1.2 We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2.2 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.
3 This site and third-party links
4 Your duty to inform us of changes
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.
5 Information we may collect from you
5.1 We may collect, use, store and transfer different types (but not limited to) of personal information about you or that you provide to us about others associated with you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identity identifiers (including reference numbers we have allocated to identify you), title etc.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Enquiry Data – includes Identity, Contact and Financial Data contained in any enquiry you submit to us regarding services and products.
- Financial Data includes bank accounts details, payment card details, other income/financial/ assets details.
- Regulatory Data includes personal data involving credit and identification checking and validation, money-laundering checks and information about criminal convictions and offences
- Transaction Data includes details about payments to and from you and other details of services and products we provide to you
- 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 our website and the online services provided by us.
- Usage Data includes information about how you use our website and services, including but not limited to, traffic data, location data, web logs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Correspondence Data includes all of the above category groups of personal data which are contained in or relating to any communication with you, which may also include the communication content and metadata associated with the communication.
15.2 This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
16 How your personal information is collected
16.1 We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g.: credit reference agencies; customer due diligence providers; surveyors, estate agencies, engineers
- from a third party with your consent, e.g. your bank or building society
- via our IT systems, e.g.: door entry systems and reception logs; automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
7. How and why we use your personal information
7.1 Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
7.2 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
7.3 The table below explains what we use (process) your personal information for and our reasons for doing so.
7.4 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. In order to process and use your personal information, we generally rely on the following legal bases:
- processing is necessary for the performance of the services and products we provide to you; or
- processing is necessary for the purposes of the legitimate business interests pursued by Wescombe Group; or
- you have given explicit consent to the processing of your personal information for one or more specified purposes.
|What we use your personal information for||Our reasons|
|To provide products/services to you and register you as a new customer||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or Westcombe Group||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or em-bargoes
Other processing necessary to comply with profes-sional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
Performance of services and products we provide to you (or steps taken on your request prior to entering into a contract for the performance of services)
Necessary to comply with a legal obligation
Necessary for our legitimate interests (for running our business, to ensure security, to prevent fraud, to meet our regulatory compliance and reporting obligations)
|Gathering and providing information required by or relating to audits, enquiries or investigations by reg-ulatory bodies||To comply with our legal and regulatory obliga-tions|
|Ensuring business policies are adhered to, e.g. poli-cies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obliga-tions
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demon-strate we operate at the highest standards
To comply with our legal and regulatory obligations
7.5 The above table does not apply to special category personal information, which we will only process with your explicit consent.
8 Promotional communications
8.1 We may use your personal information 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 (we call this marketing) and to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
8.2 We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
8.3 You will receive marketing communications from us if you have requested information from us or requested services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
9.1 You can ask us or third parties to stop sending you marketing messages at any time by logging into the relevant website and checking or unchecking relevant boxes to adjust your marketing preferences, by selecting the unsubscribe options in email correspondence received, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
9.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service request, warranty registration, product/service experience or other transactions.
10 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Westcombe Home Group of companies for marketing purposes.
11 Who we share your personal information with
11.1 We routinely share personal information with:
- any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, insofar as is reasonably necessary for the purposes set out in this Policy
- third parties we use to help deliver our products and/or services to you, e.g. [payment service providers, estate agencies, surveyors, delivery companies];
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
- our insurers and/or professional advisors insofar as reasonably necessary for the purposes of obtaining and maintaining insurance cover, managing risks, obtaining advice and managing legal disputes;
- our business partners, suppliers and sub-contractors and professionals for the performance of any contract we enter into with them or you;
- credit reference agencies;
- our insurers and brokers;
- our banks;
- HM Revenue & Customs;
- other financial service organisations (lenders and operators of card schemes) both within the UK and abroad
- other third parties if we are under a duty to disclose or share your Information in order to comply with any legal or regulatory obligation, or as part of legal proceedings, or in order to enforce any of our rights against you under your contract with us or to protect the property, safety or vital interests of Westcombe Group, or of another natural person.
- your advisers (including but not limited to accountants, lawyers or other professional advisors) where authorised by you
- to carefully selected third parties for marketing purposes when you have consented to be contacted for such purposes
11.2 We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
11.3 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
11.4 We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
11.5 We will not share your personal information with any other third party.
12 Where your personal information is held
12.1 Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
12.2 Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
13 How long your personal information will be kept
13.1 We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
13.2 We will not retain your personal information for longer than necessary for the purposes set out in this policy. The period of retention also may be dependent on whether the retention is necessary for compliance with any legal, accounting, or reporting obligations to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
13.3 In some circumstances, you can ask us to delete your data: see request erasure below for further information.
14 Transferring your personal information out of the EEA
14.1 To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
14.2 These transfers are subject to special rules under European and UK data protection law.
14.3 Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. Whenever we transfer your personal information out of the EEA and the contractual relationship is within our control, we aim to ensure a similar degree of protection is afforded to it.
15 Your rights
15.1 You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
15.2 For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
15.3 If you would like to exercise any of those rights, please let us know what right you want to exercise and the information to which your request relates.
16. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
16 How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
We may change this privacy notice from time to time.
18 How to contact us
Westcombe Homes Group
Effective from 25 May 2018