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 firstname.lastname@example.org 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.
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.
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:
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):
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.
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.
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.
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:
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 email@example.com
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:
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 firstname.lastname@example.org.
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.
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 email@example.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.
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:
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.
If you have any concerns or require any further information, please do not hesitate to contact us at firstname.lastname@example.org.
Copyright 2019 DeTrafford