1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive digital marketing communications. You can access the privacy controls via the 'update your details' or 'unsubscribe links' at the bottom of any emails from Easthaus or you can email us at email@example.com.
1.5 In this policy, "we", "us" and "our" refer to Easthaus Limited. For more information about us, see Section 17.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number and / or postal address. The source of the contact data is you.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.4 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Publications - We may process data such as sales and lettings property details and content for our journal for the purposes of publishing such data on our website and elsewhere through our services in accordance with your instructions. The legal basis for this processing is consent.
3.3 Relationships and communications - We may process contact data such as your name, email address, telephone number and / or postal address for the purposes of managing our relationships and communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4 Marketing communications - We may process contact data for the purposes of creating and sending digital marketing communications by email only. The legal basis for this processing is consent.
3.5 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.6 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.7 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.8 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 We may disclose contact data along with any relevant property information to third parties such as photographers, solicitors, joint agents and in the case of lettings properties, maintenance contractors where necessary for the purpose of proper administration of business and communications with users.
4.4 For letting applicants, we may provide your personal data (including name, date of birth, property address and passport or other identification document details) to Goodlord who provide tenant referencing and TrustID who provide digital identification verification, where such processing is necessary for compliance with a legal obligation to which we are subject and for the proper administration of our business and communications with users.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2 We use Webflow to host our website. Webflow’s servers are located in the United States which means their data is stored, processed and transferred in the United States. Webflow uses approved data transfer mechanisms to transfer your Personal Information in and out of the United States and other jurisdictions. Webflow relies on European Commission–approved Standard Contractual Clauses as a legal mechanism where required for any data transfers from the U.S. to a country outside the UK, EU, EEA, or Switzerland to the extent that any such transfers occur. We have completed a Data Processing Agreement with Webflow and are confident that they are committed to GDPR compliance. Webflow only stores the information you provide to us via the contact form on our website. You may ask for this data to be removed at any time by emailing firstname.lastname@example.org.
5.3 We use Mailchimp to deliver our marketing emails regarding new properties for sale and to let and local area and property updates. Mailchimp’s servers and offices are located in the United States which means their data is stored, processed and transferred in the United States. Mailchimp uses approved data transfer mechanisms to transfer your Personal Information in and out of the United States and other jurisdictions. They process such data in compliance with the standard contractual clauses between controllers annexed to the European Commission's Implementing Decision 2021/914 of 4 June 2021, or the equivalent clauses adopted by the UK Government, and currently located here (https://mailchimp.com/legal/controller-controller-scc-2021/) (the “Controller-to-Controller Clauses”). We have completed a Data Processing Agreement with Mailchimp and are confident that they are committed to GDPR compliance. EastHaus only provides Mailchimp with your email address and you may update your preferences or unsubscribe by clicking the update preferences or unsubscribe links at the bottom of any emails we send you via Mailchimp.
5.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.6.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 6 years following the most recent contact between you and us.
(b) transaction data will be retained for a minimum period of 6 years following the date of the transaction.
(c) communication data will be retained for a minimum period of 6 years following the date of the communication in question.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In these cases we will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. You can contact us by emailing email@example.com or by writing to us at Easthaus, Ground Floor Shop, 30c King Edward’s Road, E9 9SF.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.1 We do not use any cookies on our website
13. Cookies used by our service providers
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15.1 We may update this policy from time to time by publishing a new version on our website.
15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
15.3 We may notify you of significant changes to this policy by email.
16. Our details
16.1 This website is owned and operated by Easthaus Limited.
16.2 We are registered in England and Wales under registration number 10275389, and our registered office is at The Oast Emr Centre, New Road, East Malling, Kent, England, ME19 6BJ.
16.3 Our principal place of business is at Ground Floor Shop, 30c King Edward’s Road, London E9 7SF.
16.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephoning us on 020 3176 1270
(d) by emailing us at firstname.lastname@example.org
17. Easthaus Complaints Procedure
We are committed to providing aprofessional service to all our clients and customers. If, at any point, you are unhappy orconcerned about the service we have provided, please tell us immediately so that we can do our best to resolve the problem quickly and professionally.
In the first instance, it may be helpful to contact the person who is dealing with your transaction to discussyour concerns and we will do our best to resolve any issues. If this does not resolve the matter and you wish to make a formal complaint, please put this in writing, including as much detail as possible and send to email@example.com
What will happen next?
We will send you a letter acknowledging receipt of your complaint within three working days of receiving it, enclosing a copy of this procedure.
We will then investigate your complaint. This will normally be dealt with by the Office Manager who will review your file and speak to the member of staff who dealt with you. A formal written outcome of our investigation will be sent to you within 15 working days of sending the acknowledgement letter.
If, at this stage, you are still not satisfied, you should contact us again and we will arrange for a separate review to take place by a director.
We will write to you within 15 working days of receiving your request for a review, confirming our final viewpoint on the matter.
If you are still not satisfied after the last stage of the in-house complaint procedure (or more than 8 weeks has elapsed since the complaint was first made) you can request an independent review from The Property Ombudsman without charge.
The Property Ombudsman contact details areas follows:
The Property Ombudsman
43-55 Milford Street
Please note the following:
You will need to submit your complaint to The Property Ombudsman within 12 months of receiving our final viewpoint letter, including any evidence to support your case.
The Property Ombudsman requires that all complaints are addressed through this in-house complaints procedure, before being submitted for an independent review.
If you feel we have not sought to address your complaints within eight weeks, you may be able to refer your complaint to The Property Ombudsman Ltd to consider without our final viewpoint on the matter.