For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (the GDPR), the Company is the controller of the personal data it processes about you. We are registered with the Information Commissioner’s Office with registration number: ZA362789. We also control and operate http://www.arncliffehomes.co.uk (the Website). This policy sets out how we collect, process, store and protect your personal data.
2 How we collect your personal data
We collect personal data directly from you when you contact us by phone, email, or through the Website. We also collect your personal data when we meet you in person, for example when you attend one of our developments to view a home.
The personal data we collect from you may include:
- your name, address, home, work and mobile telephone number(s) and email address;
- information about your transactions with us,
- information you provide when you respond to requests to submit personal information about yourself;
- records of written and verbal communications between us;
- CCTV images if you attend on our premises where we use CCTV recording (see under “CCTV” below); and
3 How we use your personal data
We may use your personal data in the following ways:
- in order to provide you with our products and services (for example, to keep in touch with you during the building process when we are building your home);
- to communicate with you by phone, email and post;
- to provide you with excellent customer service during and following your relationship with us and in order to obtain feedback from you about our services and your experience with us;
- to provide you with updates you have requested, including keeping track of specific developments and areas; and
- to ensure that the content of the Website is presented to you effectively.
4 Our legal basis for processing your personal data
Our use of your personal data as outlined above is subject to different legal bases for processing, including where necessary for:
- performing our contractual obligations to you (where you are purchasing a home from us) or to take steps at your request prior to entering into an agreement with you (when you have requested further information about, or to view, one of our homes). If you do not provide us with certain personal data we will not be able to sell a home to you;
- our legitimate interests, for example to conduct analysis and reviews in relation to our sales, in managing and monitoring the Website operation, and for our business compliance purposes; and
- compliance with a legal obligation where necessary, including making reports to regulatory authorities and law enforcement agencies.
Where our use of your data is not necessary for one of the purposes outlined above we may seek your consent to use it in a particular way (for example if you ask us to keep you updated if we start a project in a particular area or in relation to a specific type of home). Where we ask for your consent you are free to refuse our use of the data for those purposes and you may withdraw your consent at any time by contacting us using the details set out below.
5 Sharing your personal data
We only share your personal data with third parties where it is necessary for us to do so in order to provide you with our services, or where we are required to do so in order to comply with a regulatory or legal provision. We will never sell your personal data for direct marketing.
The circumstances in which we may share your personal data with third parties includes:
- where we use a provider of services, for example in relation to our computer systems or programs which we use for our business operations;
- using a security company to monitor the CCTV we use at our head office and at some of our development sites;
- sharing personal data with British Gas and the BT Group where we are required to provide details of the purchasers of our homes in order to set up utilities such as gas, electric and telephone lines; and
- where we share your personal data with our professional advisers such as lawyers and insurers.
We may use CCTV monitoring and recording on some of our premises, including our head office and development sites, for the purposes of security, crime prevention, health and safety and performance monitoring. The CCTV is monitored and administered by third party security companies. Wherever CCTV is in operation you will be notified of this via appropriate signage.
CCTV images are retained for a period of 90 days unless there is a specific requirement to retain them. The images are recorded for our internal use and will not be shared with any other third parties except where required, for example for the purposes of the prevention or detection of crime.
7 Transfers of your personal data
The personal data that we collect from you will not ordinarily be transferred to, or stored at, a destination outside the European Economic Area (EEA).
However, if we do need to transfer your personal data outside the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data.
Please contact us if you wish to find out more; if we ever transfer your Personal Data outside the EEA you can ask us for a copy of relevant safeguards.
8 How long we will retain your personal data
The length of time we hold your personal data will depend on the reason for us processing such data. For example, where you purchase one of our homes, we will retain your personal data for a period of up to 10 years so that we have your details during the period in which your home may be covered by warranties. Where you provide us with your email address and ask us to contact you in relation to a particular area or type of home, we will hold your personal data for a maximum of six years from when you provided it to us.
10 External Links
Although the Website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links provided on the Website.
We cannot guarantee or verify the contents of any externally linked website. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned. Please note external websites will have their own privacy policies. Please review these policies before you submit any personal data to those websites.
11 Changes to this policy
12 Your rights
Your personal data is protected under data protection laws and you have a number of rights (explained below) which you can seek to exercise. Please contact us using the details provided in the contact and complaints section below if you have any queries in relation to your rights.
If you seek to exercise your rights we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances.
- Right of access – You have a right to access the personal data we hold about you upon request. This is known as a “Data Subject Access Request”. You can exercise this right by making a request in writing, by email or by telephone using the contact details in the contact and complaints section below.
- Right of rectification – You can ask us to correct or update your personal data to ensure it is accurate and complete.
- Right to erasure and right to restrict processing – You can ask us to stop processing and/or to delete your personal data in certain circumstances (for example, where it is processed with your consent, or it is no longer necessary for us to process it).
- Right to data portability – You have a right to ask us to provide you with your personal data in a form that suits you, and/or to provide your information to a third party.
- Right to object – You have a right to object to our processing of your personal data.
- Profiling and automated decisions – You have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling. We do not undertake any automated decision making or profiling.
- Right to object to direct marketing – Where you have consented to receive direct marketing, you can change your mind at any time by contacting us or following the link to “unsubscribe” provided in each email we send to you. Please allow a few days for us to action your request.
13 Contact and complaints
You also have the right to lodge a complaint with a supervisory authority (the ICO) by writing to Information Commissioner’s Office, Water Lane, Wilmslow, SK9 5AF or calling 0303 123 1113. Further information about how to do this can be found at: www.ico.org.uk.