Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes ofthe GDPR. Our use ofyour personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms:

We, us, our	Loromah Estates Ltd
Contact person for Data Protection	Maria Turner Email: info@loromah.co.uk Tel: 0207 837 620
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

Personal data we collect about you

What is personal information?

Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.

Some personal information is classified as “special” data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.

Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.

What personal information do we collect?

We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.

In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

We will also confirm whether you have any relatives or close connections working at Loromah Estates Ltd so that we can consider potential conflict of interests and if identified how to manage these, in accordance with our statutory and regulatory obligations.

Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;

Rent

If you are renting a property through us

• We will collect a telephone number to get in touch with you about organising viewings.

We will also need to obtain the following details:

• Specific access requirements so that we can find a property which is suitable for your needs.
• Your bank! building society details in order to allow us to manage all approved tenancy deposit account for you and to set up your rental payments
• If you are a tenant renting under the ‘Right to Rent’ scheme we will collect details of your biometrics residence card, your immigration status document and,/or your birth certificate to carry out the required checks under the scheme.

How we use your personal information

What is the legal basis of our data processing?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;

for employment-related purposes

where we need information to perform the contract we have entered into with you

where we need to comply with a legal obligation

where the processing is necessary for us to carry out activities for which it is in Loromah Estates Ltd’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:

• where the processing is necessary for us to carry out activities for which it is in Loromah Estates Ltd’s legitimate interest ( or those of a third party) to do so and provided that your interest and fundamental rights do not override those interest, including:
• Processing that is necessary to improve our knowledge of the real estate sector— this will include undertaken market analysis and research so that we better understand trends in the property sector and provide better knowledge along with some more tailored and relevant services for customers in the future.
• Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively — this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.

In more limited circumstances we may also rely on the following legal bases:

• where we need to protect your interests (or someone else’s interests); and/or
• where it is needed in the public interest or for official purposes

We may process special categories of personal information and criminal conviction information in the following limited circumstances:

• With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

How we use your personal information

For specific information on how your personal information will be used for the services you have requested from us, please select from any of the options below;

Rent

• We use your personal information for the purposes of fulfilling our obligations to you for the purposes of arranging a lease for you.
• We will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property.

Other uses of your personal information

• If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
• We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
• Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We may share your personal information with any person working within Loromah Estates Ltd on a need to know basis to ensure we are able to perform our obligations to you.
• We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Savills to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

What happens if you do not provide information that we request?

We need some of your personal information to perform the services you have requested from us. For example;

We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.

If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.

How we keep your information secure

The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

• Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
• Hard copy documentation is stored in locked cabinets.

For how long do we keep your personal information secure

The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

As a standard guide, all tenancy agreements, Council Tax, records, Personal ID and references will be retained for 7 years.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:

• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the matter in which we are advising you.

These transfers are subject to special rules under European and UK data protection law.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• complete a data subject request form, which is available from our Maria Turner
• email, call or write to Maria Turner—see below: ‘How to contact us’; and
• let us have enough information to identify you eg your full name, address and client or matter reference number
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was published on 24 May 2018

We may change this privacy policy from time to time, when we do we will inform you via email and by notice on our website.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details	Our Data Protection Officer’s contact details
Loromah Estates 94 Richmond Avenue lslington London Ni OLU	Maria Turner Email: info@loromah.co.uk Tel: 020 7837 6202

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).