Welcome to the Coombe Residential privacy notice.
Coombe Residential Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
You can download a pdf version of the policy here.
This version was last updated on 25/05/2018
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Coombe Residential Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you enquire about a property.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Coombe Residential Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice). We are a company incorporated in England and Wales and our company registration number is 04496526.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entity: Coombe Residential Limited
Email address: email@example.com
Postal address: 259 Coombe Lane, Wimbledon, London, SW20 0RH
Telephone number: 0208 947 9393
Fax number: 0208 944 6484
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
In Schedule 1 we have set out, in table form, a description of the different types of personal data we may collect, use, store and transfer. See Schedule 1 for further details.
We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of personal data about you (which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), and we do not collect any information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to market your property (if we are a seller) or provide you with details of the properties in which you are interested (if you are a buyer). In this case, we may have to cancel our agreement with you, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect personal data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you ask us to sell your property or make an enquiry about a property you are interested in buying, arrange an appointment or make an offer, create an account on our website, subscribe to our service or publications, request marketing to be sent to you, enter a competition, promotion or survey, give us some feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may also receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- (a)Search information and analytics providers such as Google and Bing, based inside or outside the EU; and
- advertising networks such Facebook, Instagram, Twitter, LinkedIn, Pinterest, Google and Bing based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as [FCC PARAGON] based inside or outside the EU.
- Identity and Contact Data from property portals such as RightMove or Zoopla, or other intermediaries, based inside or outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. Purposes for which we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you, namely to market your property or to provide you with information about a property or properties in which you are interested.
- Where we need to comply with a legal or regulatory obligation to which we are subject, otherwise than under the contract we are about to enter into or have entered into with you, such as our contract with the person to whom you are selling or from whom you are buying the property, our reporting obligations to H M Customs & Excise or our obligations under the Money Laundering Regulations.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
In Schedule 1 below we have set out, in a table format, a description of all the ways we plan to use your personal data, and on which of the legal bases we rely in order to do so. Where the table indicates that we are relying on our “legitimate interests”, or those of a third party we have, where appropriate, also identified what those legitimate interests are. See Schedule 1 for more details.
Please note that we may process your personal data in the above circumstances without your knowledge or consent, where this is required or permitted by law.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what properties may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us and have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by following opt-out links on any marketing message sent to you or by contacting us at any time at firstname.lastname@example.org or calling us on 0208 8947 9393.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with a transaction you have already entered into with us.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish us to explain how we consider the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes described in Schedule 1 below with external third parties such as:
- Applicants registered with us, whom we think may be interested in buying or renting your property, and their professional advisers;
- External service providers, based in the United Kingdom, such as Square Feet Ltd who take photographs, including aerial photographs, Floorplanners Ltd who prepare floor plans and JJP Green Energy who assess energy performance and issue energy performance certificates, for the purposes of the brochures and websites which will be used to promote your property; and Mays Floorplanns who supply us with all the above services.
- The seller(s) of the property(ies) which you are interested in buying or renting, and their professional advisers;
- Reapit Limited, based in the United Kingdom, which provides customer relationship management software and other software and services to many of the UK's largest estate agents, and provides a comprehensive property portal review and guide;
- Creditsafe a company which we use to carry out our anti-money laundering obligations.
- Other professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- External service providers who provide IT and system administration services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- [FCC PARAGON a company which are a Tenant Referencing company ]
- TDS, a government approved deposit protection services for landlords, agents, and tenants.
We may also disclose your data to third parties to whom we may wish to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We may need to transfer your personal data for the purposes set out in Schedule 1 with buyers or sellers of properties or their professional advisers, or with external third parties, outside the European Economic Area (EEA), in order to perform the contract we are about to enter into or have entered into with you on their behalf.
Some of our external service providers may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Subject to this, we do not transfer your personal data to countries outside the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for tax purposes for at least six years after they cease being clients. Accordingly, we generally keep client information for seven years from then. If you contact us to make an enquiry without becoming a client, we will delete the information we hold about you after three years.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Data protection laws gives you a number of rights in relation to your personal data, including the right to ask us to delete it in specified circumstances. These rights, and how to exercise them, are described in more detail in Schedule 2.
TYPES OF PERSONAL DATA, AND LEGAL JUSTIFICATION FOR HOW WE WILL USE IT
In the table below, we use the following abbreviations:
Type of data
1 = Identity Data such as first name, maiden name, last name, username or similar identifier, marital status, title, age, date of birth and gender.
2 = Contact Data such as billing address, delivery address, email address and telephone numbers.
3 = Financial Data such as bank account and payment card details.
4 = Transaction Data includes details about the location and price of the property or properties in which you are interested, the total purchase price, what mortgage you require, and what payments will be due from you and when.
5 = Technical Data about the devices you use to access this website, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and other technology on the devices you use to access this website..
6 = Profile Data such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, how you found out about us and what you typed into Google or other search engines to find us.
7 = Usage Data such as information about how you use our website, products and services and about your visits to and use of our website including your referral source, length of visit, page views and website navigation.
8 = Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
Legal justification for processing
A = We process your Personal data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
B = We process your Personal data because it is necessary for compliance with a legal or regulatory obligation to which we are subject.
C = We process your Personal data because it is necessary for the legitimate interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal data for our legitimate interests. We do not use your Personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client||1, 2||A|
|To process and deliver your order including: (a) Deliver the services you order from us (b) Send statements and invoices (c) Manage payments, fees and charges (d) Collect and recover money owed to us||1, 2, 4, 8||A, C (to recover debts due to us)|
|To enable you to partake in a prize draw, competition or complete a survey||1, 2, 6, 8||A, C (to study how clients use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, dealing with enquiries and complaints made by or about you relating to the website, data analysis, testing, system maintenance, support, reporting and hosting of data, security and fraud prevention)||1, 2, 5||B, C (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|To improve your browsing experience by personalising the website and delivering relevant website content and advertisements to you, to enable your use of the services available on the website, and to measure or understand the effectiveness of the advertising we serve to you||1, 2, 5, 6, 7, 8||C (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, client relationships and experiences||5, 7||C (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||1, 2, 5, 6, 7||C (to develop our products/services and grow our business)|
YOUR LEGAL RIGHTS
You have the following rights with regard to the Personal data we hold about you, namely the right to:
(a) Request access to your Personal data (commonly known as a "subject access request").
This enables you to receive a copy of the Personal data we hold about you and to check that we are processing it lawfully.
(b) Request correction of the Personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your Personal data.
This enables you to ask us to delete or remove Personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your Personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your Personal data
This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your Personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your Personal data.
This enables you to ask us to suspend the processing of your Personal data where:
(i) you want us to establish the data's accuracy;
(ii) our use of the data is unlawful but you do not want us to erase it;
(iii) you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your Personal data to you, or to a third party you have chosen, in a structured, commonly used, machine-readable format.
This applies only where you initially provided the Personal data to us in electronic form and (i) we needed to use it to perform a contract with you, or (ii) we are relying on your consent to process the Personal data.
(g) Withdraw consent at any time
This is relevant only where we are relying on such consent to process your Personal data. It will not affect the lawfulness of any processing carried out before you withdraw your consent and it will, of course, not affect the lawfulness of any processing which is not reliant on your consent. Please note that, if you withdraw a consent on which we are relying, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above, please contact us.
1. You will not have to pay a fee to exercise any of the above rights. However, we may refuse to comply with a subject access request access or, alternatively, may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive.
2. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
3. We try to respond to all legitimate requests within one month but, if your request is particularly complex or you have made a number of requests, it may take us longer. In this case, we will notify you and keep you updated.
4. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.