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Privacy Policy

This Privacy Policy sets out how we, Douglas Martin Estate Agents Ltd, collect, store and use information about you when you use or interact with our website, http://www.douglasmartin.co.uk/ (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from [INSERT DATE] 2018.
 
Contents
  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • Information we collect when you place an order
  • Our use of automated decision-making and profiling
  • How we collect or obtain information about you from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • California Do Not Track Disclosures 
  • Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Douglas Martin Estate Agents Ltd

  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us, placing an order with us or signing up to receive information about relevant properties),
    • from your use of our website, using cookies, and
    •  from third parties.

  • Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable).

  • How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.

  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.

  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.


  • Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law.

  • Use of automated decision making and profiling: we use profiling on our website through our use of Google Analytics. For further information, please see the section below entitled Our use of automated decision-making and profiling.

  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority

  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
 
Our details

The data controller in respect of our website is Douglas Martin Estate Agents Ltd (company registration number: 0518365) of Harben House, Harben Parade, Finchley Road, London NW3 6LH. You can contact the data controller by writing to Douglas Martin Estate Agents Ltd, Harben House, Harben Parade, Finchley Road, London NW3 6LH or sending an email to enquiries@douglasmartin.co.uk.
If you have any questions about this Privacy Policy, please contact the data controller.
 
Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
 
Web server log information

We use a third party server to host our website called Webdadi, the privacy policy of which is available here: https://www.webdadi.com/privacy. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in and accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

We do not access log data from our website server collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.


Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential and analytical cookies. For further information on how we use cookies, please see our cookies policy which is available here: https://www.douglasmartin.co.uk/cookies
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is our website hosting provider, Webdadi. Their privacy policy is available here: https://www.webdadi.com/privacy
Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in the United Kingdom.

Contact form

When you contact us using our contact form, we collect your name, address, email address, telephone number and IP address. We also collect any other information you provide to us when you complete the contact form in the message field.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored within the European Economic Area on our third party hosting provider’s servers in the United Kingdom. Our third party hosting provider is Webdadi. Their privacy policy is available here: http://www.douglasmartin.co.uk/privacy
 
Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).


Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider.

Information about your phone call will be stored by our third party telephone service provider within the European Economic Area. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
 
Property newsletter and registration on our website

When you sign up for our property newsletter and register to create an account on our website by registering below, we collect your title, first name, last name, telephone number, email address, address, criteria for your property search, chosen areas for properties and password (we do not view your password).

We also collect your mobile number if you provide it.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use third party services to send out our e-newsletter and administer our mailing list, including Webdadi and/or Jupix. Their privacy policies are available via the following links:  https://www.webdadi.com/privacy and http://jupix.com/privacy-policy/.  Your information is stored within the European Economic Area in the United Kingdom.

Information we collect when you request estate agent services from us

We collect and use information from individuals who request estate agent services from us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

We collect your name, phone number, email address, billing address (and your address if different from your billing address) company name (if applicable) and VAT number (if applicable).

Depending on the service you have requested that we provide you, we may also collect and process credit references, deposit related information and bank evidence.

If you do not provide this information, we will not be able to provide you with our estate agent services.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations and ensuring we have the necessary information to be able to perform our services, including liaising with third parties.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): ensuring we have all of the information we require or which are required by third parties so that we can provide you with our services quickly and efficiently.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

 
Processing your payment

When you make payment for our services, we will process your payment using a third party payment processor called WorldPay.

WorldPay collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s):

https://www.worldpay.com/uk/privacy-policy

Transfer and storage of your information

Worldpay (UK) Limited is located in the UK but they may transfer information relating to the processing of your payment outside the European Economic Area including to their group companies such as Worldpay Limited, Worldpay BV and Worldpay AP Limited. Where WorldPay transfers your personal information outside of the European Economic Area, they will ensure appropriate safeguards are in place.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

 
Marketing communications

When you purchase services from us you will have the option of receiving marketing communications from us.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email by ticking a box indicating that you would like to receive such communications, signing up to receive marketing communications or requesting that we send you information about relevant properties (as the case may be).

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

Information you submit to subscribe for our e-newsletter will be stored on our third party website hosting provider’s servers. Our website hosting provider is Webdadi. Their privacy policy is available here:
https://www.webdadi.com/privacy

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include Rightmove and Zoopla, the privacy policies of which are available via the following links:


It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details and information relating to one or more properties (and addresses), but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one) and property websites including Rightmove and Zoopla.

In certain circumstances will also obtain information about you from private sources, both EU and non-EU.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of automated decision-making and profiling

We use profiling on our website through our use of Google Analytics. We do not consider that this has any legal effect on you or similarly significantly affects you. We do not use automated decision making.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here:

https://www.douglasmartin.co.uk/cookies

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.


Use of profiling for web analytics

Our web analytics service, Google Analytics, collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy (https://www.douglasmartin.co.uk/cookies).

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies) and your location will be analysed based on your IP address.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest: we have a legitimate interest in getting to know our website visitors’ preferences and improving our website’s effectiveness.
 
Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Telephone provider,
  • Email providers,
  • IT service and software providers,
  • Web developer,
  • Hosting provider, and
  • Online property marketing sites.

Our third party service providers are located in the United Kingdom.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the United Kingdom.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and similar professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Our accountants are located in the United Kingdom.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Our business partners are located in the United Kingdom.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.

Our accountants are located in the United Kingdom.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our accountants are located in the United Kingdom.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest(s)
: sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.
 
For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). 

Legal obligation(s)
: legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we do not retain server log information after it has been processed.

Order information: when you order services from us, we retain that information for as long as you are a client of ours and then for a further seven years for tax purposes and to for the purposes of defending against legal claims.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 12 further months, after which point we will delete your information.

E-Newsletter and property updates: we retain the information you used to sign up for our e-newsletter or property update service for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service or property update service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information; and
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
 
Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here:

 https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 
Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Douglas Martin Estate Agents, Harben House, Harben Parade, Finchley Road, London, NW3 6LH  or sending an email to enquiries@douglasmartin.co.uk:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
 
How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Douglas Martin Estate Agents, Harben House, Harben Parade, Finchley Road, London, NW3 6LH  or sending an email to enquiries@douglasmartin.co.uk:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message; or
  • sending an email to enquiries@douglasmartin.co.uk, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://www.douglasmartin.co.uk/cookies

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.


Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to enquiries@douglasmartin.co.uk.

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as cookies to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://www.douglasmartin.co.uk/cookies
 
Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.






Cookies Policy


This Cookies Policy sets out the basis on which we, Douglas Martin Estate Agents Limited, use cookies and similar technologies on or in relation to our website, http://www.douglasmartin.co.uk/ (our website). This Cookies Policy is effective from [DATE] 2018.


‘Essential’ cookies are automatically placed on your computer or device when you access our website or take certain actions on our website. ‘Non-essential’ cookies and other technologies are only placed on your computer or device if you have consented to us doing so. For information on the difference between essential and non-essential cookies, see the section below entitled About cookies.


For information on how you consent and how you can withdraw your consent to us placing non-essential cookies and other technologies on your computer or device, see the section below entitled How to accept or reject cookies.


Contents


  • About cookies
  • List of cookies used
  • Essential cookies
  • Non-essential cookies
  • How to accept or reject cookies
  • Copyright

 

About cookies


What are cookies?

Cookies are small data files sent by a website’s server to a web browser, processor memory or hard drive and stored there. They can be used for a range of different purposes, such as customising a website for a particular user, helping a user navigate a website, improving that user’s website experience, and storing that user’s preferences and login information.

 
Essential and non-essential cookies

Cookies can be classified as either ‘essential’ or ‘non-essential’.
Essential cookies: these are cookies that are either:
  • used solely to carry out or facilitate the transmission of communications over a network; or
  • strictly necessary to provide an online service (e.g. our website or a service on our website) which you have requested.

Non-essential cookies: these are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (‘analytical’ cookies) or cookies used to display advertisements to you (‘advertising’ cookies).

 

Session and persistent cookies


Cookies can be classified as either ‘session’ or ‘persistent’, depending on how long they last after they are placed on your browser.

Session cookies: session cookies last for as long as you keep your browser open. They expire when you close your browser.

Persistent cookies: persistent cookies expire at a fixed point in time or if you manually delete them from your browser, whichever occurs first.

First and third party cookies


Cookies can be classified as ‘first party’ or ‘third party’.

First party cookies: these are cookies placed on your device by our website domain.

Third party cookies: these are cookies placed on your device by third party website domains.

If you require further information about cookies in general, please visit www.allaboutcookies.org

List of cookies used

We use the following cookies on or in relation to our website:

Name of Cookie
Essential or Non-essential?Type of cookieFirst or Third party?Session or Persistent?Expiry TimePurpose
ASP.NET_SessionIdEssentialEssentialFirst partySessionEnd of browser sessionPreservers user’s state for the duration of their browser session
_utmaNon-essentialAnalyticalFirst partyPersistent2 yearsGoogle Analytics cookie used to collect information on the number of times a user has visited the website
_utmbNon-essentialAnalyticalFirst partySessionEnd of browser sessionGoogle Analytics cookie used to record the time when a user accesses a website (for the purpose of calculating the duration of the user’s visit)
_utmcNon-essentialAnalyticalFirst partySessionEnd of browser sessionGoogle Analytics cookie used to record the time when a user leaves the website (for the purpose of calculating the duration of the user’s visit)
_utmtNon-essentialAnalytical (functional)First partySessionEnd of browser sessionGoogle Analytics cookie used to manage (throttle) number of requests received from users to Google’s servers
_utmvNon-essentialAnalyticalFirst partySessionEnd of browser sessionGoogle Analytics cookie used to save custom parameters about a user
_utmzNon-essentialAnalyticalFirst partyPersistent6 monthsCollects information on user source and search engine related information including search term and links clicked

 

Essential cookies

These are cookies which are strictly necessary for our website to be able to operate or to provide you with a service on our website which you have requested. We use the following essential cookies on our website:
  • a first party session cookie to remember information you input across the website and allow you to remain logged in to areas of the website (i.e. to preserver your ‘state’ during a browsing session). This cookie is called ASP.NET_SessionId

Legal basis for processing: we process information about you contained in or obtained from essential cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests:
ensuring our site functions properly and providing you with online services you have requested.

How to opt out of essential cookies

Most browsers allow you to block all cookies, including essential cookies. Please note, however, that if you block all cookies, parts of our website and its functionality may not work or display properly.

You can delete existing cookies from your browser by clearing your browsing data and ensuring that the option to delete cookies is selected.

For more detailed information on how to accept and reject cookies, including guidance for specific browsers, please see the section below entitled How to accept or reject cookies

 

Non-essential cookies


We use the following types of non-essential cookies on our website:

  • Analytical (or performance) cookies
  •  

Analytical (or performance) cookies


Analytical (or performance) cookies track and gather data about what a user does on a website. These cookies are not essential for our website or its functionality to work. We use the following analytical cookies on our website:
  • Google Analytics cookies. Google Analytics cookies help us understand how you engage and interact with our website, including how you came to our website, which pages you visited, for how long and what you clicked on, your location (based on your IP address).
  • The Google Analytics cookies used on our website are: _utma, _utmb, _utmc, _utmt, _utmv, _utmz. These cookies include both session and persistent cookies. _utma and _utmz are both persistent cookies expiring after 2 years and 6 months respectively. The other Google Analytics cookies are session cookies.
  • The information we collect using Google Analytics cookies is collected on an anonymised basis.
More information

Google Analytics cookies are classified as first party cookies as they are set by our website domain, although Google collects and processes information from our use of Google Analytics. To find out more about how Google handles information collected from Google Analytics, see Google Analytics’ privacy policy, which is available here: https://support.google.com/analytics/answer/6004245

For information on how Google uses data from cookies it uses, please visit www.google.com/policies/privacy/partners/


How to opt in or out from analytical cookies

See the section below entitled How to accept or reject cookies

To opt out of Google Analytics tracking across all websites in general, you can do so here: http://tools.google.com/dlpage/gaoptout

Processing information about you contained in or obtained from analytical cookies

Legal basis for processing: we process information about you contained in or obtained from analytical cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: analysing how individuals use our website to help us improve our website and business. For further information on how we use the information gathered from our use of analytical cookies, including profiling, please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: http://www.douglasmartin.co.uk/privacy

 

How to accept or reject cookies


There are a number of different ways in which you can accept or reject some or all cookies. Some of the main methods of doing so are described below:

You are welcome to block the use of some or all of the cookies we use on our website. However, please be aware that doing so may impair our website and its functionality or may even render some or all of it unusable.

You should also be aware that clearing all cookies from your browser will also delete any cookies that are storing your preferences, for example, whether you have accepted cookies on a website or any cookies that are blocking other cookies.

You can find more detailed information about cookies and adjusting your browser settings by visiting www.allaboutcookies.org

Accepting or rejecting cookies

Cookie control tool

You can accept or reject non-essential cookies by using our cookie management tool: [insert description of how your cookie control tool works and how a user can turn on or off different types of cookies]
Browser settings

You can accept or reject some or all cookies (for example, blocking all third party cookies) by adjusting your browser settings. If you do not know how to do this, the links below set out information about how to change your browser settings for some of the most commonly used web browsers:


Some browsers, such as Chrome and Firefox, allow you to change your settings to browse in ‘incognito’ mode, limiting the amount of data placed on your machine and automatically deleting any persistent cookies placed on your device when you finish your browsing session. There are also many third party applications which you can add to your browser to block or manage cookies.

Existing cookies

To clear cookies that have previously been placed on your browser, you should select the option to clear your browsing history and ensure that the option to delete or clear cookies is included when you do so.

Google Analytics Opt-out Browser Add-on

You can opt out of Google Analytics tracking by installing the browser add-on which is available here: http://tools.google.com/dlpage/gaoptout

Copyright

The copyright in this Cookies Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.