is presented to you based on your likely interests;
Legal and Regulatory Obligations:
- To transfer information to any entity which may acquire rights in us;
- To collect a debt which is owed to us; and
- For onward referencing where you are a tenant; and
- To carry out anti-money laundering checks;
- To transfer information to any entity which may acquire rights in us;
- To collect a debt which is owed to us; and
- For onward referencing where you are a tenant; and
- Retention of copyright in all advertising material (including photographs) used to market your property including reserving the right to use these for marketing initiatives following the sale of the property.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of contract entered into or other transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 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.
5. Disclosures of your personal data
The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff or Our Estate Agents for the purposes set out in this Privacy Notice or for other purposes approved by you. We may also provide your personal information to other companies or Our Estate Agents for the purposes of administering our business or where services are provided another company or across Our Estate Agents under our franchise agreements.
We may also disclose your information to the third parties listed below for the following purposes:
- Service providers who need to know the information in order to provide us or you with a product or service including our approved contractors for the purpose of carrying out maintenance or gas safety checks at your property, surveyors where you or your mortgage provider require a homebuyers or structural survey to be carried out, your conveyancer, mortgage or insurance adviser;
- Our panel of conveyancing firms if you ask us to arrange conveyancing services for you;
- Law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation or court order including the police, HMRC and local authorities;
- Auction houses where the property you are buying or selling is being sold by auction;
- Third parties we work with as part of providing our services and their associated companies and sub-contractors, including (but not limited to) IT administrators, inventory clerks, photographers, utility companies, marketing and transactional communication companies, energy performance certificate companies, companies that facilitate electronic signature of documents and relocation agents;
- Referencing companies to check your creditworthiness and to help prevent fraud and money laundering, the check will leave a soft ID footprint on your credit file which should not affect your credit rating;
- Social media networks such as Facebook for marketing purposes as explained in the ‘use of the information we collect’ section of this Privacy Notice;
- Debt collection companies to assist us in collecting any monies which you owe to us where payment is overdue;
- Our professional advisers, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- Third parties as necessary in the event of a claim or dispute relating to the use of our services;
If we are providing you with letting services we may share your personal information with:
- the landlord, tenant or their guarantor to comply with our legal obligations, including our obligation to keep the landlord fully informed where we manage a property on their behalf and to allow you to contact each other directly in circumstances where the landlord is managing the property;
- Tenancy Deposits Scheme for the purpose of providing a tenancy deposit protection scheme;
- NAEA Propertymark a professional body responsible for raising professional standards amongst letting agents, where information relating to you is requested by them in order to protect your interests; and
- The Property Ombudsman scheme where they are providing an alternative dispute resolution service in connection with the letting services which we are providing.
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
We do not transfer your personal data outside the European Economic Area (EEA).
6. 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.
7. Data retentiony
How long will you use my 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 for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information in the following limited circumstances:
- Where it is no longer needed for the purposes for which it was collected; or
- Where you have withdrawn your consent (where the data processing was based on consent); or
- Following a successful right to object; or
- Where it has been processed unlawfully; or
- To comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- For compliance with a legal obligation; or
- For the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict the processing of your personal information, but only where:
- Its accuracy is contested, to allow us to verify its accuracy; or
- The processing is unlawful, but you do not want it erased; or
- It is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
- You have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction:
- Where we have your consent; or
- To establish, exercise or defend legal claims; or
- To protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes. You can request that we do not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.