Privacy Policy

The Scope and Purpose of this Privacy Notice

This Privacy Notice explains how DeTrafford and Palatine Estates Ltd, company number 09921732 (‘DeTrafford’, ‘we’, ‘us’, ‘our’), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a DeTrafford client or being generally interested in our services and our publications in accordance with applicable data privacy laws. Should you have any questions about this Privacy Notice you can contact us at mail@detrafford.com or at the address mentioned below.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Notice.
DeTrafford is the controller of the Personal Data that we collect. A ‘controller’ is an organisation that decides why and how your personal information is processed.

Personal data

The term ‘Personal Data’ as used in this Privacy Notice means any information relating to you such as your name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymised or aggregate data.

What information do we collect about you and how do we collect it?

The kinds of Personal Data we collect depends on the type of relationship you have with us, including if you are a tenant, landlord or another third party that we have a relationship with, or if you make contact with us via our website.

If our client is a corporate entity, we may collect personal data about you from our client (for example, we may collect information about employees of our client, its directors and other relevant individuals of the client).

Personal Data you give to us: we collect the Personal Data that you give to us via our website, on forms you complete (on paper or electronically) and over the phone, email or other means of communication. The information we collect includes your name, address, contact information (email address and telephone number) and bank details. If you’re a tenant we may also ask for your ID (including passport, driving licence and household bills), date of birth, employment details, bank statements and payslips, and references from your employer and your current or previous landlord. We also keep a record of your marketing preferences.

Personal Data we receive from other sources: we obtain certain information about you from other sources, as follows:

• if you’re a tenant, information we receive following enquiries we or our third party referencing agency make with your employer and/or your previous or current landlord;
• if you’re a tenant, information we receive following enquiries we or our third party referencing agency make with credit reference and fraud prevention agencies – please see ‘Use by credit reference and fraud prevention agencies’ below for further information;
• if you’re a tenant, information we or our third party referencing agency receives following a right to rent check;
• if you’re a landlord, we’ll make enquiries with the Land Registry to confirm ownership of the property;
• when you visit our website we collect industry standard log data that will provide us with information about your visit (including through the use of Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). This includes information such as your location, browser type, operating system, which pages you have visited and how you have reached our website. We use this information to provide you with relevant information and ensure that our site is working properly. We may ask for further information from you should you report a problem with our website. In addition, we collect data from cookies, details of which can be found in our Cookie Policy.

How do we use Personal Data?

The purposes for which we use your Personal Data and the legal bases under data protection laws on which we rely to do this are as follows (as relevant):

• Performance of the contract with you or to take steps to enter into it. This includes verifying your identity, assessing your application, and, if we enter into an agreement with you/ our corporate client, administering the agreement in order to provide you with the service under that agreement (i.e. advertising properties and dealing with enquiries, communicating with you in relation to the service we’re providing to you, sending and receiving rental payments and dealing with any complaints).
• Our legitimate interests or that of a third party for the following purposes:
  o if you’re a tenant, to assess your application, including analysing the information we receive from the credit check and right to rent check, in order to assess and understand your payment performance and ability to rent; o to prevent fraud and money laundering, and to verify your identity, in order to protect our business and to comply with laws that apply to us; o to respond to and deal with any queries we receive; o to enhance and personalise your customer experience by analysing patterns and customer behaviours, including contacting you to ask you about your experiences (we may engage a market research company to contact you on our behalf); o to recover debt, for repossession, and trace your whereabouts; o to carry out marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms; o if you’re a corporate contact, to send you direct marketing via email, post or phone; o for management and audit of our business operations including statistical analysis and accounting; o to monitor communications between us to prevent and detect crime, to protect the security of our communications, systems and procedures, and for quality control and training purposes; o for network and information security in order for us to take steps to protect your information against loss, damage, theft or unauthorised access; and o to notify you of any changes to this Privacy Notice.
• Our legitimate interests or that of a third party for the following purposes:
  Compliance with a legal obligation. This includes when you exercise your legal rights under data protection laws, to verify your identity, for the establishment and defence of our legal rights, for activities relating to the prevention, detection and investigation of crime, to conduct credit, fraud prevention and anti-money laundering checks and for compliance with our legal and regulatory responsibilities.
• Our legitimate interests or that of a third party for the following purposes: Consent. Where we have your consent, to use it for direct marketing communications (unless we rely on our legitimate interests). You can withdraw your consent to marketing at any time by following the unsubscribe instructions in the relevant communication.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

What if you do not provide the Personal Data we request?

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our services, to enter into a contract with you or to send you requested marketing or other information.

Change of purpose, anonymisation

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above, we may share your Personal Data with the following third parties:

• If you’re a tenant, the landlord of the property you are renting. If you’re a landlord, the tenants of your property.
• If you’re a tenant vacating a property, your incoming agent may ask us for a landlord reference, which we will provide to them provided they have obtained your consent.
• Your local council to notify them of any change in tenancy for the purpose of council tax calculation.
• Contractors engaged to carry out works on the property.
• Credit reference agencies, fraud prevention agencies and our provider of right to rent check services.
• Third party suppliers engaged by us to undertake certain services, including our third party referencing agency, Let Alliance, our deposit service providers including the Deposit Protection Service and our inventory service providers. These third parties will also be controllers of your information and are solely responsible for protecting your personal data and processing it in line with data protection laws.
• Third parties acting on our behalf, such as our systems provider, our contracts manager system, back-up and server hosting providers, IT software and maintenance providers and their agents, and third parties that provide customer support services, claims handling services, income verification services, affordability checks, communication fulfilment services and market research agencies.
• Law enforcement agencies in order to detect, investigate and prevent crime (we or any fraud prevention agency may pass your information to law enforcement agencies).
• Courts in the United Kingdom or abroad as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.
• Any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event, including where we transfer your agreement to a third party.
• Our professional advisors and auditors as necessary.

Where is your information stored?

For the purposes described above we may transfer your Personal Data from the UK to a DeTrafford office located outside of the UK or a third party outside of the UK and to a jurisdiction not being subject to an adequacy decision of the European Commission. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with and respects the UK laws and other applicable laws and regulations on data protection. We have put in place standard contractual clauses as our safeguard method. If you require further information about this please contact us at mail@detrafford.com

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

• request access to your Personal Data (commonly known as a ‘data subject access request’) and request certain information in relation to its processing;
• request rectification of your Personal Data;
• request the erasure of your Personal Data;
• request the restriction of processing of your Personal Data;
• object to the processing of your Personal Data.
• withdraw your consent where we rely on it (please see further information on this right below);
• transfer of your Personal Data.

Your ability to exercise your rights depends on the legal basis on which we have relied to process your Personal Data, therefore there may be some limitations as to how or if you can exercise these rights.

If you want to exercise one of these rights please contact us at mail@detrafford.com.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Right to withdraw consent

Where you have provided your consent to the processing of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact mail@detrafford.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.

How long will we retain your information?

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data. Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.

We retain tenant and landlord Personal Data for the duration of the relationship we have with you plus 6 years. If you have signed up to receive marketing from us we will retain your Personal Data for as long as you are subscribed to our marketing list. If you unsubscribe, we will keep your details on our suppression list to ensure that we do not send you further marketing.
Credit reference agencies will retain the account information we give to them for 6 years after your account is closed.

Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your information can be held for up to 6 years.

We may hold your information for a longer or shorter period from that described above where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; and
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website.

Further information

If you have any concerns or require any further information, please do not hesitate to contact us at mail@detrafford.com.