Whirledge & Nott Limited trade as Whirledge & Nott (we/us). Our company number is 079891217 and our registered office is The Black Barn, Lubards Farm, Hillbridge Road, Rayleigh, Essex SS6 9QG. We offer a range of property services to land owners, investors, developers, occupiers, the public sector and charities.
Which personal data do we use about you?
We collect and use your personal data to the extent necessary in the framework of our activities and to achieve a high standard of personalised products and services. Depending upon the type of product or service we provide to you, we may collect various types of personal data about you, including
- Identification information, such as full name, date and place of birth, gender and photograph
- Contact information, such as postal address, email address and phone number
- Family situation, such as marital status and number of children • Economic, financial and tax information, such as tax ID, tax status, income and value of your assets
- Education and employment information, such as level of education, employer’s name and remuneration
- Banking, financial and transactional data, such as bank account details, credit card number, money transfers, assets, declared investor profile, credit history, debts and expenses
- Data relating to your habits and preferences relating to your use of our products and services such as your interactions with us from our website or our social media pages
- Video surveillance, such as CCTV
- Connection and tracking data, such as cookies
- Data necessary to fight against over indebtedness, fraud, money laundering and proceeds of crime
We never ask for personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning your sexual orientation, unless it is required through a legal obligation.
The data we use about you may either be directly provided by you or be obtained from the following sources in order to verify or enrich our databases:
- Publications or databases made available by official authorities
- Third parties such as credit reference agencies or fraud prevention agencies
- Website or social media pages containing information made public by you, such as your own website or social media
- Databases made publicly available by third parties
Specific cases of personal data collection including indirect collection
In certain circumstances, we may collect and use personal data of individuals with whom we have, could have, or used to have a direct relationship, prospects for example.
For some reasons we may also collect information about you, even where you have no direct relationship with us. This may happen for instance where your employer provides us with information about you or your contact details are provided by one of our clients if you are, for example:
- Family members
- Legal representatives (power of attorney)
- Beneficiaries of payment transactions made by our clients
- Beneficiaries of insurance policies and trusts
- Ultimate beneficial owners
- Clients’ debtors (in the case of bankruptcy)
- Company shareholders
- Representatives of a legal entity (which may be a client or a vendor)
- Staff of service provider and commercial partners
Why and on which basis do we use your personal data
We use your personal data to comply with our legal obligations, including real estate regulations, banking and financial regulations in compliance with which we:
- Set up security measures in order to prevent abuse and fraud and to detect transactions which deviate from the normal patterns
- Reply to an official request from a duly authorised public or judicial authority
- Prevent money laundering and financing of terrorism
- Comply with legislation relation to sanction and embargoes
- Fight against tax fraud and fulfilment of tax control and notification obligations
We use your data to perform a contract with you or to take steps at your request before entering into a contract.
We use your personal data to enter into and perform our contracts, which includes providing you with information regarding our products and services, to assist you and answer your requests, to evaluate if we can offer you a product or service and under which conditions and to provide products or services to our corporate clients of whom you are an employee or a client.
We use your data to fulfil our legitimate interest in order to:
Deploy and develop our products or services, to improve our risk management and to defend our legal rights, including proof of transactions, fraud prevention, IT management, business continuity and IT security, train our staff, improve the quality of our products and services.
We may advertise products or services that match with your situation and profile which can be achieved by:
- Segmenting our prospects and clients
- Analysing your habits and preferences in the various channels (emails or messages, visits to our website etc)
- Matching the products or services that you already hold or use with other data we hold about you
- Monitoring transactions to identify those which deviate from the normal routine
Who do we share your personal data with?
We only disclose your personal data to:
- Contractors who are instructed by us, sometimes on your behalf, to carry out works, repairs and the like to your property;
- Independent agents, intermediaries or brokers, banking and commercial partners, with which we have a regular relationship;
- Financial or judicial authorities, arbitrators and mediators, state agencies or public bodies upon request and to the extent permitted by lay;
- Certain regulated professionals such as lawyers, notaries or auditors.
How long do we keep your personal data for?
We will retain your personal data for the longer of the period required in order to comply with applicable laws and regulation or another period with regard to our operational requirements, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. For instance, most of client’s information is kept for the duration of the contractual relationship and 10 years after the end of the contractual relationship. For prospects, information is kept for 3 years.
What are your rights and how can you exercise them?
In accordance with applicable regulations, you have the following rights:
- To access: You can obtain information relating to the possession of your personal data and a copy of such personal data
- To rectify: where you consider that your personal data is inaccurate or incomplete, you can require such personal data be modified accordingly
- To erase: you can require the deletion of your personal data to the extent permitted by law
- To restrict: you can request the restriction of the processing of your personal data
- To object: you can object to the processing of your personal data, on grounds relation to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
- To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
- To data portability: where legal applicable, you have the right to have the personal data you have provided to us to be returned to your or, where technically feasible, transferred to a third party.