Introduction

This privacy notice tells you what to expect us to do with your personal information when you make contact with us or use one of our services.

This notice is layered. Part 1 of this notice contains information we need to tell everybody whose personal data we process and it applies to them all. Part 2 of this notice contains specific sections which are relevant to particular categories of individuals whose personal information we process depending upon their relationship with us. So, if you wish, you can easily select the specific section which applies and see how we process your personal information and see what we do with it.

Please read the “Cookies” section for more information about cookies and their use on our website. This appears at the end of Part 1 of this notice.

In this privacy notice we explain to you:


• why we are able to process your information
• the purposes we are processing it for
• whether you have to provide it to us
• how long we store it for
• whether there are other recipients of your personal information
• whether we intend to transfer it to another country, and
• whether we use automated decision-making or profiling.

PART 1

Controller of your personal information

References to we, our or us in this privacy notice are to Nicholas King Developments plc, Registered Number: 6561603. Registered Office: 10 Penn Road, Beaconsfield, Buckinghamshire, England, HP9 2LH and each of its direct and indirect subsidiaries and joint ventures.

We are the controller for the personal information we process about you, unless another controller is stated and for the purposes of this privacy notice the controller is the relevant part of the Nicholas King Developments plc group or its joint ventures which is processing your personal information. If you are unsure which of our group or joint ventures is processing your personal data then please ask us (see the “Contacting us” section below) and we will provide details to you.

Where we pass your personal information to a third party, in some cases they may then become a controller of your personal information and they should in these cases provide you with their own privacy notice to explain how they use your personal information.

Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.

The difference between controllers and processors

A data controller or controller is a person who controls how personal information is processed and used. Data controller or controller are two terms that mean the same thing. A data processor or a processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller or controller.

This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have). These rights can generally only be exercised against a controller of your personal information.

In most cases we will be a controller of your personal information. In any case where we are not a controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the controller of your personal information so that you can direct any such requests to them.

Also it is only a controller that will provide you with a privacy notice about your personal Nicholas King Developments plc Privacy Notice information, so where we process your personal information as a controller this is our privacy notice. If we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.

Data Protection Officer

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section below.

Contacting us

There are many ways you can contact us, including by phone, email, and post. You should contact our Data Protection Compliance Manager]in relation to any data protection related queries. Details are below:

Email: dataprotection@nkhomes.com

Post: The Data Protection Compliance Manager, Nicholas King Developments, 10 Penn Road, Beaconsfield, Bucks, HP9 2LH

Telephone 01494 811800 and ask to speak to our Data Protection Compliance Manager or another member of our data protection team

Your rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information and also whether we process your information in particular ways. Your rights are set out below:

Your right of access – You have the right to ask us for copies of your personal information and to be informed about how your personal information is used. This right always applies. There are some exemptions, which mean you may not always receive all the information we process.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the right to object to processing if we are able to process your information because it is in our legitimate interests.

Your right to data portability – This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

Your right to object to marketing – You have an absolute right to object to receiving any marketing materials from us. However, if this right is invoked by you, we can still contact you for other purposes.

Your right to withdraw any consent provided to us – You have an absolute right to withdraw any consent you have given to us to process your personal information. Withdrawal of consent will not affect any processing that took place prior to the withdrawal. We may also have other basis on which we can continue to process your personal information, so withdrawal of consent does not automatically mean we can no longer process your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section above.

Your right to complain

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator if you are based outside the UK. Details of how to complain to the Information Commissioner’s Office can be found at https://ico.org.uk/make-a-complaint/ We are here to help and encourage you to contact us to resolve your complaint first.

Transferring your personal information internationally

Unless stated differently in a section in Part 2 that covers your personal information, this section will apply to all the personal data about you that we process.

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Economic Area except as set out in this section.

Our staff and other individuals working for us may in limited circumstances access personal information outside of the UK and European Economic Area if they are on holiday abroad outside of the UK or European Economic Area. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

Marketing information

From time to time, we may contact you by email, post, telephone or SMS or via social media with marketing information about our products or services we believe you may be interested in. We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously. You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at sales@ or by using the by using the details set out in the “Contacting us” section above. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any written marketing messages we send to you or letting us know during any marketing telephone call.

Security

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.


Linking with third party websites

Our website may, from time to time, contain links to and from the websites of our commercial partners and advertisers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a controller of your personal information you provide to them. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

In addition, if you linked to this website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party website and recommend that you check the policy of that third party website and contact its owner or operator if you have any concerns or questions.

Changes to this notice

We keep our privacy notice under regular review to make sure it is up to date and accurate. We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this privacy notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information. 

PART 2

Introduction

This part sets out the different categories of personal information, sources of information, uses and legal bases for those uses and how long we retain your personal information for different categories of individuals that we deal with.

More than one of these sections may apply to you, for example you may be a customer of ours and also recorded on a CCTV system controlled by us.

Prospective purchasers of homes from us

This section applies to anyone who is or may be interested in purchasing a home from us.

1. Personal Information

When you interact with us (either directly or indirectly) you may provide us with or we may obtain personal information about you, such as information regarding your:

• personal and work contact details and identifiers such as name, title, addresses, telephone numbers, and email addresses, emergency contact details, date of birth, gender;

• marketing preferences including preferred contact methods, property types, locations of interest, developments of interest, purchase schemes and incentives of interest, details of availability;

• financial status, mortgage status, sale status of your current property;

• account information for any of our portals and websites including username, password and other identifying information and other account information;
• advisors appointed by you including mortgage brokers, lawyers, financial advisors, surveyors;

• details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations all of which may relate to enquiries, complaints and correspondence and other communications with you; and

• subscription information, for example when you subscribe to one of our blogs or other materials.

2. Special categories of personal information and criminal records information

We will not generally collect, store and use any “special categories” of more sensitive personal information regarding you including information about your race or ethnicity or any medical condition, health and sickness records, medical records and health professional information and disability information:

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information, and usually in the limited cases where any special category information is processed by us it will be for legal compliance reasons or to establish, defend or bring legal claims.

We will also not generally collect, store and use any criminal records information in relation to you as it not relevant to our dealings with you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information and would only process it for legal compliance reasons.

3. Where we collect your information

We will collect personal information from a number of sources. These include the following:

• Directly from you: from yourself, when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.

• Third parties authorised by you; a family member or someone else authorised by you;

• Our website: provides us with information about how you use it and the devices that you use to connect to our website.

• Providers of information: which may include credit reference agencies, money laundering check providers, the Land Registry.

• Portals, other web platforms and social media: for example Rightmove, Zoopla, Facebook, Twitter

• Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.

• Your professional advisors: such as lawyers, accountants, planning consultants, mortgage brokers, financial advisors and surveyors.

• Our professional advisors: such as lawyers, accountants, planning consultants and surveyors.

We will also collect additional personal information throughout the period of your relationship with us connected to marketing our properties to you.

If you are providing us with details of family members or other individuals they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section above in relation to any personal data we may process about them.

4. Uses made of our personal information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal information used	Lawful basis
Marketing to you properties and developments of potential interest to you and incentives/ schemes of potential interest to you	Name, personal contact details and other identifiers, marketing preferences and any previous purchases	We have a legitimate interest in marketing our properties and developments to you in order to make new sales You may have requested that we send to you details of certain properties, developments or purchase incentives/ schemes We may also have obtained your explicit consent to send you details of our properties, developments and purchase incentives/schemes
Providing to you purchaser portal and/or website access and for the purposes of ensuring the security of our systems and our information	All the personal information we collect about you	We have a legitimate business in providing portal/website access and ensuring our website and systems are secure
To conduct data analytics studies and customer satisfaction surveys to review, and better understand our customer purchase, retention, attrition and satisfaction levels	Our customer records and any information you provide in response to our satisfaction surveys and marketing surveys	We have a legitimate interest in order to improve as a business
Staff training	All the personal information we collect about you	We have a legitimate interest to train our staff and improve as a business
Managing our business and internal reporting	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and manage our business properly
Dealing with enquiries, complaints and other communications from you, managing our relationship with you and dealing with legal disputes involving you	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications We have a legitimate interest to ensure that all legal claims are managed effectively
For the purpose of complying with any regulatory or legal requirements	All the personal information we collect about you	We may have a legal obligation to comply with any legal requirements and we have a legitimate interest in complying with regulatory requirements
Storage of records relating to you and also records relating to our business	All the personal information we collect about you	We may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records

For personal information you will not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly provide the information you have requested or market our properties and purchase/incentive schemes to you.

You should be aware that it is not a condition that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section above.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to carry out certain activities.

We only collect the data we need to provide services that people opt-in to receive that will inform people about Nicholas King Homes and our developments that they may be interested in. This includes using Personal Data for analysis purposes, such as an e-mail address, subscriber activity, gender, age, postcode, name or other characteristics. Data is aggregated for reporting purposes.

5. Disclosure of your personal information

We share personal information with the following parties:

• Companies in the same group of companies as us: for the purpose of providing a service to you.

• Our commercial partners: where they need to know personal information as part of our business dealings.
• Any party approved by you: for example mortgage brokers, financial advisors, legal advisors, your family.

• Service providers to our business and advisors: advisors including legal advisors, administration and IT service providers, marketing and public relations service providers and other service providers to our business. All our third-party service providers are required to take appropriate security measures to protect your personal information.

• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.

• Professional bodies and associations: where relevant to our business dealings.

• The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example the Information Commissioner’s Office.

• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

6. How long we keep personal information for

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of approximately 6 years after our last contact with you. The exceptions to this general rule are:

• Audio recordings will generally be retained for approximately 30 days and then overwritten or deleted, unless required for any reason.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You may be able to update some of the personal information we hold about you through any account you have on our customer portal. Alternatively, you can contact us by using the details set out in the “Contacting us” section above.

PURCHASERS OF HOMES FROM US

This section applies to anyone who is going through the process of purchasing a home from us or who has already purchased a home from us.


1. Personal Information

When you interact with us (either directly or indirectly) you may provide us with or we may obtain personal information about you, such as information regarding your:

• personal and work contact details and identifiers such as name, title, addresses, telephone numbers, and email addresses, emergency contact details, family members, date of birth, gender;

• marketing preferences including preferred contact methods, property types, locations of interest, developments of interest, purchase schemes and incentives of interest, details of availability;

• tax or governmental identifiers regarding any stamp duty or other relevant property taxes;

• bank accounts, credit card details, payment and receipt details, financial status, mortgage status and amounts and tax status, sale status of your current property;

• account information for any of our portals and websites including username, password and other identifying information and other account information;

• details of the home to be purchased, lease details, options selected and payments made, and where you take part in a part exchange referral scheme, details relating to any property you are selling, payments we make to you and other associated information, relevant utilities records, decisions made by you;

• identification documents and information such as passport, utilities bills, identity cards, signature, etc;

• advisors appointed by you including mortgage brokers, lawyers, financial advisors, surveyors;

• property records, searches, documents and files (including our legal files relating to the sale to you);

• details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations all of which may relate to enquiries, complaints and correspondence and other communications with you;

• subscription information, for example when you subscribe to one of our blogs or other materials; and

• pictures where you or your home feature in our marketing materials;

2. Special categories of personal information and criminal records information

We will not generally collect, store and use any “special categories” of more sensitive personal information regarding you including information about your race or ethnicity or any medical condition, health and sickness records, medical records and health professional information and disability information:

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information, and usually in the limited ases where any special category information is processed by us it will be for legal compliance reasons or to establish, defend or bring legal claims.

We will also not generally collect, store and use any criminal records information in relation to you as it not relevant to our dealings with you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information and would only process it for legal compliance reasons.

3. Where we collect your information

We will collect personal information from a number of sources. These include the following:

• Directly from you: from yourself, when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.

• Third parties authorised by you; a family member or someone else authorised by you

• Our website: provides us with information about how you use it and the devices that you use to connect to our website.

• Providers of information: which may include credit reference agencies, money laundering check providers, the Land Registry and other web platforms.
• Portals, other web platforms and social media: for example Rightmove, Zoopla, Facebook, Twitter

• Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.
•
• Your professional advisors: such as lawyers, accountants, planning consultants, mortgage brokers, financial advisors and surveyors.

• Our professional advisors: such as lawyers, accountants, planning consultants and surveyors.

We will also collect additional personal information throughout the period of you going through the purchase process connected to your dealings and activities connected to the purchase of the home from us and, if you are selling your current property, updates on that sale.

If you are providing us with details of family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section above in relation to any personal data we may process about them.

4. Uses made of your personal information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal information used	Lawful basis
Marketing to you properties and developments of potential interest to you and incentives/ schemes of potential interest to you	Name, personal contact details and other identifiers, marketing  preferences and any previous purchases	We have a legitimate interest in marketing our properties and developments to you in order to make new sales You may have requested that we send to you details of certain properties, developments or purchase incentives/schemes We may also have obtained your explicit consent to send you details of our properties, developments and purchase incentives/schemes
Carrying out any identity and money laundering checks	Name, personal contact details and other identifiers, and identification documents, money laundering checks	We have a legal obligation to do so
Dealing with and managing the reservation, exchange of contracts and completion of your purchase of a home from us	All the personal information we collect	We need this information to be able to perform and administer your acquisition of the home from us To be able to enter into, manage and perform our contract with you regarding your property purchase and fixtures and fittings options
Dealing with and carrying out any fixtures and fittings options selected by you in relation to the property you purchase from us	Personal contact details, property details, options selected and payment and transaction information	This is necessary to enter into and perform the contract with you regarding any fixtures and fittings options selected by you in relation to your property purchase
Receiving money from you for your selected options and/or the property	Personal identifiers and transaction and payment information	To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options We may have a legal obligation to do so
Introducing and referring you to potential purchasers of your current property under our part exchange referral scheme where a third party may agree to purchase your existing property	Personal contact details, financial details and property details	We have a legitimate interest to assist you in finding a buyer for your current property You may also ask us to assist you in finding a buyer for your current property
Administering the contract we have entered into with you regarding property transactions and managing our relationship with you including your rights in relation to the property you are buying and managing our part exchange referral scheme	All the personal information we collect about you	To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, if relevant, our part exchange referral scheme
Providing to you our purchaser portal and/or website access and for the purposes of ensuring the security of our systems and our information	All the personal information we collect about you	We have a legitimate business in providing portal/website access and ensuring our website and systems are secure
To conduct data analytics studies and customer satisfaction surveys to review, and better understand our customer purchase, retention, attrition and satisfaction levels	Our customer records and any information you provide in response to our satisfaction surveys and marketing surveys	We have a legitimate interest in order to improve as a business
Staff training	All the personal information we collect about you	We have a legitimate interest to train our staff and improve as a business
Managing our business and internal reporting	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and manage our business properly
Dealing with enquiries, complaints and other communications from you, managing our relationship with you and dealing with legal disputes involving you including any involving defects in properties	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications We have a legitimate interest to ensure that all legal claims are managed effectively
For the purpose of complying with any regulatory or legal requirements	All the personal information we collect about you	We may have a legal obligation to comply with any legal requirements and we have a legitimate interest in complying with regulatory requirements
Storage of records relating to you and also records relating to our business	All the personal information we collect about you	We may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to sell to you the home you wish to purchase or we may not be able to properly perform our contract with you or comply with legal obligations. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you regarding sale of the home to you or, where you are utilising a part exchange referral scheme, assist in the sale of your existing property.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section above.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to carry out certain activities.

5. Disclosure of your personal information

We share personal information with the following parties:

• Companies in the same group of companies as us: for the purpose of providing a service to you.

• Any party approved by you: for example mortgage brokers, financial advisors, legal advisors, your family.
• Service providers to our business and advisors: building, repair and maintenance contractors, product suppliers, banks, advisors including legal advisors, administration and IT service providers, third party property purchasers, marketing and public relations service providers and other service providers to our business. All our thirdparty service providers are required to take appropriate security measures to protectyour personal information.

• Insurance providers: where relevant to the insurance of the home you purchase.
• Managing agents, management company, landlords, the Land Registry: where relevant to the completion of your property transaction.
• Guarantee providers: such as the National House Building Council or other guarantee or warranty providers in relation to your home and/or the fixtures and fittings in the home.

• Utility providers and council tax authorities: for example water, electric, gas, telephone, internet/broadband and the relevant council tax authority.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.

• Government agencies and representatives: where you are taking part in any scheme run by them, for example help to buy.

• The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC, the National House Building Council or the Information Commissioner’s Office.

• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

6. How long we keep personal information for

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of approximately 10 years until after you have completed your purchase of a property from us due to this being the duration of the structural warranty applicable to the home you purchase. The exceptions to this general rule are:

• Legal property information and legal files will be retained for approximately 12 years after completion because this is the limitation period for claims related to property title claims;

• Information regarding the property and its fixtures and fittings will retained for approximately 10 years after completion because this is the duration of the structural warranty applicable to the home you purchase

• Audio recordings will generally be retained for approximately 30 days and then overwritten or deleted, unless required for any reason (please see our separate privacy notice for more details)

• If for any reason you property transaction with us does not complete, then we would retain your records for approximately 6 years (instead of 10 years) because this is the
limitation period for claims related to breach of contract.

It is important to ensure that the personal information we hold about you is accurate and upto-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You may be able to update some of the personal information we hold about you through our customer portal. Alternatively, you can contact us by using the details set out in the “Contacting us” section above.

INDIVIDUALS RECORDED ON OUR CCTV SYSTEMS

This section applies to individuals who are recorded on CCTV systems controlled by us. These will usually be at our developments for security purposes during the building and sales phase of a development, but may also apply to our office premises and sales/showroom premises.

1. What information may we hold / process that will relate to you

We may collect from you video recordings and still pictures which feature you if you are in the field of vision of any of our CCTV system.

This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.

We may also collect personal information about you if you, your representative or a person authorised by you contacts us regarding an enquiry, complaint or other communication.

We do not collect any special category information regarding you, for example your race or biometric information, and we do not process CCTV images in ways which may assess or use these aspects of the images.

The source of your personal information is either direct from yourself when you are recorded on our CCTV system or from communications with or from you or others who act on your behalf.

2. What do we do with your personal information?

As the data controller we will collect personal information on or connected to our CCTV system and use it for the following purposes:

Purpose	Personal information used	Lawful basis
For the prevention and detection of crime	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to prevent and detect crime
For evidence in any civil or criminal legal proceedings	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to use information collected in legal cases, either criminal or civil
To assist in investigations	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to use information collected in investigations
For safety and security	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to ensure safety and security
Dealing with any queries, complaints or enquiries	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to deal with any queries, complaints or enquiries
Retaining records	All the personal information we collect about you on or connected to our CCTV system	It is a legitimate interest to retain records

We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.

3. Who we share your personal information with

We share your personal information with the following parties:

• Suppliers and service providers: to manage and operate the CCTV system as our data processor.

• Joint data controllers: who may jointly operate and maintain the CCTV system with us.

• The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people and investigate alleged criminal activities.
• The security services: where relevant for matters of national security.

• People who have been injured, attacked or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.

• People who have been involved in road traffic accidents and their insurance providers: to assist with insurance claims, legal claims and investigations.

• Private and other investigators: to aid their investigations.
• Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives, and this includes but is not limited to the Information Commissioner’s Office.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

4. Transferring your personal information internationally

In limited circumstances the people to whom we may disclose personal information from our CCTV system as mentioned in section 3 above may be located outside of the UK and European Economic Area. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

5. How long do we keep your personal information for

We will keep your personal information for up to approximately 35 days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will usually be overwritten. However if we receive an enquiry about a particular recording on our CCTV we will generally then retain that part of the recording until it is no longer required, and we will also retain details of the enquiry. This period can vary as it will depend upon the circumstances of the particular case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be many years. As soon as it is no longer required we will then delete the personal information.

ANYONE ELSE WE INTERACT WITH - “REST OF THE WORLD”

This section applies to anyone else who is not covered by one of the other sections above (and who is also not an existing employee/worker/officer of ours or a potential employee/worker/officer we are looking to recruit). This section will therefore cover for example suppliers, contacts at suppliers and members of the general public who may interact with us.

1. Personal information we collect

We may collect the types of personal information about you as set out below. However not all types of information may be relevant, and it will depend on the nature of our relationship and interactions with you:



• Contact details: information that allows us to identify and contact you directly such as your name, address email address, telephone number and addresses.
• Identification information: passport and other official identification details, information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes, construction industry scheme number and details.
• Details of your work history: This includes may include positions, roles, responsibilities, professional qualifications.
• Personal history and information: This includes hobbies, interests, marital status, family details and dietary requirements.

• Advisors appointed by you: including but not limited to, lawyers, financial advisors, surveyors.
• Business information: including information about your business and the products/services it provides, property owned by you, transactions, amounts paid or owed and tenants.

• Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
• Creditworthiness: We may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you or the organisation you work for.
• Details of your performance: when working with or for us or in relation to any project or work we are engaged in.

• How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.

• Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.

• Your usage of the IT systems we make available to visitors to our premises: for example our customer internet and Wi-Fi facilities.

• Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.

• Subscription information: for example when you subscribe to one of our blogs or other materials.

• IP address information: your computer’s IP address allows us to track your usage of our website.

2. Special categories of personal information

We do not generally collect, store and use any of the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;

• information about your trade union memberships;

• information about your health, including any medical condition, health and sickness records, medical records and health professional information; and

• biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information, and usually in the limited cases where any special category information is processed by us it will be for legal compliance reasons or to establish, defend or bring legal claims.

We will also not generally collect, store and use any criminal records information in relation to you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information and would only process it for legal compliance reasons.

3. Sources we collect your personal information from

We will collect personal information from a number of sources. These may include the following:

• Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.

• Your landlord: such as a housing association, rental business, property investor or other landlord where they have purchased a property from us

• From referrals and recommendations: usually given by other people who know you or have a working relationship with you.

• Our website or social media: our website provides us with information about how you use it and the devices that you use to connect to our website and you may alsovisit or use our social media platforms.

• Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms.

• Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.

• Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.

• Our professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
• Your professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.

• The Government, local authorities or relevant regulators: to assist with investigations, for example the Information Commissioner’s Office or applications to the local authority.

• We will also collect additional personal information throughout the period of our relationship with you.
• If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section above.

4. What we use your personal information for

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

Purpose	Personal information used	Lawful basis
Carrying out identity and credit checks	Name, identity details and contact details and payment information	We may have a legal obligation to undertake identification We also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid
Enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties	All the personal information we collect	To enter into and perform contracts with either yourself or the organisation that you represent We have a legitimate to properly perform contracts with third parties
Maintain and improve our services and/or products	All the personal information we collect	We have a legitimate interest to improve the services and/or products we provide
Provision of our website and online portals, carrying out data analytics, statistical analysis and other research to help us improve our online services	Any data we collect when you use our website	We have a legitimate interest to provide our website and any online portals We have a legitimate interest to improve the online services we provide and user experience for our website and online portals
Security of our IT systems	All the personal information we collect	We have a legitimate interest in ensuring the security of our IT systems
Staff training	All the personal information we collect	We have a legitimate interest to improve the products and services we provide
Direct marketing	Contact details and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past	We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively if you or your organisation has purchased similar services or products from us previously we may market similar products or services as a legitimate interest in developing our business. You have the right to opt out from such marketing at any time
Holding events	Your contact details, details of attendance, your comments in response forms and dietary requirements	We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements
To manage our relationship with you or the organisation you work for and to operate and manage our business and internal reporting	All the personal information we collect	We have a legitimate interest to operate our business in an efficient way and to expand our business To enter into and perform contracts with either yourself or the organisation that you represent
Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the organisation you work for	All the personal information we collect	This may be necessary to perform a contract with you or the organisation that you represent We have a legitimate interest to improve the services and/or products we provideWe have a legitimate interest to improve the services and/or products we provide To defend, bring or establish
To comply with our legal and regulatory obligations	All the personal information we collect	To comply with any legal and regulatory obligations or requirements
Storage of records relating to you and also records relating to our business	All the personal information we collect	To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

5. Who we share your personal information with

We may share personal information with the following parties:

• Organisations in the same group as us: in relation to joint events or joint work.
• Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain.
• Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
• Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
• Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns
• Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
• Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
• The Government, local authorities, planning authorities or relevant regulators: where we are required to do so by law or to assist with their investigations, for example the Information Commissioner’s Office.
• Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

6. How long do we keep personal information for

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:

• For individual contacts at customers and suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 10 years afterwards so that it ties in with the duration of the structural guarantee provided on homes.
• For marketing contacts it will generally be a period of 6 years after we were last in contact with you.
• For website users it will generally be a period of 6 years after you used our website.

For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years.

• For individuals attending an event it will generally be a period of 2 years after the event.

It is important to ensure that the personal information we hold about you is accurate and up-todate, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section above.