Privacy Policy

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you – this is called the right of subject access.  You can exercise this right (or any of the other rights described below) by sending our Data Compliance manager a written request at any time. Please mark your letter “Data Subject Request” and send it to our Data Compliance Manager (see the section on Our Data Compliance Manager for contact details).

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
• have inaccurate personal data corrected, blocked or erased
• object to decisions being made about you by automated means
• object to our using your personal data in ways that are likely to cause you damage or distress
• restrict our use of your personal data
• require that we delete your personal data
• require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making and profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

• the business partners, suppliers and sub-contractors we work with to enable your property purchase and to assist in dealing with any snagging issues following your purchase:
  • legal service providers who assist us in relation to your conveyance
  • accountancy service providers who advise us in relation to the general management and administration of our business
  • building contractors and New Homes Customer Care who may deal with snagging issues
  • our building warranty provider, Premier Guarantee and NHBC
  • utility service providers who provide essential utilities and services to your property, including British Gas, Anglian Water and Affinity Water.
  • NPA24:7, who provide 24 hour emergency assistance to customers who have purchased one of our properties.
  • Our managing agents, RMG UK.
  • financial service providers who administer agreements on our behalf e.g. loan providers
  • Business information / management and IT support providers who keep our internal systems and networks running smoothly
  • analytics and search engine providers that assist us in the improvement and optimisation of our site
  • The Council of the area in which you have purchased a property
  • HM Revenue & Customs
  • Other Governmental, public sector or regulatory bodies as required.

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. We process your personal data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

• we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of useand other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure.  The security measures we take include:

• only storing your personal data on our secure servers
• using appropriate encryption techniques including file encryption, point to point encryption and SSL and TLS
• keeping paper records to a minimum and ensuring that they are stored in a locked office with restricted access.
• maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
• ensuring a strict policy is in place regarding the use of mobile devices and out of office working
• limiting access to data on a need to know basis

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about, or buy, one of our properties and have not opted-out of receiving our marketing communications
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our properties
• you have specifically asked to receive marketing communications

We may send you marketing communications by email, telephone, automated calls, text message and post.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about particular types of properties or developments in specific locations or you may ask us not to send you any marketing communications at all.

You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

You can opt out of receiving our marketing communications at any time by following the unsubscribe instructions you will find in each marketing communication or by contacting us at any time using the details in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

We do not transfer your personal data to any organisations outside of the European Economic Area. If this should change (for example, because we instruct sub – contractors who are based outside of the EEA or we switch systems or service providers to an organisation which is based outside of the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely by that organisation and in accordance with this privacy policy and all relevant data protection legislation. In such circumstances, we will also update this Privacy Policy to include details of the organisation, where they are based, and the safeguards we have put in place.

How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Please note that we may anonymise your personal data or use it for statistical purposes.   We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

If you have any questions about our data retention practices please contact data compliance manager (see the section on Our data compliance manager for contact details).

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact our data compliance manager to discuss this using the contact details set out in the Who we are and how you can contact us section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk.  Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website, or you can contact us (using the details set out in the Who we are and how you can contact us section of this policy) to request a copy of the latest version.

Each time we update out policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

This is policy version 003 which came into effect in February 2019