We are David Conway & Co. Ltd with registered number 5444145 and address 269 Northolt Road South Harrow Middlesex HA2 8HS. Our Data Protection Lead can be contacted at email@example.com. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the UK Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 ("Data Protection Legislation"). The terms "Personal Data", "Special Categories of Personal Data", "Personal Data Breach", "Data Protection Officer", "Data Controller", "Data Processor", "Data Subject" and "process" (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. "Data Protection Lead" is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
You can exercise your right to access personal data held about you by contacting firstname.lastname@example.org with the subject line: "Subject Access Request". When you submit a 'subject access request', you will need to provide confirmation of your identity by including a photocopy of your driver's license or passport. This service is provided free of charge and our response will be made within thirty (30) days, unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section 'Who can you complain to?'.
If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at email@example.com.
Under Data Protection Legislation, there must be a 'lawful basis' for the use of personal data. The lawful bases are :
Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
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 this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
|Reference||What categories of information about you do we process?||Why are we processing your data?||Where did we get your personal data from?|
||Direct marketing to former, current and prospective clients. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained or by referral from existing clients/partners/suppliers.|
||To understand how you use our website, how you reached us and how long you spend on our website, in order to analyse our performance and improve our service. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained or indirectly obtained through a client's website (notice given at the point of collection).|
||To combat fraud, we share information of clients who instruct the payment issuer to cancel payments to us without first informing us of why and/or allowing us the opportunity to issue a refund with credit reference agencies. This processing is conducted lawfully on the basis of 'protection of your, or another's vital interests'.||Directly obtained or indirectly obtained through a client's website (notice given at the point of collection).|
||When you send us information about you by posting on a forum or blog, we will store this information in order to make it available for viewing on the website. You consent is obtained at the time of posting and via reference to this notice. This processing is conducted lawfully on the basis of 'your consent'.||Directly obtained or indirectly obtained through a client's website (notice given at the point of collection).|
|Online Payment Processing||
||We require certain information about you in order to instruct our payments processor to take payment from you and transfer it to us. To ensure security, we do not ever process your payment information and will transfer you to the payment processors website at the time of payment. None of our staff or contractors ever have access to this information. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained.|
||To setup a direct debit between your bank and ours, we pass your details to our bank and keep a copy for our records. This activity is conducted under the Direct Debit Guarantee Scheme. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained.|
||We might record calls for training and/or auditing purposes. We also collect Calling Line Identification information. This is used to help improve the efficiency and accountability of our customer services. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained.|
|Email and Web Contact||
||If you contact us through our website or by email, we will use the information you send in order to respond to your enquiry or complaint. This information will be kept in order to improve our service to you overall. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained or indirectly obtained through our website (notice given at the point of collection).|
||If you make a purchase with us, we will add your contact information to our marketing list and send you information we think you might be interested in. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained.|
The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the benefits we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.
We process some personal information as part of a contractual relationship with a Data Controller. Any requests to restrict this type of processing should be forwarded to the Data Controller; they will be responsible for discussing your concerns and making any decisions.
Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact firstname.lastname@example.org.
David Conway & Co. Ltd does not perform any profiling or automated decision making based on your personal data.
David Conway & Co. Ltd holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.
David Conway & Co. Ltd passes your data to the third parties listed in the section 'Third Party Interests' below, for the purposes of providing our services to you, and for no other purpose.
David Conway & Co. Ltd uses overseas web and IT providers. Details of what data is sent where, and the safeguards in place, are included in the section 'Third Party Processors' below.
|Name of Third Party Controller||What processing are we performing for them?||If applicable - who is their representative within the EU?|
|HMRC, regulatory authorities or other authorities||We are joint Controller with these authorities who require reporting of processing in some situations||N/A|
|Payment Processors||We are joint Controller with these service providers who simply pass payments you make through their services directly to us based on a transaction. These transactions are subject to the provider's privacy notices/policies.||N/A for European based services please contact email@example.com if you would like to find out about a specific representative.|
|Postal/Courier Providers||Where these providers act as Data Controller, we are joint Controller with them for the purposes of sending you physical documents.||N/A|
Our Data Processors
|Name of Third Party Processor||Purposes for Carrying out Processing|
|Elihan Group||Property Maintenance Contractors|
|Affinity Property Maintenance||Property Maintenance Firm|
|DAS||Rent Guarantee Insurer|
|Scottish Power||Energy Supplier|
|Residential People||Property Portal|
|Affinity Property Services||Handyman|
|Goodlord||Referencing Company and Insurer|
|HomeShift||Utility Update Provider|
|Agent Canvassing||Canvassing system|
|HM Land Registry||Land registry titles|
|Fredrick George||Property Management Company|
|Customer review site|
|All Agents||Customer review site|
|Google+||Customer review site|
|Customer review site|
|Trustis||Customer review site|
|Blinc||Tenant referencing and deposit replacement scheme|
|Department for Work and Pensions||Where Universal Credit is paid to the tenant|
|Local Authorities||Informing of new tenant/owner occupation|
|Home Office||Verifying Tenants Immigration Status|
|ValPal||Online Valuation Tool|
|Yomdel||Website Live Chat|
|K&S Signs||Sign Erector|
|Bennett & Son||Roofing Company|
|Y & Y Management Ltd||Estate Management Company|
|Wenlock & Taylor||Fencing Company|
|Wenlock & Taylor||Estate Management Company|
|W E Black||Estate Management Company|
|Utility Warehouse Member Services||Utility Provider|
|Urban Construction||Gas Engineer|
|Trinity Estates||Estate Management Company|
|Tom Ford Ltd||Domestic Appliance Repair|
|Three Rivers Property Investments Ltd||Estate Management Company|
|Switch2 Energy Limited||Utility Provider|
|Spark Energy||Utility Provider|
|Southern Electric||Utility Provider|
|Scottish & Southern||Utility Provider|
|Scanda Windows||Window Supplier|
|SAV Systems||Heat Interface Unit Provider/Service|
|Sainsbury's Energy||Utility Provider|
|Robin Hood Energy||Utility Provider|
|Robert Wells Locksmith||Locksmiths|
|Red Rock Estate & Property Management||Estate Management Company|
|Ramki Heating||Gas Engineer|
|Pro-Maintain Ltd||Property Maintenance Company|
|Premier Waste||Waste Disposal|
|Ovo Energy||Utility Provider|
|Orbit Property Management Ltd||Estate Management Company|
|Mechanical Engineering Ltd||Gas engineer|
|MCM Property Management Ltd||Estate Management Company|
|Mayfords||Estate Management Company|
|AAM Maintenance||Property Maintenance Company|
|London Property Licensing||Property Licensing Company|
|Hillingdon Council||Local Council|
|Lets Match||Property Management Company|
|Leete Estate Management||Estate Management Company|
|K & T Services||Gas Engineer|
|Kenwoods||Timber and Damp Specialist|
|JB Ward & Son||Timber and Damp Specialist|
|Ian Gibbs Management||Estate Management Company|
|Relocation Agent Network||Relocation Company|
|Heronsgate Management Ltd||Estate Management Company|
|Heat Interface Team||Heat interface unit supplier and service company|
|FW Lettings||Property Management Company|
|First Utility Ltd||Utility Provider|
|ESS VENTILATION LLP||Ventilation System Provider and Service|
|EDF Energy||Utility Provider|
|Ebico Ltd||Utility Provider|
|Double Glazing Doctor||Double glazing specialist|
|DK Locksmith Services||Locksmiths|
|David Phillips Furniture||Furniture Provider|
|Dash Maintenance||Property maintenance company|
|Dan's Carpets & Flooring||Carpet Fitters|
|D & R Drain Services Ltd||Drain Specialists|
|CPH Plumbing Ltd||Gas engineers|
|Clever Energy Ltd||Utility Provider|
|Clearview Homes Ltd||Property Developer|
|Catalyst Housing||Property Developer|
|Carpet Rite||Carpet Fitters|
|Carpet Link||Carpet Fitters|
|Capital Repairs Ltd||Appliance Repairs and Suppliers|
|Connells Asset Management||Asset Management Company|
|Barnes Brothers Fencing||Fencing Company|
|Various Estate Agents||Estate Agencies whom we may contact in connection to sales chains|
|Various Solicitors||Solicitors whom we may recommend and whom purchasers and vendors may be using for the sale/purchase of their property.|
|AVS Electrical Contractors||Electricians|
|Aprino Property Services||Cleaning Company|
|Aardvark Pest Control Services||Pest Control Company|
|Leasehold Property Management Ltd||Management Company|
|Monster Cleaning||Cleaning Company|
|Brent Council||Local Council|
|Hertsmere Council||Local Council|
|Ealing Council||Local Council|
|Harrow Council||Local Council|
|Scottish & Southern||Utility Provider|
|Affinity Water||Utility Provider|
|Scottish Power||Utility Provider|
|British Gas||Utility Provider|
|Niche Design||EPC Assessor Professional Photography|
|Royal Institute of Chartered Surveyors (RICS)||Accreditation Body|
|The Property Ombudsman||Property Ombudsman|
|Tenancy Deposit Scheme (TDS)||Tenancy Deposit Scheme|
|Van Mildert||Referencing Company|
|Landlord's Lawyer||Landlord's Legal advisor|
|Chase Debt||Debt Collection Agency|
|Practical Mortgage Solutions||Financial Advisors|
|Finance Planning||Financial Advisors|
|City & County Property Services Ltd||Maintenance Company|
|Top Boiler||Gas Engineers|
|Inventories 247||Inventory Company and EPC Assessor|
|Probitus Inventory Services||Inventory Company|
|The Property Collection||Marketing Company|
|Smart Search||Anti-Money Laundering System|
|Adobe Sign||Electronic Document Signatures|
|Brief Your Market||Marketing|
|My Communications||Telephone Systems|
|On The Market||Property Portal|
|The Property Jungle||Website Hosting|
In addition to sending us your complaints directly to firstname.lastname@example.org, you can send complaints to our supervisory authority. As David Conway & Co. Ltd predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner's Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting ico.org.uk.