We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the UK) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2) About us
28 Stafford Street Edinburgh
Tel: 0131 240 1330
We are registered as a controller with the ICO under registration number: ZA399320.
3) Types of personal information we collect
If you are interested in one of our properties or if you have bought one of our properties, we may collect and use the following personal information about you:
- full name and contact details (including home address, email and phone number)
- information about the property you have bought, or information about what type of property you are interested in
- information about how your use our websites
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
Where you are a business contact (for example, if you work for one of our suppliers or contractors, or if you work in our industry), we may collect and use your full name and professional contact details (including professional email address and contact number).
If you are looking to apply for a job with us, we may collect and use the following personal information about you:
- your full name and contact details (including home address, email and phone number)
- information contained in your CV and covering letter, or from an application form
- information from any references that are given about you
This personal information is required to process your application to work with us. If you do not provide personal information we ask for, we may not be able to process your application or invite you to an interview or offer you a position.
4) How your personal information is collected
We collect personal information directly from you, whether via our sales agent, from a completed application form, in the delivery or receipt of services, via our website, or via our Facebook page.
We may also collect personal information from cookies on our website (more information is set out in section 10 below).
5) How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- for the performance of our contract with you or to take steps at your request before entering into a contract (such as arranging your first appointment);
- to comply with our legal and/or regulatory obligations;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
If you are interested in one of our properties, we will need to collect personal information from you in order to take steps necessary to acknowledge your interest and provide you with any further information you may have requested from us, and to ultimately enter into a contract with you for the property.
We process the personal information of our business contacts for the day-to-day running of our business, which it is in our legitimate interests to do.
Where you are applying for a job with us, we need to collect certain information from you in order to take steps with a view to entering into an employment contract with you. It is also in our legitimate interests to collect information about candidates to help us make our decision and to help us ensure that you are suitably qualified for a particular role. If you accept a role with us and become one of our employees, you will be provided with further information about how we use your personal information as your employer.
6) Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our services, e.g. our sales agents, our sub-contractors, suppliers and our IT and digital service providers, such as our supplier who hosts this website and data collected from it on our behalf, and Dropbox which we use to store certain information;
- our professional services advisers (such as lawyers, accountants and auditors)
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7) How long your personal information will be kept
We will keep your personal information for as long as is necessary:
- to respond to any enquiries, questions, complaints or claims made by you or on your behalf
- to show that we treated you fairly
- as required by law.
Generally, we retain customer records for up to 10 years after completion of our contract with you, in case there is a claim under your Premier Guarantee policy.
We will not retain personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Please note that different retention periods apply to different types of personal information held. Further details on this are available on request.
8) Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g. we use Dropbox for storing certain information on their servers which are located outside the EEA.
These transfers are subject to special rules under European and UK data protection law, because non- EEA countries do not have the same data protection laws as the UK and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. In respect of our use of Dropbox, Dropbox are certified under the EU-US Privacy Shield mechanism which ensures that they put adequate measures in place to protect personal information. You can find out more about the security measures Dropbox use to protect personal information here.
If you would like further information please contact us (see ‘About us’ above).
9) Cookies and Tracking
- recognise you whenever you visit our website (this speeds up your access to the website as you do not have to log in each time);
- obtain information about your preferences, online movements and use of the internet;
- carry out research and statistical analysis to help improve our content; and
- make your online experience more efficient and enjoyable.
We use the following categories of cookies on our website:
- Strictly necessary: These cookies are essential for certain features of our websites to work (for example, making payments online). These cookies do not record personally identifiable personal information and we do not need your consent to place these cookies on your device. Without these cookies some services on our website cannot be provided and certain parts of our website cannot be accessed.
- Performance: These cookies are used to collect anonymous information about how you use our website. This information is used to help us improve our website and understand how effective our website is. In some cases we use trusted third parties to collect this information for us but they only use the information for the purposes explained.
- Functionality: These cookies are used to provide services or remember settings to enhance your visit, for example by remembering your text size preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.
- Targeting and Advertising: These cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and does not contain personal information. To find out more about cookies used for targeting and advertising follow www.youronlinechoices.com and www.networkadvertising.org or contact us for further information about the trusted third parties we use.
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. For further information about cookies and how to disable them please go to the ICO’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
10) Your Privacy Rights
Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us in writing.
- Access: you may request access to a copy of your personal information.
- Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
- Rectification: you may ask us to rectify any inaccurate information we hold about you.
- Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
- Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
- Object: you may object to our processing of your personal information.
- Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a complaint to the ICO by visiting their website at https://ico.org.uk/concerns/ or on 0303 123 1113.
11) Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.