When we collect and use your personal information, we are subject to the General Data Protection Regulation and the Data Protection Act 2018 and for the purpose of these laws; we are responsible as the ‘controller’ of the personal data.
Key terms used within this policy:
|We, us, our||Universal Management Services Limited trading as ‘Behr and Butchoff’|
|Team responsible for data protection compliance||Data Protection Officer, 44-48 Old Brompton Road, South Kensington, London, SW7 3DY.|
|You or Your||Refers to anyone whose personal data we process|
2. What data we collect
Personal data is any information that tells us something about you where you are directly or indirectly identified or identifiable as an individual. We may collect and use the following personal data about you.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, your image (be that photographic or video), nationality (purely for the purposes of complying with the Immigration Act 2014) and gender.
- Contact Data includes residential address, property ownership information, relevant contact addresses, email address and telephone numbers.
- Financial Data includes bank account, payment card details and information to enable us to undertake Anti Money Laundering and Terrorist Financing electronic checks on you
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Call recordings includes recording all calls made and received externally.
This personal data is required to provide our services to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing services to you.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How do we collect personal data
We use different methods to collect data from and about you including through:
- Direct interactions. 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.
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- contact us through social media;
- request marketing to be sent to you;
- walk-in to our branch offices;
- enter a competition;
- promotion or survey;
- give us some feedback;
- speak with us on the telephone and we record the call;
- make a complaint;
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Data directly from a third party
- sanctions screening providers;
- payment service providers;
- credit and tenant referencing agencies;
- government or police databases or registers;
- customer due diligence providers;
- property portals through which you request our services.
- analytics providers such as Google based outside the EU;
- advertising networks such as Google based outside the EU; and
- search information providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as First Data or FiServe who may be based outside the EU.
Identity and Contact Data from publicly available sources such as social media sites, including Facebook, YouTube and LinkedIn (based outside the EU), Companies House, HM Land Registry and the Electoral Register (based inside the EU).
4. How we use personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer and provide services to you.||For the performance of our contract with you or to take steps at your request before entering into a contract.|
|To prevent and detect fraud against you or us||For our legitimate interest or those of a third party, i.e. to minimise fraud that could be damaging to you and us.|
|To manage our relationship with you which will include:
- Updating and enhancing customer records
- Asking you to leave a review or take a survey
|Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|Conducting checks to identify our customer and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, range of services or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|To record telephone calls both incoming and outgoing||Performance of a contract with you
Necessary for our legitimate interests (to train staff and maintain high levels of services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
|To enable you to partake in a prize draw, competition or complete a survey||Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|Marketing our services to:
— existing and former customers;
— third parties who have previously registered with us or expressed an interest in our services;
— third parties with whom we have had no previous dealings
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We will hold your personal data on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
5. Who we share your personal data with
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 (where possible) to ensure they can only use your personal information to provide services to us and to you. These will include but will not be limited to:
- We will share personal data with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
- We may share a anonymised version of your personal data to third parties such as Facebook and google to enable these third parties to display Chestertons ads when you visit their websites.
- We may share your personal information with any person working within the Chesterton Global Limited Group on a need to know basis to ensure we are able to perform our obligations to you.
- Third parties we use to help deliver our services to you, e.g. payment service providers, referencing companies, electronic AML due diligence providers, utility concierge services, maintenance contractor, inventory companies etc.;
- Other third parties we use to help us run our business, e.g. website suppliers, online tenancy progression platforms, case management system providers etc.;
- Third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
- Credit reference agencies;
- Our banks.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform then that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertiser’s wishes by displaying their advertisement to that target audience. Analytics and search engine providers that assist us in the improvement and optimisation of our site. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you or for the purposes of completing an anti-money laundering identity check, in accordance with our legal obligations.
We use online advertising to keep you aware of what we’re up to and to help you find our products. Like many companies, we may target Chestertons banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience Service.
Our use of analytics and targeted advertising tools
We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyse Google's interest-based advertising data and/or third-party audience data (such as age, marital status, life event, gender and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook to perform similar tasks, using your Contact, Technical, Usage and Profile Data.
In order to opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings or opt-out of the relevant third-party Ad Settings. For example, you can opt-out of the Google Display Advertising Features. As an added privacy measure, you can also use the The Digital Advertising Alliance (which includes companies such as Google and Facebook), who provides a tool called WebChoices that can perform a quick scan of your computer or mobile devices, find out which participating companies have enabled customised ads for your browser, and adjust your browser preferences accordingly.
6. Where we keep your data
The security of your data is very important to us and we have measures in place, which are designed to prevent unauthorised access to your personal data including but not limited to:
- Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
- Hard copy documentation is stored in locked cabinets within our offices.
7. Overseas transfers of your personal data
We may transfer your personal data to an external third party which is based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. For how long do we keep your data
We will not keep your personal data for longer than we need to, the period for which we will keep your personal data will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain information in case of legal claim.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your rights in relation to your personal information
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data. - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. - This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data. - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data. - This enables you to ask us to suspend the processing of your personal data in the following scenarios
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data. - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent. - Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies at section 8 above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Complaints and contact details
If you have any complaints about the way we use your personal data 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 Information Commissioner Office (ICO). If you need more information about how to contact the ICO please let us know.
11. Update to this notice
From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice and you can check our website here to review the previous version.
This notice was last updated May 2023
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