At Your London we are committed to ensuring that your privacy is protected. This privacy notice explains how we will collect your personal data and how we use your personal data..
Your London Limited is a data controller in respect of the personal data processed when you visit our website or communicate with us. If you have any questions or concerns in relation to this Privacy Notice you can contact our Data Protection Officer Scott Smith, Director of Your London at firstname.lastname@example.org
This privacy notice was last amended in May 2018. It supersedes any earlier version.
1. WHAT INFORMATION WE MAY COLLECT AND HOW WE USE IT
As a business we collect, use, store and transfer different types of personal data depending on who you are.
If you are enquiring to or indeed purchasing, renting, selling or letting a property through Your London, we collect and use your personal data in order for us to provide you with our services. The personal data we collect and use may include:
· Identity Data (Passport, Work/Study Visa, name, marital status, title, date of birth, university letters, employment referenced, landlord references, gender, username and password, feedback and survey responses)
· Contact Data (billing address, delivery address, email address and telephone numbers)
· Financial Data (bank account and payment details)
· Transaction Data (details about payments to and from you and other services you have purchased through us)
We also may collect and use Aggregated Data. For example, when you visit our website we may aggregate data about your usage to tell us about how certain features on our website are used. This is not usually classified as personal data as whilst it derives from personal data (in the example, it is derived from your Usage Data) it does not reveal your identity to us. If we do link this Aggregated Data to your personal information, it will be treated as personal data in line with this policy.
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. You can ask us to rectify or update your personal information at any time by email to email@example.com
2. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
You may give us your Identity, contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· apply for our services;
· create an account on our website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· contact us through social media;
· walk-in to our branch offices or telephone our call centre;
· give us some feedback.
We collect information on the party being referenced through our online or paper-based tenancy application forms. We may sometimes collect additional information regarding additional referees from third parties to perform other background checks throughout the application process. If you are being referenced the personal data we collect will include your name, home address information, date of birth, telephone number, email address, employment details and financial circumstances.
The lawful basis for processing by Your London Limited for tenant referencing is that of Legitimate Interest.
Agency business accounts (letting agents, estate agents and property managers)
The personal data we collect will include your name, address, work telephone number and work email address.
Why might you share my personal data with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so, for example informing utility and council tax departments of commencement or termination of tenancies, with contractors to attend to remedy maintenance issues, informing superior landlords.
Which third party data processors process my personal information?
The following activities are carried out by third-party data processors: IT services, credit checking, post code validation.
What about other third parties?
We may need to share your personal information with a regulator or to otherwise comply with the law.
We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.
Data is held in the United Kingdom using different (multiple) servers. Your London Limited does not store personal data outside of the EEA
Third parties or publicly available source
We may receive personal data about you from various third parties and public sources as set out below:
Identity and Contact Data from data brokers or aggregators such as:
· Rightmove based inside the EU
· Zoopla Property Group based inside the EU
· Homelet Reference and credit agency inside the EU
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. You also have the right to withdraw consent for us to pass your information to third parties for marketing purposes. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.
You can ask us to stop sending you marketing messages at any time by:
· contacting us at any time by emailing firstname.lastname@example.org
· If you do withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations.
Your London is committed to operating its business in a transparent and open manner consistent with our legal and regulatory obligations. We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity. We always seek to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to the National Crime Agency.
As part of this commitment, we adopt a strict compliance of all Anti-Money Laundering rules, with specific emphasis on the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010 and the Terrorism Act 2000.
Your London policy commitment is applicable to all of our customers, including vendors, buyers, landlords tenants and contractors. As a result we obtain and hold for a period of at least seven years evidence pertaining to our customers' identity and, where appropriate, we obtain proof of ownership of property and source/destination of funds. We will be unable to proceed with any work on behalf of our customers if we are unable to obtain this information. Customers' identity will be subject to an electronic identity check, which may also include a credit check and right to rent checks.
Your London is registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017.
3. DATA SECURITY
Once we have received your personal data we will use reasonable and necessary procedures and security features to try and prevent unauthorised access. For example, we limit who can access your personal data to those individuals and third parties who need to know it and who are subject to a duty of confidentiality. If we become aware of a data breach we will notify the Information Commissioner's Office. If we believe that the data breach is serious, we may notify you in accordance with our legal requirements.
4. INTERNATIONAL TRANSFERS
We will not transfer your personal data outside of the European Economic Area, except to a country offering the same level of protection for your personal data. For example, with certain service providers we may use specific contracts approved by the European Commission which ensures that your personal data has the same protection as it would have in Europe.
5. DATA RETENTION
We hold on to your personal data whilst you use our services (or whilst we provide services connected to you) and for at least seven years thereafter, for legal, regulatory and accounting purposes. If we need to hold on to your personal data for longer, we take into consideration the potential risks in continuing to store your data against why we might need to keep it..
6. YOUR LEGAL RIGHTS
Under data protection laws you have the right to protect and look after your personal data. You have the right to:
· ask us for the personal data that we hold and process about you (this is commonly known as a data subject access request). You have rights to the following information:
o the purpose(s) for which we are processing your information;
o the categories of personal information we hold about you
o the recipients or categories of recipient to whom the personal data have been or will be disclosed;
o the period for which we will store your information, or the criteria used to determine that period;
· prevent the use of your personal data for marketing purposes by emailing email@example.com
Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions.;
· ask that any inaccurate information we hold about you is corrected;
· ask that we delete the personal data we hold about you in certain situations;
· ask that we stop using your personal data for certain purposes;
· ask that we do not make decisions about you using completely automated means; and/or
· ask that personal data we hold about you is given to you, or where technically feasible a third party chosen by you, in a commonly used, machine-readable format.
The rights listed above may apply in certain circumstances, and so we may not always be able to comply with your request to exercise these rights. We will usually respond to a request from you to exercise your rights within 14 days of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests. Please be aware that we may need to process your personal data and/or request specific information from you to help us comply with your request.
Complaints and Feedback
If you would like to speak to us about how we handle your personal data, please contact our Data Protection Officer in the first instance at firstname.lastname@example.org
You can also complain to the Information Commissioner's Office who is the UK supervisory authority for data protection issues.
How to contact Your London
Your London Limited is registered in England and Wales (registered number 08162473).
Our registered office is:
Garbetts Accountants, Exchange House, St. Cross Lane, Newport, Isle Of Wight, PO30 5BZ