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WHITMAN AND CO - PRIVACY POLICY

1. Our contact details

Name: Whitman and Co
Address: 5-7 Turnham Green Terrace, London, W4 1RG
Phone Number: 020 87478800
E-mail: info@whitmanandco.com 

2. What type of information do we collect and process?

We currently collect and process the following information:

Personal identifiers, contacts and characteristics. These may include:

Identity Data: includes first name, maiden name, last name, employment status, marital status, title, date of birth and gender.

Contact Data: includes home address {previous, current and forwarding), email address and telephone numbers.

Property Data: includes type, number of rooms, locks, energy usage, easements, keys, utility meter information, services records, insurance documents and mortgage documents.

Financial Data: includes bank account details.

Transaction Data: Includes card payment details & details about payments to and from you. Other details of products and services you may have purchased from us.

Technical Data: includes Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Usage Data: includes information about how you use our website, products and services.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Data is also collected and used when you:

a.         register a password-protected account,

b.         fill in forms on our Website, third-party websites and Portals which send information to us,

c.         visit in person via our branch,

d.         via telephone calls, emails, live web chat, and social media.
            This information can include, but is not limited to, personal information (name, address, email address and telephone number); financial or employment information that you disclose when agreeing to register as an applicant or enter a transactional relationship with us.

3.        Information required to help us ensure our staff are safe when attending external appointments such as viewings and market appraisals; for example, contact details for the client or customer, including a residential address in the UK.

4.         Information required to comply with legislation such as Right to Rent checks required under section 22 of the Immigration Act 2014 if you are renting a property and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (more commonly referred to as the Money Laundering Regulations 2017) which Is a legal requirement for a number of our Services.

5.         lnformation to enable us to tailor our marketing and communications to you, based on your personal preferences, such as the types of service you are looking for, the location of your search area, the budget you are willing to spend etc.

6.         We may also ask you to complete surveys, either on our own Website or through a third-party provider, which we use for research purposes; although you do not have to respond to them.

7.         When you visit or otherwise access our Website, details including but not limited to: -

            a.         information about the device and browser (hereafter ‘Device’) you are using to access the Website e.g. type, version, operating system, etc.,
            b.         traffic data including the URL of the website that referred you to our website if applicable,
            c.         location data including geolocation (this can be explicitly controlled on your Device),
            d.         weblogs and other communication data,
            e.         the resources that you access including social media interaction,
            f.          your IP (Internet Protocol) address,
            g.         the date and time of the visit and how long you remained on our Website,
            h.         the pages visited on our Website and interactions performed.

How we collect information

We collect information in the following ways:

•           in person via our branch office,
•           by telephone,
•           by post,
•           by SMS,
•           by email,
•           live web chat,
•           social media use such as Facebook and Twitter.
•           via our Website,
•           via third party websites,
•           via property portals.

Why do we have this information and what do we use it for?

Improving our products and services: we will use your personal information to understand your requirements and to personalise the properties and services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate interests in providing better products and services for you.

Processing your transaction: we use relevant personal information described above (including your name, address and financial details) to enable us to complete a transaction with you when you are using any of our services. This information may require to be passed on to third parties, including but not limited to solicitors, surveyors, financial advisors etc.

Preventing fraud: we will also use your personal information to assess your creditworthiness (in the case of buying or renting a property) and to prevent fraud. For this purpose, we may need to share your personal information with our referencing providers and/or solicitors. This is necessary for the purposes of our legitimate interests in ensuring we are not the victim of fraud and to protect our legal rights.

To provide customer support: if you contact our team (or vice versa), we will use personal information such as your email address, phone number and residential address as well as your contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract or if it is required for us to comply with any legal obligations. If it is not necessary to process our personal data for either of these reasons, we will process it as it is necessary for the purposes of our legitimate interest in ensuring we can provide the best service possible.

Marketing: When you register your details with us for any of our services, or enter into a transaction with us, provide feedback on our service online or use our Website; we will use your personal information to send you relevant and proportionate marketing communications about our properties, services, and third-party providers.
You have the right to ask not to process your personal data for marketing purposes, to alter your preferences for the type of marketing content you receive (such as properties for sale, information about related services etc.) or to alter the methods via which you receive marketing correspondence from us (i.e. via email, text, post or phone call).
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 contacting us.

Who do we share it with? 

We treat your personal information with care and confidentiality and do no share it with third parties other than as set out below:

            With Service Providers

            Where required we may share limited personal information you provide when you register with us or enter into a transaction with us, as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf (Data Processors), such as;

            Lettings 

            Including but not limited to tenant referencing agencies, other estate agents or landlords, contractors and property maintenance services, gas and electrical contractors, utility companies and insurance providers.

            Sales 

            Including but not limited to Solicitors/Conveyancers, Surveyors, Financial/Mortgage advisors, other estate agents in a chain, Developers where a purchase is agreed, contractors and property maintenance services.

            Software and system providers including but not limited to:

            Vebra Alto, Webdadi, BriefYourMarket

            Website hosts and analytics platform providers including but not limited to:

            Webdadi, BriefYourMarket, Good Analytics

We require that these service providers and other third parties adhere to strict rules when processing your personal information, including to only use your personal information in accordance with our specific instructions (such as for the purposes of completing referencing or contacting you to arrange access to carry out necessary repairs) and the applicable laws.

How long do we store your information for and where is it kept? 

The length of time we hold your information for will vary dependent on the lawful basis for collecting and processing the data.
We will hold data supplied where there is a legitimate interest in doing so (such as where a client or customer has registered with us, expressing an interest in any of our Services such as buying, selling, letting or renting a property through us) for a period of 7 years.

Where a transaction has been entered in to and there is a contractual necessity to do so, or where there is a requirement to comply with legal obligations (for example in order to comply with the requirements of the TPO Codes of Practice, both for Sales and Lettings Agents, to maintain clear and full written records of transactions for a period of six years and to comply with the Money Laundering Regulations 2017 requirement to hold records for a period of 5 years).

If you have an Account on our Website and it has been deemed dormant then we may delete the Account and all personal information “tied to" or “held against' it. We consider an Account to be dormant if one of the following conditions is met:

            it has not been accessed by you for more than 5 years (7 max),
            if you have not responded to any emails sent to the registered email address,
            if we receive email delivery failure notifications in response to any email sent to the registered email address,
            the Account is in breach of our Terms of use.

STORAGE 

All information you provide to us is stored in the UK on our secure servers and all paper-based information is also securely stored in the UK.

By submitting your personal data to us, you agree to this transfer, storing or processing.

Your data protection rights

            Your right to access - You have the right to ask us for copies of your personal information.

            Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

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

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

            Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

            Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You have the right to ask us not to process your personal data for marketing purposes, to alter your preferences for the type of marketing content you receive (such as properties for sale, information about related services etc.) or to alter the methods via which you receive marketing correspondence from us (i.e. via email, text, post or phone call).

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 contacting us at any time.

Our Website may, from time to time, contain links to and from the websites of our partners and third-party service providers. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Use of third-party websites is at your own risk.

You have the right to request a copy of the information we have for you, known as a ‘Subject Access Request'.

All requests should be made in writing to:

Whitman and Co, 5-7 Turnham Green Terrace, London, W4 3DP

Updates to our policy 

We review our privacy statement in order to ensure that it is free of errors and clearly visible on our Website, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites along with an updated version of the privacy statement.

How to make an official complaint to the ICO

You can complain to the ICO if you are unhappy with how we have used your data.

The ICO's address:

information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number. 0303 123 1113