This document explains how we use your personal data.
Carterwood Limited is a private limited company registered in England and Wales with company registration number 06235762 and registered office at Woodlands Grange, Woodlands Lane, Bradley Stoke, Bristol, BS32 4JY (We, us, our).
We take your privacy very seriously. In this policy we explain how we hold, process and retain your personal data.
1. How we use your personal data
- This section provides you with information about:
- what personal data we hold and process;
- in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
- the purposes for which we may process your personal data; and
- the legal grounds on which we process your data.
- Enquiry data. We may process contact details that you provide to us (Enquiry Data). This enquiry data may include your name, telephone number, and email address, and may be provided through our website when you contact us through our Enquiry Form. We may use this contact data to respond to your enquiry. The legal basis for this processing is our legitimate interest in processing your query.
Your enquiry data may be processed for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract.
We may use your Enquiry Data to send you marketing communications (please see section 3 below). Our legal basis for this processing is our legitimate interest or, where required, consent.
We may also use this enquiry data to contact you to discuss your use of our website, and how our website performed and functioned for you. This may include requesting you to complete surveys about our website and service. The legal basis for this processing is our legitimate interest in ensuring the efficient administration and continued function of our website by users.
- Identity data. If you engage us to provide services, we will collect and process personal data to enable us to check and verify your identity. This identity data may include your name, address, telephone number, date of birth, passport details (Identity Data). The legal basis for this processing is the performance of our contract with you and to comply with our legal and regulatory obligations. If you do not provide the identity data we ask for, it may delay or prevent us from providing services to you.
- Transaction data. We may collect and process personal data relating to the matter in which you seek to engage and/or engage us to act on your behalf. In addition to your identity data, we may collect and process information including your bank or building society account details, the source of your funds (e.g. if we are acting for you on a purchase transaction), your salary and other financial information relating to you or your business (e.g. where we are acting for you on a business sale) (Transaction Data).
The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and in order to comply with our legal and regulatory obligations.
- Website data. We may process data about your use of our website and services (Website Data). The website data may include your IP address, geographical location, browser type and version, time zone setting, browser plug-in types, 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 website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- Log-in data for use of our Data Room Services. If you have registered to use our Data Room Services, we will collect and process your personal data in order for us to issue you with log-in details and enable you to access the services and information contained in our Data Room.
The legal basis for this processing is the performance of a contract between you and us or, where you access our services as part of a business, our legitimate interest in ensuring the efficient administration and secure use of our Data Room Service by users.
- Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of 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.
2. Providing your personal data to others
- Professional advisers. We may disclose your data to third party professional advisers engaged in the transaction where necessary for the purposes of providing our services to you, e.g. solicitors, accountants, architects, tax advisers or other property consultants or experts.
- The other party or parties to a transaction. We may disclose your data to a potential buyer or buyers (where we are acting for you on a sale transaction) or a seller or sellers (where we are acting for you on a purchase) where necessary for the purposes of performing our contract with you.
- Other third parties. We may disclose your data to other third parties where it is necessary for us to do so in order to provide services to you or to comply with a legal or regulatory obligation. This may include your lender or mortgage provider, credit reference agencies, HM Land Registry, HM Revenue and Customs or Companies House.
- Our professional advisers, insurers and brokers. We may disclose your personal data to our professional advisers, insurers and insurance brokers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
- Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.
- To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal or regulatory obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.
- Other. We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymized but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
3. Promotional communications including newsletters
We may use your personal data, including Enquiry Data to send you marketing communications (by email, text message, telephone or post), including updates about developments in our sector which might be of interest to you, newsletters and/or information regarding our services. We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications including newsletters. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes except where we have obtained your consent in advance. You have the right to opt out of receiving promotional communications at any time by
- Contacting us by email at firstname.lastname@example.org
- Using the ‘unsubscribe’ link in emails.
4. Transfers of your personal data outside of the European Economic Area
- Your personal data may be transferred and stored outside of the EEA. It may also be processed by our staff, or those of our suppliers, operating outside of the EEA.
- Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an “adequacy decision” with respect to the data protection laws of the country to which it is transferred, or (b) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US; or (c) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.
5. Retaining and deleting personal data
- 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.
- Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:
- Enquiry Data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Website Data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Identity Data and Transaction Data will be retained after we have finished providing our services to you. This is in order for us to respond to any questions, complaints or claims made by you or on your behalf and/or to keep records required by law. In most cases this data will be retained for no more than 7 years following the end of the project in relation to which you have engaged us to act.
- Log-in data for use of our Data Room Services will be retained for a period of 1 year following the date you last accessed our Data Room Services.
We may retain your personal data for a longer period 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.
- We may update this policy from time to time by publishing a new version on our website or sending a copy to you.
- We may notify you of changes to this policy by email.
7. Your rights
- You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- your request not being found to be unfounded or excessive, in which case a charge may apply; and
- the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
- We may withhold personal information that you request to the extent permitted by law.
- You may instruct us at any time not to process your personal information for marketing purposes.
- In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- The rights you have under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
- Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
- Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
- Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
- Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
- Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
- Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
- Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
9. Our details
- You can contact us:
- by post, using the following postal address Aztec Centre, Aztec West, Bristol, BS32 4TD;
- using our website contact form at https://www.carterwood.co.uk/contact/ ;
- by telephone, on 08458 690777 or the contact number published on our website from time to time; or
- by email, using email@example.com or the email address published on our website from time to time.