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Privacy Policy

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PRIVACY POLICY for www.trisara.co.uk

Privacy Policy and Notice – March 2019

Please read the following information carefully. We are committed to ensuring that your privacy is protected. This privacy notice, together with our Terms and Conditions and any other notice referred to in it, explains how we collect and use your personal data when you visit our website or use our services.

This privacy notice was last amended in March 2019 and supersedes any earlier version. We constantly review our internal privacy practices and this policy will be reviewed as a minimum, six-monthly. If any changes are made to this policy we will inform you by email.

Who we are:

Trisara Consultants UK Ltd. (here-in referred to as TCUK) are a company with offices located London in the UK. TCUK are primarily involved in development, construction, renovation, sale, auction, letting and acquisition of property and land in London and the South East of England.

Data Controller:

Trisara Consultants UK Ltd. with Registered offices at 126 Wigmore Street, London, W1U 3RZ (a company registered in England & Wales with registration number 07461319)
Email: dataprotection@trisara.co.uk / Tel: +44 (0) 207 305 7193

Trisara Consultants UK Ltd. (TCUK) collects, uses and is responsible for personal information about you. When we do this we are the ‘controller’ of this information for the purposes of the General Data Protection Regulation and other applicable data protection laws.

Our Data Protection Officer is:

Email: dataprotection@trisara.co.uk / Tel: +44 (0) 207 305 7193

1. Personal data we collect

As a business we collect, use, store and transfer different types of personal data depending on who you are.

If you are purchasing, renting, selling or letting a property through TCUK, or purchasing, renting, selling or letting a property from one of our clients, we collect and use your personal data to provide you with our services. The personal data we collect and use may include:

o Identity Data (name, marital status, title, date of birth, gender, username and password, purchases made by you, your interests and preferences, property ownership details or other evidence of your ability to sell or let the property, references, credit checks, details of your immigration status, feedback and survey responses)
o Contact Data (billing address, delivery address, email address and telephone numbers)
o Financial Data (bank account and payment details)
o Transaction Data (details about payments to and from you and other services you have purchased through us)
o Technical Data (internet protocol address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, identification number, online identified, location data and other similar identifying information required for the customer’s device(s) to communicate with websites and applications on the internet)
o Usage Data (how you use our website products and services, the full uniform resource locators clickstream to, through and from our site (including date and time), download errors, lengths of visit to certain pages, page interaction information, methods to browse away from the page and any phone numbers you use to call us)
o Marketing and Communications Data (your marketing preferences from us and our third parties and your communication preferences)
o Call recordings (recordings of your conversations with us)

We also may collect and use Aggregated Data. For example, when you visit our website we may aggregate data about your usage to tell us about how certain features on our website are used. This is not usually classified as personal data as whilst it derives from personal data (in the example, it is derived from your Usage Data) it does not reveal your identity to us. If we do link this Aggregated Data to your personal information, it will be treated as personal data in line with this policy.

2. How we collect personal data

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

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o apply for our services;
o create an account on our website;
o subscribe to our service or publications;
o request marketing to be sent to you;
o contact us through social media;
o walk-in to our branch offices or telephone our call centre;o enter a competition, promotion or survey; or
o give us some feedback; or
o speak with us on the telephone and we record the call

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources, for example:

o Contact, Financial and Transaction Data from providers of payment services based inside the EU.
o Identity and Contact Data from data brokers or aggregators such as Rightmove, Zoopla (based inside the EU, or Facebook (based outside the EU)
o Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.o Credit referencing agencies

3. How we use your personal data

We use your personal data for the purposes shown in the table below. We will only use your personal data for the purposes for which we collected it. If we need to process your personal data for a different purpose that is not compatible with the original purpose we will let you know.

We may process your personal data for a different purpose without your consent where it is necessary for us to comply with our legal obligations.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To contact you

 

 

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (for running our business, to recover debts due to us, to keep our records updated and to study how customers use our products/services)

 
To carry out our obligations arising from any contracts entered into between you and us and to provide with you the information, products and services you request from us

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (for running our business and to recover debts due to us)

 

 
To provide you with information about other goods and services that we offer which we feel may interest you
  • Identity
  • Contact
  • Technical Usage
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

 
To permit selected third parties:
• to provide you with information about goods or services which we feel may interest you
• to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website
  • Identity
  • Contact
  • Technical Usage

 

 
  • Consent (in relation to SMS and email marketing communications)
  • Necessary for our legitimate interests (to develop our service offering)

 

 
To assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website

 

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications
  • Call Recordings
  • Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services, for training and monitoring of our customer service standards and to help resolve disputes

 

 
To notify you about changes to our service

 

 
  • Identity
  • Contact

 
  • Performance of a contract with you
  • Necessary to comply with our legal obligations
  • Necessary for our legitimate interests (to keep our records updated)
To ensure that content from our website is presented in the most effective manner for you and your computer

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)

 
To verify your identity

 

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Necessary to comply with our legal obligations
  • Necessary for our legitimate interests (for running our business and to prevent fraud and money laundering)

 
As part of our efforts to keep our site safe and secure and to prevent or detect fraud

 

 
  • Identity
  • Contact
  • Financial
  • Transaction
  • Necessary to comply with our legal obligations
  • 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)
To provide customer support

 
  • Identity
  • Contact
  • Performance of a contract with you

 
To facilitate and to enable you to partake in a property viewing, open house event or visits to property marketing suites

 
  • Identity
  • Contact

 
  • Performance of a contract with you
  • Necessary for our legitimate interests (for running our business and to develop and grow our business)
To comply with the requirements imposed by law or any court order

 
  • Identity
  • Contact
  • Technical Usage
  • Necessary to comply with our legal obligations

 
Where you have viewed through us, we may disclose your name to a landlord or vendor where we have been dis-instructed, in order to avoid a potential commission dispute

 
  • Your name

 

 
  • Necessary for our legitimate interests (to protect our entitlement to a commission and to avoid commission disputes wherever possible)

 
We may disclose tenant references and any forwarding address to a landlord

 
  • Identity
  • Contact
  • Necessary for our legitimate interests (to help protect our landlord customers’ legal rights)
Marketing

You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. You also have the right to withdraw consent for us to pass your information to third parties for marketing purposes. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.

You can ask us to stop sending you marketing messages at any time by:

o following the opt-out links on any marketing message sent to you; or
o contacting us at any time by emailing unsubscribe@trisara.co.uk or by calling +44 (0) 207 305 7193.

Where you withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations.

If you no longer wish to be contacted by third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies about how to unsubscribe.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside TCUK for marketing purposes.

Cookies

The TCUK website and applications may automatically collect data about how you use our services in order to help us improve future functionality of our website and to assist with advertising and targeting. We use Google Analytics, which is a web analysis service provided by Google.

The cookies on the TCUK website do not track, collect or upload data such as your name, email address or billing information, but it may collect data about your equipment and browsing activities. We may collect and report on the adoption and usage of specific features, crashes and exceptions and other useful, anonymous metrics.

Certain devices can detect your approximate location, via latitude and longitude. The accuracy of this data is not in the control of TCUK. If this feature is requested, TCUK will prompt you to provide your permission to access your location data for the purposes of providing you with results or directions based on your current location. You can disable location settings within your browser or app.

To read more about our use of cookies on the www.trisara.co.uk and consult our cookie policy.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the “How we use your Personal Data” table above. We have agreements in place with our third parties that restrict their use of your personal data. We only allow third parties to use your personal data for specified purposes and in accordance with our instructions.

Category Explanation
External Third Parties

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 For Sales or Auction – for the purpose of processing an offer, negotiation, agreeing the sale of property or land – it is assumed that the buyer and/or their mortgage lender will require access to your property to undertake a valuation and/or survey. A minimum of details will be supplied such as the full property address and the contact telephone number for you so that they can arrange an appointment.

For buyers – during the course of any offer negotiation or when a sale is agreed we will pass both seller and buyer personal details to their respective solicitors. Full chain details of your name and address will be provided to other solicitors in the chain, and sometimes to other estate agents in the chain. Your phone numbers, emails addresses and proof of identity documents will not be passed to those contacts.

Tenants Referencing is undertaken by our agents Kingsley Hamilton Estates. The tenant applicant’s full contact details and date of birth will provided. The Tenants provide their own employment information to TCUK and as part of completing the application form direct to Kingsley Hamilton Estates. Landlord and Letting Agent information where applicable will be passed to Kingsley Hamilton Estates. Kingsley Hamilton Estates may contact you about the other services that they provide if you consent for them to do so.

Landlord and Tenant contact details will be passed to a tenancy deposit administrator such as the Deposit Protection Scheme (DPS) or to mydeposits, 3rd Floor, Kingmaker House, Station Road, New Barnet, Hertfordshire EN5 1NZ

We may forward your present and future contact details to utility suppliers, local authorities and credit or reference providers, including for the purposes of debt recovery.

Where you are a landlord or a vendor we may forward your personal data to HM Land Registry for proof of property ownership purposes.

Property developers acting as Processors or independent controllers based in the UK who process your personal data in order to arrange or facilitate your visit to their marketing suite.

Advertisers and advertising networks (including social media) that require the data to select and serve relevant adverts to you.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accountancy services.

HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Service providers acting as processors based in the United Kingdom who provide IT and system administration services, anti-money laundering service providers and services to enable us to perform our contract with you, or carry out surveys to help us improve our services.
Other Third Parties

 

 

 Sometimes there may be 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 notice.
5. Data security

We are, through technical and organisational means, committed to ensuring the security of, and prevention of unauthorised access to, your personal data. For example, we limit who can access your personal data to those individuals and third parties who need to know it and who are subject to a duty of confidentiality. If we become aware of a data breach we will, where we are required to, notify the Information Commissioner’s Office. If we believe that the data breach is serious, we may notify you as well.

6. International transfers

We will not transfer your personal data outside of the European Economic Area, except to a country offering the same level of protection for your personal data. For example, with certain service providers we may use specific contracts approved by the European Commission which ensures that your personal data has the same protection as it would have in Europe.

7. Data retention

We will retain your personal data whilst you use our services (or whilst we provide services connected to you) and for at least seven years thereafter, for legal, regulatory and accounting purposes. If we need to retain your personal data for longer, we will take into consideration the potential risks in continuing to store your data against why we might need to keep it. In some circumstances we might anonymise your personal data so it is not associated with you, and we may then use this information indefinitely.

8. Your legal rights

To Under the General Data Protection Regulation you have a number of right which you can exercise, free of charge. These rights are:

  • Access a copy of the personal data that we hold and process about you. You have rights to the following information:
    o the purpose(s) for which we are processing your information;
    o the categories of personal information we hold about you
    o the recipients or categories of recipient to whom the personal data have been or will be disclosed;
    o the period for which we will store your information, or the criteria used to determine that period;
  • Object to the use of your personal data (including for marketing purposes) by
    o clicking the link to unsubscribe in the email footer or on our website homepage; or
    o by ticking the relevant boxes on the data collection forms; or
    o by emailing unsubscribe@trisara.co.uk; or
    o by writing to: Data Protection Officer, Trisara Consultants UK Ltd., 126 Wigmore Street, London W1U 3RZ.

Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions:

o rectification of any inaccurate information we hold about you;
o erasure of the personal data we hold about you (in certain situations);
o ask that we do not make decisions about you using completely automated means; and/or
o ask that personal data we hold about you is, where technically feasible, transmitted to a third-party chosen by you, in a commonly used, machine-readable format.

The rights listed above may not apply in certain circumstances. Therefore we may not always be able to comply with your request. We will tell you if this is the case.

If you require further information about your rights under the GDPR please see the Guidance from the Information Commissioners Office: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/

We will usually respond to a request from you to exercise your rights within one month of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests.

How to make a complaint:

We hope that you are happy with our service and that our Data Protection Officer can resolve any issues or complaints that arise. Please get in touch if you have any concerns (see ‘How to contact us’ below).

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

If you do have a complaint about the way in which your personal data has been processed and you contact the Information Commissioner’s Office you may be required to first complete our internal complaints procedure.

9. How to contact us

To contact us about how we handle your personal data, please contact our Data Protection Officer at dataprotection@trisara.co.uk. Alternatively, write to us at Data Protection Officer, Trisara Consultants UK Ltd., 126 Wigmore Street, London W1U 3RZ.