INTRODUCTION

Welcome to Regent’s privacy policy.

Regent respects your privacy and is committed to protecting your personal data. This privacy policy 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.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1 Important information and who we are

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how Regent collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us.

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 policy together with any other privacy statements we may provide on specific occasions when we are collecting or processing personal data about you, for instance in our Terms of Business, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

1.2 Controller

Regent Letting and Property Management Limited is the controller and responsible for your personal data (collectively referred to as Regent, “we”, “us” or “our” in this privacy policy).

We have appointed a Compliance Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Compliance Manager using the details set out below.

1.3 Contact details

Our full details are:

Full name of legal entity: Regent Letting and Property Management Limited

Name or title of data privacy manager: Compliance Manager

Email address: Dataprotection@regent-property.com

Postal address: 6th Floor, Tower Building, 11 York Road, London, SE1 7NX

Telephone number: 02087439101

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.

1.4 Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 15th May 2018.

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.

1.5 Third-party links

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 policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2 The data we collect about you

2.1 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).

2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

2.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, nationality and gender.

2.2.2 Contact Data includes billing address, delivery address, email address, telephone numbers and any previous addresses provided by you.

2.2.3 Financial Data includes bank account details.

2.2.4 Transaction Data includes details about payments to and from you.

2.2.5 Technical Data includes internet protocol (IP) address, your login data, 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 this website.

2.2.6 Usage Data includes information about how you use our website.

2.3 If you fail to provide personal data

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.

3 How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1 Direct interactions -You may give us your Identity, Contact and Financial Data, and nationality information by filling in forms or by corresponding with us by post, phone, email or otherwise.

3.2 Automated technologies or interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

3.3 Third parties or publicly available sources – We may receive personal data about you from third parties and public sources as set out below:

3.3.1 companies in the Regent Group or external companies based outside the EEA;

3.3.2 social media platforms, such as LinkedIn, WhatsApp and WeChat;

3.3.3 property search engines and websites such as Zoopla and Rightmove;

3.3.4 the Land Registry website; and

3.3.5 the EPC Register.

3.4 Technical Data from the following parties:

3.4.1 analytics providers such as Google based outside the EU; and

3.4.2 advertising networks such as Google ads or Facebook ads based outside the EU.

3.5 Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as banks or Goodlord.

3.6 Identity and Contact Data from data brokers or business acquisitions.

3.7 Identity and Contact Data from publicly availably sources such as Companies House.

4 How we use your personal data

4.1 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:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.

4.1.2 Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

4.1.3 Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data, but when we do, you will have the right to withdraw consent to marketing at any time by contacting us.

4.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 contact you regarding a property enquiry you have made (a) Identity (b) Contact Necessary for our legitimate interests.
To collect your proof of address documentation (a) Identity (b) Contact Necessary to comply with a legal obligation
To manage and progress a tenancy (a) Identity (b) Contact Necessary to comply with a legal obligation
To prepare a tenancy agreement (a) Identity (b) Contact Performance of a contract with you.
To request and review tenant references (a) Identity (b) Contact (c) Photograph Performance of a contract with you.
To forward any mail at the end of the tenancy and update utility suppliers, if necessary (a) Identity (b) Contact Necessary for our legitimate interests.
To carry out identification and right to rent checks on tenants Identity (including passport) Necessary to comply with a legal obligation.
To carry out identification checks on landlords Identity (including passport) Necessary to comply with a legal obligation.
To check a property’s details on the Land Registry website Identity Necessary to comply with a legal obligation.
Processing your bank account details (a) Identity (b) Bank details Performance of a contract with you.
To send out our newsletter (a) Identity (b) Contact (a) Necessary for our legitimate interests (b) Your consent
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity (b) Contact (a) Performance of a contract with you (b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business)

4.3 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

4.4 Change of purpose

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 to get an explanation as to how 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5 Disclosures of your personal data

5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

5.1.1 Internal Third Parties as set out in the Glossary.

5.1.2 External Third Parties as set out in the Glossary.

5.1.3 The new owner of a property of which you are a tenant, in the event that property is sold.

5.1.4 Specific third parties such as contractors, utility suppliers, solicitors, regulatory bodies, mortgage companies, local authorities, the police, surveyors, debt collectors, movers and leasehold management companies.

5.1.5 Third parties to whom we may choose 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 policy.

5.2 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

6.1 We may share your personal data with a company that is under common control with us or with a third party referral company. This may involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

7 Data security

7.1 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.

7.2 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 we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

9 Your legal rights

9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

9.1.1 Request access to your personal data.

9.1.2 Request correction of your personal data.

9.1.3 Request erasure of your personal data.

9.1.4 Object to processing of your personal data.

9.1.5 Request restriction of processing your personal data.

9.1.6 Request transfer of your personal data.

9.1.7 Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

9.2 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.3 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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.

9.4 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10 Glossary

10.1 Lawful Basis

10.1.1 Legitimate Interest means the interest 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.

10.1.2 Performance of Contract means processing your data where it is necessary for us to do so, either when there is an existing contract between you and us and that processing is necessary for us to be able to perform that contract, or when you are about to enter into a contract with us.

10.1.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.2 Third Parties

10.2.1 Internal Third Parties

A company that is under common control with us (based in Hong Kong) and provides us with referrals of Hong Kong or China-based landlords who have purchased a property in London.

10.2.2 External Third Parties

(a) Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

(b) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

(c) Third party companies based outside the EEA.

10.3 Your Legal Rights

You have the right to:

10.3.1 Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.3.2 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.

10.3.3 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.

10.3.4 Object to processing of your personal data 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.

10.3.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.3.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

10.3.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.