PRIVACY POLICY
Privacy Policy – Charlotte Brown Property
Who we are, what we do, and how we process your data
Charlotte Brown Property ("we", "us" or "our" in this privacy notice) is a real estate search agent specialising in acting for potential buyers and renters of residential property in prime London locations and related research, negotiations, introductions, inspections and such other assistance as clients may require in connection with the same.
Charlotte Brown Property is a trading name of Charlotte Brown.
Our contact details are:
Mobile: + 44 (0) 7760 193 856
Office: + 44 (0) 20 8677 6940
Email: info@charlottebrownproperty.com
Web: charlottebrownproperty.com
We act as a controller of personal data and are responsible for your personal data in connection with our activities.
Changes to the privacy policy and your duty to inform us of changes.
We keep our privacy policy under regular review. This version was last updated on 28 October 2022.
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.
Your rights
You have these rights:
• to get a copy of the personal information we hold about you;
• to question any information we have about you that you think is incorrect, so that we can take reasonable steps to check and correct it;
• to share your data with outside companies, as a digital file, so that you can keep and use it yourself, or give it to other organisations;
• to object to us keeping or using your personal data;
• to ask us to delete, remove or stop using your personal data if there is no need for us to keep it; and
• to restrict the use of your data, so that it can only be used for certain things, such as legal claims or to exercise legal rights.
There may be legal or other official reasons why we need to keep or use your data.
Making a complaint.
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.
If you do not provide 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.
We will notify you if this is the case at the time.
How to withdraw your consent
You can withdraw your consent at any time. Please contact us by email at info@charlottebrownproperty.com if you want to do so. This will only affect the way we use information when our reason for doing so is that we have your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. This will not affect the lawfulness of our use of the data before your consent was withdrawn.
The type of personal data that we collect and use
We may collect, use, store and transfer different kinds of personal data about you,
as follows.
Identity: Including first name, maiden name, last name, username or similar identifier, marital status, religious beliefs, title, date of birth and gender, national insurance number, tax reference.
Contact: Including home address, company address, email address and telephone numbers.
Financial: Including bank account and payment card details.
Transactions: Including details about payments to and from you and other details of products and services we have provided to you.
Technical: Including 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.
Profile: Including your username and password, your interests, preferences, feedback and survey responses.
Usage: Including information about how you use our website.
Where do we get your personal data from?
We use different methods to collect data from and about you including through:
Direct interactions. You may provide us with your personal data by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
· Contact, Financial and Transaction Data from lawyers, lenders, and others in connection with you, your assets and debts
· Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
COOKIES
Details of the types of cookies which our website uses can be found here.
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.
How we use your personal data
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:
1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal or regulatory obligation.
Purposes for which we 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 engage you as a new client | (a) Identity (b) Contact (c) Finacial |
Performance of a contract with you |
| To analyse our enquiries received | (a) Transactions (b) Technical |
Managing and conducting our business in order to provide you with services |
| To analyse market trends | (a) Transactions (b) Technical (c) Usage |
Managing and conducting our business in order to provide you with services |
| To progress your purchase or rental by liaising with agents, mortgage advisers or contractors, as may be required in connection with our relationship with you | (a) Identity (b) Contact (c) Profile (d) Financial (e) Transaction |
Performance of a contract with you |
| To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy |
(a) Identity (b) Contact (c) Profile (d) Financial (e) Transaction |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
| To provide marketing materials to you | (a) Identity (b) Contact (c) Profile |
Providing marketing materials to you |
| Type of third party | Country in which they are based | Service provided / need for disclosure |
|---|---|---|
| Lawyers | United Kingdom | Legal services |
| Lenders | United Kingdom | In connection with borrower debts |
| Bankers | United Kingdom | Banking services |
| Accountants | United Kingdom | Accounting services |
| Auditors | United Kingdom | Accountancy services |
| Insurers | United Kingdom | Insurance services |
| HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers, law enforcement and fraud prevention agencies | United Kingdom | Require reporting of processing activities in certain circumstances |
| Agents | United Kingdom | Valuation, auction, removal, relocation and other service providers relating to the services we are providing to you |
Disclosing your personal data to others
We may have to share your personal data with the parties set out below for the purposes set out in the table marked “Purposes for which we use your personal data” above.
How we work out what marketing you receive
We use marketing to let you know about products, services and offers that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organisations we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
If you change your mind you can contact us to update your choices at any time.
How we use your information to make automated decisions
We do not currently use systems to make automated decisions about you.
Credit Reference Agencies (‘CRAs’)
We may carry out credit and identity checks when you apply for a product or services for you or your business, and when you are using our services. We may use Credit Reference Agencies to help us with this.
We will share your personal information with CRAs and they will give us information about you. This data includes:
· name, address and date of birth of you or your officers or members;
· your credit application;
· your financial situation and history;
· fraud prevention information; and
· public information, from sources such as the Electoral Register and Companies House.
We use this data to assess your application, including the accuracy of the information you have provided, as well as to manage our relationship, trace and recover debts, tell you about relevant offers and to help and detect financial crime.
We will go on sharing your personal information with CRAs for as long as you are a customer.
Sending data outside the United Kingdom (the ‘UK’)
We will only send your data outside of the UK to comply with a legal duty, to engage with you if you are located outside of the UK, or to work with our suppliers in providing products and services to you.
If we do transfer your personal information outside the UK, we will ensure that a similar level of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
