Privacy Policy
How your personal information is used by Just Mortgages and the Just Mortgages family of companies…Your information will be held electronically by Spicerhaart Group Services Limited, which is a processor of information for our trading names such as haart, Felicity J Lord, Chewton Rose, Haybrook, Darlows, Butters John Bee, B.C.Holt, Howards, Just Mortgages, Spicerhaart Corporate Sales, Land & New Homes and Valunation which are trading brands owned by the Spicerhaart Group.Further information on our group of companies can be found at www.spicerhaart.co.uk
Introduction
This Privacy Policy forms part of Spicerhaart Group Services Limited (“Spicerhaart”) obligation to be open and fair with all individuals whose personal data we process and to provide details around how we process such personal data and what we do with it.Spicerhaart is committed to safeguarding the privacy of personal data and complying with the European General Data Protection Regulation (2016/679) and the Data Protection Act 2018, and any future changes in data protection legislation with which Spicerhaart will be required to comply.When selling, purchasing, renting or financing a property (including surveying services) through our group we process your personal data such as name, address, contact details, email address and passport amongst other things. Processing of this data implies collecting, storing, using or disclosing your personal data.If You consent to be notified of, or receive other products or services from Spicerhaart, or use any of our websites, You may be provided with further privacy notices which may be contained in a separate policy or within any terms and conditions. These additional privacy notices shall supplement this Privacy Policy.This Privacy Policy relates to the processing of personal data by Spicerhaart and any of its subsidiaries and high street brands. Unless otherwise stated, all references to “we” or “our” shall imply all Spicerhaart lines of business that process personal data.None of the lists or examples provided in this Privacy Policy is intended to be exhaustive or fully representative of every individual.Scope
The scope of this Privacy Policy covers client personal data in respect of the following:- Ways we use your Personal Data
- Definitions of Personal Data types
- Collecting Personal Data
- Using Personal Data
- Fraud Protection Agencies (FPAs)
- Disclosing Personal Data
- Retaining Personal Data
- Securing Personal Data
- Sharing Personal Data
- International Data Transfer
- Data Subject Rights
- Updates / Amendments
- Third Party Websites
- Consents (“Opt-in”)
- Withdrawal of Consent (“Opt-out”)
- Our Details
- Ways we use your Personal Data
- a) as necessary to perform and fulfil our contracts with You:
- to take steps at your request prior to entering into it;
- to exercise rights set out in agreements or contracts;
- to deliver our products and services;
- to update our records;
- to make and manage customer payments;
- to manage fees and charges due on customer transactions;
- to collect and recover money that is owed to us.
- b) as necessary to comply with legal obligation, e.g.:
- to verify your identity, make credit, fraud prevention and anti-money laundering checks;
- to manage risk for Us and our customers;
- to detect, investigate, report and seek to prevent financial crime;
- to run our business in an efficient and proper way;
- to manage how we work with other companies that provide products and services to Us and our customers.
- c) as necessary for our own legitimate interests, or those or other persons and organisations, e.g.:
- to respond to complaints and seek to resolve them;
- to run our business in an efficient and proper way;
- to develop and manage our brands, products and services;
- to manage how we work with other companies that provide products and services to Us and our customers;
- to monitor emails, calls, other communications and activities with reference to your contract;
- d) based on your consent, e.g:
- to manage our relationship with you;
- to develop new ways to meet our customers’ needs and to grow our business;
- to develop and carry out marketing activities;
- to provide advice or guidance about related products and services.
- You are free at any time to change your mind and withdraw your consent. The consequence might be that we can’t do certain things for You.
Definitions of Personal Data types
We use various kinds of personal information, and group them together like this.- Type of Personal Information
- Description
- Contact
- Where You live and how to contact You.
- Consent
- Any permissions, consent or preferences that You give Us, including how You would like Us to contact You.
- Financial
- Your financial position, status and history.
- Contractual
- Details about the products and services we provide to You.
- Behavioural
- Details about how You use our products and services.
- Communications
- What we learn about You from conversations, emails and letters between Us.
- Social Relationships
- Your Family, friends and other relationships.
- Open Data and Public Records
- Details about You that are in public records such as the Electoral Register and information about You that is openly available on the internet.
- Usage Data
- Other data about how You use our products and services.
- Documentary Data
- Details about You that are stored in documents in different formats, including copies. This could include things like your passport, drivers licence, birth certificate or utility bill.
- Socio-demographic
- This includes details about your work or profession, nationality, education and where You fit into general social or income groups.
- National Identifier
- A number or code given to You by a government to identify who You are, such as a National Insurance number or Passport Number.
Collecting Personal Data
We may collect and store the following kinds of personal data:Information that You provided to Us when applying through our website, during visits to branch offices, in emails or over the phone.- Information contained in or relating to any communication that You send to Us through our website, email, in writing, using Live Chat or over the phone.
- Information that You provide to Us when using any services we provide, or that is generated during the use of those services.
- Information that You provide as part of electronically signing agreements with Us.
- Information that You provide in performing anti-money laundering, financial and credit checks as well as for fraud and crime prevention and detection purposes.
- Information to help Us comply with court orders and to exercise and defend our legal rights.
- Any other personal information that may be sent to Us and which we use for legitimate business purposes.
- Information shared as part of our competitions or promotions.
Data from third parties we work with:
- Companies that introduce You to Us (property portals for example)
- Public information sources such as Companies House
- Financial Advisors • Land agents
- Comparison websites • Agents working on our behalf
- Social networks • Market researchers
Using Personal Data
We may use your personal information to:Enable your use of any services that we may provide through our websites or third-party websites.- Supply You with our products and services.
- Send You marketing communications.
- Deal with enquiries and complaints.
- Perform money laundering, financial and credit checks.
- We may need to confirm your identity before we provide products or services to You or your business. Once You have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help Us with this.
- Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed for either of Us to obey the law, or for a ‘legitimate interest’.
- Disclosing Personal Data
- We only disclose your personal data in the ways set out in this Privacy Policy or subject to any agreements in place between Us. The following circumstances may apply:
- To third parties’ with whom information is shared for anti-money laundering checks, credit risk reduction, debt collection and other fraud and crime prevention purposes.
- To any regulator, external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation.
- To any central or local government department and other statutory or public bodies, such as HMRC.
- We do not sell, rent or trade any of your personal data.
- We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party’s direct marketing.
- Retaining Personal Data
- The following criteria are used to determine data retention periods for your personal data (whether or not You become a customer):
- Retention in case of queries – we will retain your personal data as long as necessary to deal with your queries (e.g. if your potential transaction is unsuccessful);
- Retention in case of claims – we will retain your personal data for as long as You might legally bring claims against Us; and
- Retention in accordance with legal and regulatory requirements – we will retain your personal data after your contract or service with Us has come to an end based on legal and regulatory requirements.
- Securing Personal Data
- Where Spicerhaart acts as the controller of personal data, it will ensure that necessary and adequate safeguards (e.g. encryption) are in place to prevent unauthorised access, loss, misuse or alteration of your personal data.
- Where data is stored electronically we store all personal information on secure servers with relevant access and firewall controls.
- Where data is stored on paper or forms all personal data is locked away when not in use, and disposed of securely after use either using document shredders or third-party disposal organisations who have been contracted to dispose of documents appropriately.
- Any personal data sent to Us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.
- Where You use a Password to access any service provided by Spicerhaart this must be kept confidential and not disclosed to anyone else. Spicerhaart does not ask You for your password.
Sharing Personal Data
To provide the services to You we may share the personal data that You supply with several third parties:- SmartSearch Limited who are used to undertake anti-money laundering checks, Politically Exposed Person (PEP) and sanctions checks.
- Docusign Inc who are used to undertake the electronic digital signing of agreements.
- Glanty Limited who are used for new let administration and self-service tenancy portal services.
- Tenant Shop Limited who are used for lettings related utility switching services.
- Property Inventory Management Limited who are used for lettings related property visit and inventory services.
- Rex Labs Limited (UK) who provide case and customer management software.
- Cronofy Limited who provide a cross platform calendar synchronisation solution.
- giosg.com Limited who provide online chat services for our websites.
- Rightmove Group Limited who advertise properties online.
International Data Transfers
Personal data that we collect, is predominantly stored and processed in the UK, but for specific services may be transferred, stored, processed outside of the EU (designated under GDPR as “Third Countries”).As part of providing our services to You under an agency agreement we will use third party data processors from Third Countries as outlined below:- Docusign Inc which is based in the USA.
- Shergroup Limited whose services are based in India.
Log Files and Statistics
Spicerhaart may use IP addresses, URLs of requested resources, timestamps and HTTP user agents to administer the system, analyse trends and gather broad demographic information for aggregate use.In addition to this we may use third party services to monitor your use of our website, including Google Analytics, a web analytics service provided by Google, Inc (‘Google’). This information allows Us to track how many visitors we have, how often they visit and where they originated from. It also gives the ability to gather which terms were used when searching for properties.Data Subject Rights
Your rights are as follows (noting that these rights don’t apply in all circumstances):- The right to be informed about our processing of your personal data;
- The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
- The right to object to processing of personal data;
- The right to restrict processing of your personal data;
- The right to have your personal data erased (the “right to be forgotten”);
- The right to request access to your personal data and information about how we process it;
- The right to move, copy or transfer your personal data (“data portability”); and
- Rights in relation to automated decision making including profiling.
- You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law: www.ico.org.uk