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Privacy Notice

Privacy Notice

Contents

What personal information do we collect and why?

How we use this information

Information sharing

How we keep your information secure

For how long do we keep your personal data?

Transferring your personal data overseas

Your rights and choices in relation to your personal information

Our Use of Cookies

Children’s Privacy

 

 

London Villa takes active steps and measures to protect your privacy. This Privacy Notice governs the use and processing of personal information that may be collected and used by certain members of our team. We assure you, we will always protect your information as though it were our own.

On this site, when you see the terms “London Villa”, “we” and / or “our”, we are referring to London Villa Ltd and all related UK companies which may require and collect your information as explained in this Privacy Notice. When we say “you” or “your”, we are referring to anyone whose personal information we process.

Personal information means any (and we mean any) information that could be used to identify you. So if you call us and your favourite lettings agent is not at their desk, just leaving your first name for a call back means we have collected your personal information and the way we treat that information is explained in this Privacy Notice.

It’s really important so please do take the time to read it.

What personal information do we collect and why?

The personal information London Villa collects really depends on why we are in touch. If you call us because you are looking for a rental property for example, we would need to be able to stay in touch with you to arrange a viewing. If we have the pleasure of letting and managing one of your properties, we would need to know which bank account to send rent collections to.

We want to get to know you so that we can provide the best possible service to you so when you first get in touch with us we will collect:

  • Your full name
  • Phone number(s)
  • Email address
  • Postal address

You will in return always have the name and contact details of the letting agent or property manager who is looking after you. If you like us you may decide to use our services or buy our product. At this point, we are required by law to take a little bit more information from you. That would include at least some of these details:

  • Date of birth
  • Payment information (such as credit card if you are, e.g. a tenant paying administrative fees this way) and bank account details (to set up your rental payments / collection)
  • Demographic information (if you need you’re a short let tenant who needs our concierge to arrange a driver from the airport for example)

We are only as nosey as we really have to be so generally speaking, we don’t collect information that is considered under the new GDPR guidelines as “sensitive”; we won’t ask you about your racial or ethnic origins, political opinions or religion for example. However, there are some situations where another law means we have no choice but to ask for other types of sensitive information. For example, if you are a tenant who has to adhere to the rules of the “Right to Rent” scheme we have to carry our certain checks and for these, we need to collect details of your:

  • Biometric residence card
  • Immigration status document and / or
  • Birth certificate

Sometimes it’s really helpful for us to have other little bits of information. If you tell us why you want to have certain property features, we can often make suggestions you might not have considered; for example, if we know you want small outdoor space because you have a dog, an apartment with no private outdoor space but direct access to a huge communal garden might be lots more fun for doggo (can you tell we’re dog people?). Similarly, if you have subscribed to receive market updated from us, or stay informed about our other / future developments, we may ask you for information about the sector you’re most interested in. You don’t always have to answer these types of questions but if you do, we can make sure we don’t send you information about hotel investments when all you want is a rental property in Notting Hill.

If you’re buying or selling a property through us, and especially if you want us to negotiate on your behalf, we will need to ask you about your budget. As soon as we find your ideal asset or buyer, there will be additional information we need from you so we can confirm that you meet anti-money laundering and counter terrorist financing rules and requirements. Excuse the legal jargon here but, if the buyer is not a “natural person” (e.g. a trust or a company) we will still have to collect personal information about the beneficiaries of the entity and / or the controllers; again, this would be to can confirm that you meet anti-money laundering and counter terrorist financing requirements. We would confirm this with information that proves you are who you say you are, such as:

  • Photographic identity documents (e.g. passport or driving licence)
  • Government approved proof of address (e.g. recent utility bill or bank statement showing your name and address)

If we’re letting or selling a house for you we will need to prove we know for certain that you are the owner and / or have the authority to let /sell the property so we will either check the Land Registry or, where appropriate ask you for:

  • Proof of Power of Attorney
  • Guardianship Order
  • Grant of Probate

The personal data we ask for is information we need to perform the services you have asked of us. If we don’t have your address for example, we won’t be able to let or sell your property. And if we don’t have your contact details we can’t tell you about any offers or interested tenants.

This Privacy Notice talks a lot of our legal obligations. Most of our compliance obligations are designed to prevent fraud and money laundering. There is particular emphasis on the following laws and regulations:

  • Proceeds of Crime Act 2002
  • Money Laundering Regulations 2017
  • Bribery Act 2010
  • Terrorism Act 2002

If you do not provide the information we need to comply with these laws, we could be breaking the law if we continue to provide some of our services to you. We will always explain when this is the case when we are collecting information from you.

How we use this information

We are only allowed to collect information if we have a legal basis to do that. We’ve put together a table to help you understand the different types of information we may collect, why and the legal basis that allows and governs the collection of that data.
We will only use your personal date for the purposes for which we collected it, unless we really have to use it for another reason which is compatible with the original reason. For example, if we are managing one of your properties and an urgent repair is required, we may enlist the services of a qualified tradesperson and we would of course need to tell them which property to go to. If your personal data is needed for a different, unrelated purpose, we will contact you to explain that to you.

Purpose / Activity Type of Data Legal Basis for Processing Including Basis of Legitimate Interest
To register you as a new client IdentityContact

KYC

Conflict Checks

Performance of a contract with you
To deliver our services to you Identity

Contact

Financial

Transactional

Marketing & Communications

Performance of a contract with you

Necessary for our legitimate interests (e.g. running our business, checking your suitability to buy or rent a property via us, to recover debts due to us, etc.)

Consent

Compliance with legal obligations (e.g. carrying out customer due diligence per Money Laundering Regulations)

 

To manage our relationship with you including letting you know about changes to our terms of service or privacy notices Identity

Contact

Financial

Usage

Marketing & Communications

Performance of a contract with you

Necessary for our legitimate interests (e.g.to keep our records up to date

Compliance with legal obligations

To deliver relevant website content and advertising to you

Help us improve and optimise our websites, marketing material, content and services

To help us keep our website up and running

Identity

Contact

Technical

Usage

Profile

Marketing & Communications

Necessary for our legitimate interests (e.g. develop our products / services, provision of administration and IT services)

Compliance with legal obligations

To use data analytics to improve our website, products / services, marketing, client experiences Technical

Usage

Profile

To make suggestions and recommendations to you about services that may be of interest to you

Identity

Contact

Marketing and communications

Technical

Profile

Usage

Necessary for our legitimate interests (e.g. to develop our services and grow our business etc)

 

Information sharing

There is nothing worse than cold callers which is why we would never sell your information to external marketers, and we only share your information when it is needed and to your benefit, and / or if we are obligated to do that. We only work with and engage with organisations who can show us they respect your privacy as much as we do. If we haven’t already, we will ask them to tell us how they secure your data and how far access to your personal data is restricted. We won’t let any of our service providers use your personal data for their own purposed and they can only use the information for the specific reason it is given to them. Here are some examples of who we might share your personal data with and why:

  • If you are renting a property we have on our books, we do have to share your information with independent and third party referencing agencies who check whether you’re a suitable tenant for that property
  • If you are buying a property with us or selling through us, we will need to share your personal information with the solicitor you appoint for the purpose of that purchase or sale, as well as the solicitor acting on the other side of the transaction.
  • If you instruct us to manage your property and we are undertaking maintenance, we may sometimes use external contractors who will need personal data (usually just your address) to fulfil their duties
  • If you are one of our Investment clients and need our help to raise finance, manage and / or advise you on your investments, we may need to share your personal information with third party lenders
  • Similarly, if you need a mortgage to purchase your dream property, we will disclose personal to lenders to source funding options for you
  • If the ownership of our company changes or we merge with another company, our advisers, potential buyers or joint owner and their advisers may need access to some of your personal details. They would have to use your information as governed by this Privacy Notice
  • The property industry is governed by various regulators, government organisations, who, similarly to law enforcement agencies, arbitration bodies and courts, may request (or even demand) access to your personal data. We will always comply with regulatory and legal obligations

 

How we keep your information secure

We have always been incredibly proactive in keeping your personal data secure and as private as possible. London Villa operates on a “need to know” basis which means that only those who need to access your information (e.g. the accountant who needs to issue rent collections to you, or the property manager tasked with looking after your property) will be able to access your data. Access restrictions also apply to contractors and other third parties who have a business need to know. Everyone who has access to your information have agreed to a duty of confidentiality.

Some of the steps we have taken to protect your personal data are:

  • Any paperwork we have with personal data on it is organised and stored in locked cabinets
  • Digital storage is secure and restricted to people within or connected to London Villa, with a business need to access your information
  • The CRM systems (the software we use to file, manage and monitor all our customer interactions) comply with stringent security measures to prevent your data from being accidentally lost, used, accessed, altered or disclosed in an unauthorised way

For how long do we keep your personal data?

We do not keep your information any longer than we are allowed to keep it. Usually that will mean keeping it beyond the time period over which we are providing a service to you; this is because we often have to hold on to personal data for at least seven years for legal, regulatory and accounting purposes.

 

Transferring your personal data overseas

If we have to transfer, store, or process your personal information anywhere outside the UK and the European Economic Area, and the country in question does not offer the same level of protection for your personal data, we will take the following steps to safeguard your information:

  • We will try to transfer it to a country with privacy laws that afford the same protection as that of the EEA
  • Use service provider contracts approved by the European Commission which ensures that your personal data has the same protection standards as the EEA

 

Your rights and choices in relation to your personal information

You have the right to know what information of yours is used, by whom, and how it is used. You also have some control over it. For example, you have the right to:

  • Ask us for the personal data that we hold and process about you (data subject access request)
  • Ask us to correct your information if you think it is incorrect or incomplete
  • Ask that personal data we hold about you is given to you in a commonly used, machine-readable format
  • Ask that we do not automate any decisions about you

 

You can also ask us to delete your personal information if:

  • We continue to process your personal data beyond the period necessary for the purpose it was originally collected AND the period we are legally obligated to keep it
  • You would like to withdraw consent and we consent is the legal basis we rely on for processing your data
  • The personal information has to be deleted to comply with legal obligations
  • Your personal information has been processed in breach of data protection legislation

 

Sometimes we will not be able to, for legal reasons, delete your personal data but you can still ask us to stop processing your data if:

  • You consider the information we hold about you is inaccurate
  • It is unlawful for us to process your information
  • You don’t want us to process the information but need us to keep hold of it to help you in the course of a legal claim

 

You can expect us to respond to a request from you to exercise your rights within one month of receiving it. If your request is complicated it might take a little longer. All reasonable requests are free of charge to you. You may be charged however, where you request is complex, resource heavy, unreasonable, excessive and / or repetitive.

 

If you do ask for access to your personal data, we will want to make sure we’re not giving your information to someone who doesn’t have any right to it. As a security measure to ensure we do not unwittingly disclose your information to anyone who has no right to receive it, 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).

 

If you would like to exercise any of your rights please contact dataprotection@londonvilla.co.uk

  1. Complaints and Contact Details

Complaints

If you have any complaints about the way we use your personal information you can contact us at dataprotection@londonvilla.co.uk. In the unlikely event that we are not able to resolve your complaint, you can get in touch with the Information Commissioner’s Office (ICO) if you are in the UK, or the data protection authority in your country,

Contact details

If you have any questions about of this Privacy Policy, let us know by sending an email to dataprotection@londonvilla.co.uk

Alternatively, you can go with the more traditional option of writing to: The London Villa team, 16a Baker Street, London, W1U 3BL

Our Use of Cookies

COOKIES POLICY

This cookie notice is for visitors to our website.

What are cookies?

For almost any modern website to work properly, it needs to collect certain basic information on its users. To do this, a site will create files known as cookies – which are small text files – on its users’ device, for example, your computer or mobile phone. These cookies are designed to allow the website to recognise its users on subsequent visits, or to authorise other designated websites to recognise these users for a particular purpose.

The London Villa website logs the user’s IP address which is automatically recognised by the web server. This is used to record the number of visitors to our site and to help monitor the performance of individual web pages.

These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often and if they get error messages from web pages. These cookies do not collect information that identifies a visitor; all information collected by these cookies is anonymous. We only use such information to improve our services and our website. Examples of performance cookies used on the website are listed below.

Analytics cookies

We use Google Analytics to monitor the performance of the website. Google Analytics sets cookies to help us accurately record the number of visitors to the website and volumes of usage. This helps us to identify where visitors to the site may be encountering problems and also gives us an indication of the types of content visitors find particularly useful.

The site uses the following analytics cookies:

Example below 

Name: _utma
This cookie stores each user’s amount of visits, and the time of the first visit, the previous visit, and the current visit.
Expires: 2 years

For more information about Google Analytics visit the Google Analytics website.

Removing and disabling cookies

If you do not wish to accept cookies on to your machine you can disable them by adjusting the settings on your browser. However, this will affect the functionality of the websites you visit.

Children’s Privacy

None of our services are for children under the age of thirteen so we would never knowing collect any information about or from children via our websites or any other method.

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