We are Newboulds & Co Limited with registered number 08027848 and address 4 Station Approach Shepperton TW17 8AR. Our Data Protection Lead can be contacted at sales@newboulds.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 sales@newboulds.com 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 sales@newboulds.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? |
| B2B Marketing |
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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. |
| Analytics |
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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). |
| Fraud Prevention |
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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). |
| Contact Submission |
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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). |
| Phone Calls |
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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 |
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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). |
| Consumer Marketing |
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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 sales@newboulds.com.
Newboulds & Co Limited does not perform any profiling or automated decision making based on your personal data.
Newboulds & Co Limited 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.
Newboulds & Co Limited 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.
Newboulds & Co Limited 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.
Data Controllers
| 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 |
| 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 |
|---|---|
| Mortgage Advice Bureau | If we are providing you with mortgage, protection or insurance advice, your contact details will be shared to progress your enquiry or application |
| Conveyancing Alliance Ltd | If you have asked us to refer you to one of our panel conveyancing firms Conveyancing Alliance Ltd will be passed such personal information as is necessary to provide a quotation |
| The Property Jungle | The Property Jungle provide website management |
| DPS | We will share your contact details with Deposit Protection Scheme in relation to your security deposit |
| Home Inventories | Rental Inventory Services |
| Complete Independent Inventories | Rental Inventory Services |
| Barclays | For the purpose of business banking |
| Relevant County Councils | We will share your contact details with Relevant County Councils relating to council tax matters |
| LetMC | Your data will be stored on our software platform for the purposes of marketing and CRM. |
| Relevant Landlords | Your relevant data will be shared with the landlord of the property you are applying for; in order for them to make a decision about your application. |
| Surveying Firms and Surveyors | We will share your contact and transaction information with relevant firms of surveyors in order to process the sale of your property. |
| Tenants | We will share landlord information with tenants as part of the tenancy agreement. |
| Lettings Agents | We will share your data with other letting agents for the purpose of providing references requested by you. |
| HMRC | We will share data requested by the HMRC for accounting purposes. |
| A Lawler & Co | We will share only relevant transactional data with our accountants for the purpose of our year end accounts. |
| Nethouseprices Ltd | We will share data and details of your property with the Nethouseprices Ltd for the purpose of advertising your property for sale or to let. |
| OnTheMarket plc | We will share data and details of your property with the OnTheMarket plc for the purpose of advertising your property for sale or to let. |
| Zoopla Property Group | We will share data and details of your property with the Zoopla Property Group for the purpose of advertising your property for sale or to let. |
| Rightmove | We will share data and details of your property with Rightmove for the purpose of advertising your property for sale or to let. |
| Maintenance Contractors | We will share your contact details with relevant maintenance contractors for the purposes of investigating and rectifying problems with your property. |
| Transaction Related Estate Agents | We will share information with other estate agents in a property chain, in order to assist with the smooth processing of transactions. |
| Rent 4 Sure | We will share your data with our reference providers in order to establish your credentials when applying for a rented property. |
| Let Alliance | We will share your data with our reference providers in order to establish your credentials when applying for a rented property. |
| Utility Companies | We will share your contact details with relevant utility companies for billing of accounts and meter readings |
| Solicitors, Conveyancers and Property Lawyers | We will share your date with other relevant solicitors relating to the property transaction. |
In addition to sending us your complaints directly to sales@newboulds.com, you can send complaints to our supervisory authority. As Newboulds & Co Limited 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.
