PRIVACY POLICY
Cavendish Rentals Limited (hereafter
“Cavendish Rentals”, “We”, “Us”) – aim to provide our customers and clients
with the best possible safe and secure service. We are committed to protecting
and respecting your privacy. We use the personal information you share with us
to tailor our services to your requirements, and to provide the best possible
user experience on our website www.cavendishrentals.co.uk (hereafter “Website”)
or via self-service portal such as docs.cavendishservices.uk, salesandlettings.online, (hereafter
“Self-Service Portals”). By using our Website or
Self-Service Portals you are deemed to have accepted our Terms of Use; please
ensure you have read this document available here.
The purpose of this privacy policy (hereafter
“Policy”) is to give you a clear explanation about how Cavendish Rentals use,
store, share and control the personal and behavioural information you provide
(or that we collect from you) when you contact us or otherwise engage with us
via our Website or other media. This can be done in a
variety of different ways which can include but are not exclusively limited to:-
in person via our office,
by telephone,
by email,
by post,
by means of social media such as
Facebook, Twitter, LinkedIn
via Google and other search engine
listings,
via our Website,
via third party websites (if
appropriate),
via property portals such as
www.rightmove.co.uk (hereafter “Portals”),
And, if adopted, by SMS, WhatsApp, Facebook
Messenger, live web chat
These are collectively known as our
“Communication Channels”.
By engaging the services of Cavendish
Rentals, by visiting our Website or using the
Self-Service Portals you are accepting and consenting to the practices
described in this Policy.
For the purpose of the Data Protection Act 1998 (the Act)
and the General Data Protection Regulation (GDPR), the Data Controller is
Cavendish Rentals Limited, Office 7, Unit 1 Stephen Gray Road, Mold, CH7 1HE. Registration
number Z895514X.
PERSONAL INFORMATION WE COLLECT FROM
YOU
“Personal information” is any
information that relates to you and identifies you personally, either alone or
in combination with other information available to us.
We may collect and process the
following personal information about you:
Information that you provide by:-
a. filling in forms on our Websites or Self-Service Portals, third party websites and
Portals which send information to us,
b. in person via our office,
c. via telephone calls, emails, SMS,
WhatsApp, Facebook Messenger, live web chat, and social media.
This information can include, but is
not limited to, personal information (name, address, email address and
telephone number); financial information or employment information that you
disclose when agreeing to register as an applicant or enter into
a transactional relationship with us.
Information required to help us ensure
our staff are safe when attending external appointments such as viewings and
market appraisals; for example, contact details for the client or customer,
including a residential address in the UK.
Information required to comply with
legislation such as Right to Rent checks required under Section 22 of the
Immigration Act 2014.
Information to enable us to tailor our
marketing and communications to you, based on your personal preferences, such
as the types of service you are looking for, the location of your search area,
the budget you are willing to spend etc. (hereafter “Criteria”).
If you contact us, we may keep a record
of that correspondence and ask for information if you report an issue with our
services, or with a property you are renting.
We may also ask you to complete
surveys, either on our own Website or Self-Service Portals, by mail or through a
third-party provider, which we use for research and marketing purposes; although you do not have to respond to them.
When you visit or otherwise access our
Website or Self-Service Portals, details including but not limited to:-
a. information about the device and
browser (hereafter “Device”) you are using to access the Website or
Self-Service Portals e.g. type, version, operating
system, etc.,
b. traffic data including the URL of
the website that referred you to our Website or
Self-Service Portals portal if applicable,
c. location data including geolocation
(this can be explicitly controlled in your Device),
d. weblogs and other communication
data,
e. the resources that you access
including social media interaction,
f. your IP (Internet Protocol) address,
g. the date and time of the visit and
how long you remained on our Website or Self-Service
Portals,
h. the pages visited on our Website or Self-Service Portals and interactions performed,
You consent to any information
concerning you which we collect and process being
used, stored and processed in accordance with this Policy.
COOKIES
Cookies are small, often encrypted text
files, located in browser directories. They are used by web developers to help
users navigate their websites efficiently and perform certain functions.
Our Website and Self-Service Portals
use a number of cookies to enhance the visitor
experience. Continued use of our Website or
Self-Service Portals implies consent to cookies being stored on your computer.
Cookies used by our Website
are listed below -
· First Party Cookies: These are specific
to and created by our Website or Self-Service Portals.
In all cases these cookies do not store information of a personal or sensitive
nature, or anything that makes you identifiable to us.
· Session ID: Our web server may create a
session cookie which is essential to distinguish you from other users whilst on
our Website Self-Service Portals. This will expire once you leave the site.
· Analytics: Our Website uses Google
Analytics to understand how users find and use our Website,
to monitor visitor behaviour and to help us to update and improve the Website.
Google Analytics creates a number of cookies which we
do not deem privacy intrusive.
· WordPress: Our Website uses WordPress
as a back-end Content Management System. WordPress uses Cookies to further
enhance the experience of the Website for our users, which we do not deem
privacy intrusive. If you have any concerns, you can read more about the
cookies WordPress uses here – https://codex.wordpress.org/WordPress_Cookies
· MailChimp: The email address that you submit
will not be stored within our Website but will remain
within MailChimp’s database. The data may
be used for email marketing.
· Third Party Cookies: These are created
by an external service when you visit our Website or
Self-Service Portals. The data held can only be seen and managed by the third
party and not by us. We do not have control over these cookies, only how they
are integrated into the Website.
· Google Maps: Our Website uses embedded
Google Maps to assist our customers in locating us and properties for sale.
Google Maps creates a number of cookies which we do
not deem privacy intrusive.
· Social Media: Our Website may use a
range of widely used third party social media plugins (such as from Facebook,
Twitter and LinkedIn) to assist in the marketing of our Website
and business. These plugins may insert cookies over which we have no direct control.
If you have any concerns over this please refer to the
cookie and privacy policies of the individual third parties concerned.
Information about cookies, how you can
delete existing cookies off your hard drive and choose to block new cookies
from our Website can be found by visiting
http://www.allaboutcookies.org
Should you choose to block cookies,
then some features on our Website might not work as
expected.
LINKS TO OTHER WEBSITES
Our Website or
Self-Service Portals may contain links to enable you to visit other websites of
interest easily. However, once you have used these links to leave our site, you
should note that we do not have any control over that other website. Therefore,
we cannot be responsible for the protection and privacy of any information
which you provide whilst visiting such sites and such sites are not governed by
this policy. You should exercise caution and look at the privacy statement
applicable to the website in question.
DOWNLOADS AND MEDIA
Any downloadable documents, files,
images, video files etc. on our Website or
Self-Service Portals are provided to you at your own risk. We take all
reasonable precautions to ensure that such files are free of viruses, but we
recommend that you use anti-virus software as a precaution. We accept no
responsibility for downloads and media provided by external third-party
websites.
HOW WE USE YOUR PERSONAL INFORMATION
· The personal information we collect
when you first contact us will be used for identification and authentication
purposes in addition to creating a profile for you with the information needed
to provide you with our relevant products or services. We use and analyse this
personal information where necessary for the following purposes detailed below:
· Improving our products and services: we
will use your personal information to build a profile on you in order to
understand your requirements, to improve our Website
or Self-Service Portals, as well as to personalise the properties and services
we offer you. We process your personal information in this way as it is
necessary for the purposes of our legitimate interests in providing better
products and services for you and our other customers.
· Processing your transaction: we use
relevant personal information described above (including your name, address and financial details) to enable us to complete a
transaction with you, such as renting and/or letting a property through us.
This information may be required to be passed on to directly associated
companies ( Cavendish Ikin t/a Cavendish Residential,
Cavendish Estate Agents Limited and/or Cavendish Services (UK) Limited,
hereafter “Directly Associated Company/Companies”), third parties, including
insurance providers, utility companies, local authorities, etc.
· Preventing fraud: we will also use your
personal information to assess your creditworthiness (in the case of renting a
property) and to prevent fraud. For this purpose, we may need to share your
personal information with, but not limited to, referencing providers (see “how
we share your personal information” below). This is necessary for the purposes
of our legitimate interests in ensuring we are not the victim of fraud and to
protect our legal rights.
· To provide customer support: if you
contact our team (or vice versa), we will use personal information such as your
email address, phone number and residential address as well as your contact
history to process your request and provide you with the best service possible.
We will process your personal information in this way if it is necessary for
the performance of a contract or if it is required for us to comply with any
legal obligations. If it is not necessary to process your personal data for
either of these reasons, we will process it as it is necessary for the purposes
of our legitimate interests in ensuring we can provide the best service
possible.
· Marketing: when you sign up to receive
our newsletters (if appropriate), register as an applicant, enter into a
transaction with us, provide feedback on our service online or use our Website or Self-Service Portals; we will use your personal
information to create a profile based on the information we hold about you.
This is necessary for the purposes of our legitimate interests in ensuring we
have accurate information about you in one place. We create your profile in
accordance with your preferences in order to provide
you with the best personalised experience, to send you personalised marketing
messages and newsletters and for opinion research purposes. Below you can find
a more detailed description of the ways in which we will use your personal
information for these purposes.
· Website user experience: We may show
personalised content based upon your previous interactions with the Website.
· Self-Service Portals: if you use your
Self-Service Portal account (hereafter “Account”) we may alter the way the
portal works to improve and/or enhance the information displayed to you, or to
optimise the way you interact with the portal. We may show personalised content
based upon your previous interactions with the portal.
What kind of information
The way you interact with us across all
the different channels described above (e.g. our
Website, Self-Service Portals, social media and marketing messages we send you)
and the information we collect in that regard from each of these channels
provides us valuable information about your current circumstances and
preferences. This insight gives us the opportunity to offer you the best
customer service experience possible. To learn about you and your interests, we
may analyse your interactions with us using various kinds of information, as
set out above. If you have given us your consent to send you
marketing communications or if we are permitted by law to send such
communications without obtaining your consent, we use the information that you
have provided to us when interacting with us for sending you personalised
marketing messages about our products or services, events
and promotions. In some instances, we will also aggregate your personal
information with that of other individuals, to create comprehensive reports
about how clients and customers use our products and services. This is
necessary for the purposes of our legitimate interests in analysing our brand
and determining how to improve our services.
What kind of channels (if appropriate)
We will send direct marketing
communications to you via the channel you choose such as post, email, phone,
SMS, or social media. We ask for your consent, where required by applicable
law, in order to use the contact details you have
provided to us to send our personalised marketing communications.
What kind of messages
The messages we will send you will be
personalised and tailored to your individual preferences and requirements. We
use analytics in order to generate such personalised
messages. These analytics will process your personal information and place you
in marketing segments, which determine the content of the messages and the
offers you will receive from us. These direct marketing messages may contain
information about our products and services, events or promotions and other
company (or Directly Associated Company/Companies) news. We personalise these
messages on the basis of that it is necessary for the
purposes of our legitimate interests in ensuring that we provide the most
appropriate information. We may, in certain circumstances, also use the
channels for opinion research (such as to ask if you would like to participate
in a survey) and to learn about your experience and improve your experience
with Cavendish Rentals, including by sending you personalised messages.
Analysing our business
We will use your personal information
(including by anonymising and aggregating it with other customers’ personal
information) for lettings and financial analysis purposes, to determine how
Cavendish Rentals is performing and where improvements can be made. This is
necessary for the purposes of our legitimate interests in understanding how our
business is performing, and considering how to improve
our performance.
We will ask for your consent if we wish
to use your personal information for purposes other than those listed in this
privacy statement and as required to do so under applicable law. We will not
use your personal information for other purposes before we have received such
consent.
HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with
care and confidentiality and do not share it with third parties other than as
set out below.
With Service Providers
Where required we may share limited
personal information you provide when you register with us or enter in to a transaction with us, as necessary and only for the
purposes and on the lawful grounds described above with various third parties
who process your personal information on our behalf (Data Processors), such as;
· Third Parties with a legitimate
interest in the renting/letting transaction: Including but not limited to
tenant referencing agencies, other letting agents, property management
companies, housing associations or landlords, contractors and property
maintenance services, gas and electrical contractors, utility companies and
insurance providers.
· Software and system providers including
but not limited to: Microsoft Corporation, MRI Sales & Lettings, Infor
(United Kingdom) Limited t/a Pegasus Software.
· Website Hosts and analytics platform
providers including but limited to: Google Analytics, Google AdWords
Remarketing & the Google Display Network.
We require that these service providers
and other third parties adhere to strict rules when processing your personal
information, including to only use your personal information in accordance with
our specific instructions (such as for the purposes of completing referencing
or contacting you to arrange access to carry out necessary repairs) and the
applicable laws.
With Legal and Law Enforcement
Cavendish Rentals will disclose
personal information where required by law or legal process, for the
administration of justice, to protect your vital interest, for investigations
by law enforcement to protect and defend Cavendish Rentals property and legal
rights, to protect the personal safety of our Website
or Self-Service Portals users or by order of a valid injunction from a court or
law enforcement agency. Personal information will also be disclosed
to statutory or regulatory bodies, such as but not limited to, RentSmartWales (for properties within Wales) or any
other mandatory registration/licensing authority.
In Relation to Business Interests
In the event that we sell or buy any business or assets,
we may disclose your personal data to the prospective seller or buyer of such
business or assets.
If Cavendish Rentals is or all of its assets are acquired by a third party, personal
data held by us about our customers will be one of the transferred assets.
PERSONAL INFORMATION OF OTHERS
Before you disclose to us the personal
information of another person, you must obtain that person’s consent to both
the disclosure and the processing of that personal information in accordance
with the terms of this privacy policy.
HOW LONG DO WE STORE YOUR INFORMATION
FOR?
The length of time we hold your
information for will vary dependent on lawful basis for collecting and
processing the data.
Cavendish Rentals will hold data
supplied with consent, where there is a legitimate interest in doing so (such
as where a client or customer has registered with us, expressing an interest in
letting or renting a property through us) for a period of two years.
Where a transaction has been entered in
to and there is a contractual necessity to do so, or where there is a
requirement to comply with legal obligations (for example in
order to comply with the requirement of the TPO Codes of Practice, to
maintain clear and full written records of transactions for a period of six
years.
If you have an Account on our
Self-Service Portals and it has been deemed dormant then we may delete the
Account and all personal information “tied to” or “held against” it. We consider
an Account to be dormant if one of the following conditions is met:
· it has not been accessed by you for
more than two years,
· if you have not responded to any emails
sent to the registered email address,
· if we receive email delivery failure
notifications in response to any email sent to the registered email address,
· the Account is in breach of our
Terms of Use.
STORAGE
All digital information you provide to
us is stored in the UK on our secure (password and firewall protected) servers
and all paper-based information is also securely stored in the UK. Any Website
data collated into an email is sent over the Simple Mail Transfer Protocol
(SMTP). Our SMTP servers are protected by TLS (sometimes known
as SSL) meaning that the email content is encrypted using SHA-2, 256-bit
cryptography before being sent across the internet. The email
content is then decrypted by our local computers and devices. Unfortunately,
the transmission of information via the internet is not completely secure and
so we cannot guarantee the security of any data sent over the internet between
your Device and our Website. Any such data transmission is at your own risk.
Once we have received your information,
we will use strict procedures and security features to try to prevent
unauthorised access, as part of our secure backups and data disaster recovery
procedures.
The data that we collect from you may
be transferred to, and stored at, a destination outside the European Economic
Area (“EEA”). It may also be processed by staff operating outside the EEA who
work for us or for one of our suppliers or contractors. Territories outside of
the EEA may not have equivalent legal protections to those that apply within
the EEA but we are under a duty to make sure that our
suppliers and contractors located outside of the EEA continue to take all steps
reasonably necessary to ensure that your data is treated securely and in
accordance with this Policy.
By submitting your personal data to us,
you agree to this transfer, storing or processing.
YOUR RIGHTS
You have the right to ask us not to
process your personal data for marketing purposes, to alter your preferences
for the type of marketing content you receive (such as properties for sale,
information about related services etc.) or to alter the methods via which you
receive marketing correspondence from us (i.e. via
email, text, SMS, post or phone call). We will inform you (before collecting
your data) if we intend to use your data for such purposes or if we intend to
disclose your information to any third party for such purposes.
You can also exercise the right to
prevent such processing of your data at any time by contacting us at
informationrequest@cavmail.co.uk.
ACCESS TO, DELETION, AND CORRECTION OF
PERSONAL INFORMATION
You may contact us
and we will be able to update your records on our data management systems –
please let us know if the personal information which we hold about you needs to
be corrected or updated.
If you would like to know what personal
information Cavendish Rentals holds about you, you may make a request to
Cavendish Rentals for copies of this information. You should be aware that we
will need to see proof of identity before processing any such request (known as
a ‘subject access request’). Should your request be manifestly
unfounded or excessive, a charge will be made of £30.00 (Inclusive of VAT) for
the administrative costs of complying with the request. Further
copies of the data held will incur a fee based on the administrative costs of
providing such copies.
If requested, Cavendish Rentals will
use reasonable efforts to supply, correct or delete information about you on
file.
All subject access requests should be
made in writing and addressed to for attention of The Data Controller,
Cavendish Rentals Limited, Office 7, Unit 1 Stephen Gray Road, Mold, CH7 1HE.
In addition, you may write to us at any
time requesting amendments to certain personal information that you consider to
be incorrect or irrelevant or to request that we block, erase
or otherwise remove your personal information (The Right to Erasure/The Right
to be Forgotten).
You may also write to us at any time to
object to our use of your personal information or request that we provide your
personal information in a usable electronic format and transmit to a third
party (Right to Data Portability). We will comply with these requests in
relation to your personal information in line with applicable law.
PERSONAL DATA BREACHES
In order to comply with applicable law, Cavendish
Rentals has implemented procedures to detect, report and investigate personal
data breaches.
A data breach is defined by the
Information Commissioner’s Office (ICO) as;
“A breach of security leading to the
destruction, loss, alteration, unauthorised disclosure or, or access to,
personal data.”
The ICO will be informed of all data
breaches which present a high risk to our clients and customer’s rights and
freedoms and in line with applicable law, a notifiable breach will be reported
within 72 hours of us becoming aware of it. The individual(s) involved will
also be informed.
CHANGES TO THIS POLICY
Cavendish Rentals has pledged to adhere
to the fundamental principles of privacy and data protection. We therefore
regularly review our privacy statement in order to
ensure that it is free of errors and clearly visible on our Website and
Self-Service Portals, that it contains appropriate information about your
rights and our processing activities, and that it is implemented and is
compliant with applicable law. If we make significant changes to this privacy
statement, we will inform you by posting a notification on our Websites along with an updated version of the privacy
statement.
THE RIGHT TO LODGE A COMPLAINT
If you have a complaint regarding how
Cavendish Rentals have handled your personal data, subject access request or
right to erasure, you have a right to lodge a complaint with a supervisory
authority, in this case the ICO, using the contact details below.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Questions, comments
and requests regarding this privacy policy are welcomed and should be addressed
to informationrequest@cavmail.co.uk
Alternatively, you can write to:
Cavendish Rentals Limited
Office 7
Unit 1 Stephen Gray Road
Mold
CH7 1HE
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