Privacy And Cookie Policy
Cookies are small text files placed on your computer when you browse a website. This website uses cookies in a general way to help us to understand how our website is used and also to improve the user experience. We do not use cookies from which you can be individually identified.
Our website occasionally makes use of "embedded services" such as Facebook, AddThis and Twitter. These third party services may also save cookies on your computer whilst you use our website. We have no control over these cookies and you should seek advice from these services if you wish to understand more about how they use cookies.
You may wish to visit www.aboutcookies.org which contains comprehensive information on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
The table below sets out what cookies we use and why:
| Cookie | Brief description |
|---|---|
| __utma | Google Analytics cookie |
| __utmb | Google Analytics cookie |
| __utmc | Google Analytics cookie |
| __utmz | Google Analytics cookie |
| ASPSessionID | ASP session cookie - deleted when you end your visitor session |
| __atuvc | Cookie set by the AddThis sharing widget which features in our latest project panel |
| cookieTextSeen | This cookie is set when you dismiss the cookie notification. It is used to inform the website not to show the notification again. This cookie lasts for 12 months |
| PRProperty.FormCookie.Search | This cookie is used to save your search preferences. No personal data is stored. This cookie lasts for 12 months |
| ii_Globalisation | This is a system cookie. No personal data is stored. This cookie lasts for 12 months |
This is the privacy notice for (Mark Bowles Ltd t/a P&R Property) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we manage or hold your personal data in the following circumstances:
- When you visit our website.
- When you provide it to us directly.
- When provided indirectly via a third party such as a partner company (a referencing company).
This policy is set out as follows:
- Important Information and who we are
- The Data we collect about you
- How your personal data is collected
- How we use your personal data
- Disclosures of your personal data
- International Transfers
- Data Security
- Data Retention
- Your Legal Rights
- Glossary
1. IMPORTANT INFORMATION AND WHO WE ARE
WHO WE ARE
Mark Bowles
Ltd t/a P&R Property ”, “we”, “us” or “our” in the privacy notice) is a company which is incorporated in
England & Wales with the number 06457402 and is registered under the Data Protection Act
Z305733X
Mark Bowles Ltd t/a P&R Property undertakes a diverse range of activities, a number of which
are regulated by statute.
Where you have provided your personal information to us directly we will be the
Data Controller, and where we have received your personal information via a third party we will perform the
role of a data processor on behalf of the data controller.
We have appointed a Data Protection Officer
(DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise your rights under the Data Protection
Act please contact the DPO using the details set below.
CONTACT DETAILS
The Data
Protection Officer
Mark Bowles Ltd t/a P&R Property
Kingham Way Luton
LU2 7RG
Email
address: info@pandrproperty.co.uk
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 in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF
CHANGES
This privacy notice was last updated on the 26rd April 2018
The data
protection law in the UK will change on the 25th May 2018. This privacy notice sets out your rights under
the new laws, however is subject to change on or after the 25th May 2018.
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.
THIRD-PARTY LINKS
Our website may include links to
third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not control these third-party websites and are
not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy
notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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, employment status, marital status, title, date of birth and gender.
- Contact Data includes home address (previous, current and forwarding), email address and telephone numbers.
- Property Data includes type, number of rooms, locks, energy usage, easements, keys, utility meter information, services records, insurance documents and mortgage documents.
- Financial Data includes bank account details.
- Transaction Data includes card payment details & details about payments to and from you. Other details of products and services you may have purchased from us.
- Technical Data includes internet protocol (IP) address, 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.
- 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.
Unless we have a legitimate interest, 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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we
need to collect personal data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, to provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from
and about you including:
- Direct interactions. You may give us your Identity, Contact, addresses, employment information, accommodation information, bank details (for deposit return purposes) by filling in online forms, telephone or handwritten application forms. This includes personal data you provide when you:
- Register your details onto our applicant data base seeking properties to purchase, rent, let or sell.
- request marketing to be sent to you;
- supply us with feedback/reviews.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- Analytics & tracking providers some such as Google based outside the EU;
- Google Tag Manager
- Google Analytics
- Advertising networks based inside & outside the EU;
- Google Adwords
- Bing Ads
- Google Display Network
- PPC Protect
- Facebook ads
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law
allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where data is held for our/your legitimate interests (or those of a third party), fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We only rely on consent as a legal basis for processing your personal data in relation to marketing
communications to you via phone, email or text message. You have the right to withdraw consent to marketing at
any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL
DATA
We have set out below, some of the ways we plan to use your personal data, and which of
the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
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. Please contact if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in the
table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity |
Performance of a contract with you |
|
Property Updates |
(a) Identity |
Legitimate interest of the applicant |
|
To submit your personal information to our Referencing Provider (LetAlliance)
|
(a) Identity |
Performance of a contract with you |
|
Submit your personal information to our Financial Services Provider. |
(a)Identity |
(a) Necessary for our legitimate interest to conduct a financial qualification check. |
|
To process your order including: |
(a) Identity |
(a) Performance of a contract with you |
|
To provide your contact details onto a third party contractor to arrange & conduct maintenance works at your residence |
(a) Identity |
(a)Performance of a contract |
|
To manage our relationship with you which will include: |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business, provision of administration and
IT services, network security, to prevent fraud and in the context of a business reorganisation or
group restructuring exercise) |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
MARKETING
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following personal data control
mechanisms:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical,
Usage and Profile Data 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).
You will receive marketing communications from us if you have requested information from us or
purchased services from us or if you provided us with your details when you entered a competition or
registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY
MARKETING
We will get your express opt-in consent before we share your personal data with any
company outside the Mark Bowles Ltd of companies for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out
links on any marketing message sent to you or by contacting us. at any time.
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 purchase or other transactions.
COOKIES
A cookie is a small file of
letters and numbers that we store on your browser or the hard drive of your computer. By using
the website you are agreeing to using cookies. Cookies contain information that is transferred
to your computer’s hard drive. Our sites may use one or more of the following sorts of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around a website when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to a website. This enables us to personalise our content for you and remember your preferences.
- Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests.
Please note that third parties (including, for example, advertising networks and providers of external
services like web traffic analysis services) may also use cookies, over which we have no control. These
cookies are likely to be analytical/performance cookies or targeting cookies.
You can set your browser to
refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
For more information about cookies, please see (http://www.aboutcookies.org/)
CHANGE OF
PURPOSE
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated
purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that
we may process your personal data without your knowledge or consent, in compliance with the above rules, where
this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the
parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties
- External Third Parties
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European
Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Mark Bowles Ltd is Cyber Essentials Certified. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty of confidentiality.
We have
put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We
will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine
the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.
By law we have to keep basic information about our customers
including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for
tax purposes.
In some circumstances you can ask us to delete your data: see Request
erasure below for further information.
In some circumstances we may anonymise your personal
data (so that it can no longer be associated with you) for research or statistical purposes in which case we
may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection
laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us
NO FEE USUALLY
REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of
the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT
WE MAY NEED
FROM YOU
We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our
response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within
one month. Occasionally it may take us longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep you updated.
10. COMPLAINTS
Complaints procedure If you
wish to register a complaint regarding Insurance products, please contact us:
- By email: please send us your complaints to : info@pandrproperty.co.uk
- By phone: call us on 01582 720777
- In writing: send a letter to: The Branch Manager
Complaints Department,
P&R Property ,
Kingham House, Kingham Way, Luton, LU2 7RG - We will then investigate your complaint and respond accordingly. If your complaint is not resolved, you are entitled to refer it to The Property Ombudsman Service for further advice.
Please see link for further details: https://www.tpos.co.uk/
11. GLOSSARY
LAWFUL BASIS
Legitimate
Interest means the interest of our business in conducting and managing our business to enable
us to give you the best service/product and the best and most secure experience. We make sure we consider and
balance any potential impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us.
Performance of
Contract means processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where
it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD
PARTIES
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the United Kingdom who provide:
- IT and system administration services.
- Feedback and service references
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to
your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of
the personal data we hold about you and to check that we are lawfully processing it.
Request
correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the
new data you provide to us.
Request
erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are required to erase your
personal data to comply with local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.
Object to processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of
processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent for us
to use or where we used the information to perform a contract with you.
Withdraw consent at any
time where we are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.