For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is tlc REAL Estate Services Ltd, company number 7524071, registered in England. Our registered office is at 8 Hogarth Place, Earls Court, London SW5 0QT.
We are registered with the Information Commissioner’s Office.
We are committed to ensuring that your privacy is protected and will treat all information held about you in accordance with this policy. We understand that all users of our website are quite rightly concerned to know that their data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party. Our policy is both specific and strict. It complies with UK law. If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately. Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected at this site.
This Privacy Notice explains:
What personal information is and the types of personal information we collect. It describes how we use your personal information and the legal basis for processing your information. It also covers the length of time we will hold your personal information and your rights in relation to the information we hold.
If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
What actually is personal information?
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.
What personal information do we collect?
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 rental payments
- Details about your areas of interest where we wish to send you marketing information about similar products and services
- 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
- 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.
How do we process your personal information and on what basis?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. The legal grounds under data protection legislation for processing your personal data are as follows:
- For Employment-related issues and contracts
- 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 for one or more specific purposes, namely 1) where you have given us consent to receive electronic marketing by us and/or 2) to process your Special Category Personal Data described above. 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
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 we are acting as agents 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. You can opt out at any time from receiving these marketing messages
- 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 do we keep your information secure?
We take the security of your information very seriously and all our information is secured on our protected server and Management Systems. All terminals are password protected and access is restricted.
All unnecessary physical paperwork is shredded and removed. All necessary paperwork is kept in lockable cabinets.
All our data is hosted in data centres which have processes and systems in place to protect against both unauthorised access and other external factors that could cause damage to your personal data.
We provide training to all our Staff so that they are informed of the protocols tlc REAL Estate Services Ltd takes and can ensure the utmost security of your personal information.
How long do we retain your personal information?
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.
We keep information which forms part of our business records for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it.
Where we have used your personal information to contact you for marketing communications we will contact you periodically to ensure you are happy to continue receiving communications from us. If you tell us that you no longer wish to receive marketing communications from us, we will amend your details accordingly.
Do we share your information?
We do not sell or exchange your information. We will, however, pass your information onto third parties if they require the information to complete a role required of us by you such as credit checks, solicitors for property purchases, inventory companies to meet you at the property, contractors to meet you at the property to name a few examples.
We will not pass on your details without your consent.
Overseas transfers of your personal information
We, as a basis, will not transfer, store, or process your personal information in locations outside the UK and the European Economic Area (EEA). It may be on occasion that a third party with whom we work has servers outside the UK and EEA and if this is the case we will prepare a contract with the receiver to ensure that they protect your data to the same standards we do.
Do I have access to my personal information you hold?
At any time, you may review or update the personally identifiable information that we hold about you, by contacting us at the address at the head of this notice. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information. You have certain rights in respect of the management of the personal data we hold about you. You can exercise any of these rights by contacting us. The easiest way to get in touch is by emailing us at email@example.com.
Right of Access
You are entitled to receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information. You also have the right to access your personal information which we are handling.
The Right of Rectification
You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.
The Right to Data Portability
You have the right to receive the personal information we hold about you in a structured, standard machine-readable format and to send this to another organisation controlling your personal information.
The Right of Erasure
You have the right to require us to erase your personal information which we are handling in the following circumstances:
- We no longer need to use your personal information for the reasons we told you we collected it for.
- Where we needed your consent to use your personal information and you have withdrawn your consent.
- You object to our use of your personal information and we have no compelling reason to carry on handling your personal information.
- Our handling of your personal information has broken the law.
- We must erase your personal information to comply with a law we are subject to.
Your Right to Object
You have the right to object to us handling your personal information when:
- We are handling your personal information based on our legitimate interests (as described in section 2). If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue for marketing purposes. If you ask us to stop handling your personal information on this basis, we will stop.
Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
What happens if I have a complaint or have a question?
If you have any complaints about the way we use your personal information please contact the Data Protection Officer at firstname.lastname@example.org who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).