1.1 The Howard de Walden Estate respects your privacy and is committed to protecting your personal data.
1.2 This privacy notice informs you how Howard de Walden Estates Limited (referred to as “Howard de Walden Estates”, “HdWE”, “we”, “us” or “our” in this privacy notice) processes your personal data through all your engagements with us whether it be through using this website, property rental, service utilisation, or from any engagement, including any data you may provide when you sign up to our services, our newsletters or request information about other services from Howard de Walden.
1.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.4 Our website is not intended for children.
1.5 Howard de Walden Estates Limited is the controller and responsible for your personal data. Please find our contact information at the end of this Privacy Notice.
1.6 Our Tenant Privacy Notice can be found here
2. The Data we Collect About you
2.1 We may collect, use, store and transfer different kinds of personal data about you whenever you contact us, including through this website, for example,:
2.1.1Identity Data includes - first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.1.2Contact Data includes – billing address, delivery address, email address and telephone numbers.
2.1.3Financial Data includes - bank account and payment card details.
2.1.4Transaction Data includes - details about payments to and from you and other details of services you have purchased from us.
2.1.5Technical 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.
2.1.6Profile Data includes - your username and password, services purchased by you, your interests, preferences, feedback.
2.1.7Usage Data includes - information about how you use our website or services.
2.1.8Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.2Personal 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).
2.3Where 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 our lease or tenancy services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
2.4It 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.
3. How is your Personal Data Collected
We use different methods to collect data from and about you including through:
3.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, agreements or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
3.1.1Apply for our services
3.1.2Enter into an agreement with us
3.1.3Subscribe to our service or publications
3.1.4Request property details to be sent to you
3.1.5Give us some feedback
3.1.6You may also provide data to us
3.1.7 By liking our social media pages
3.1.8 By following our social media pages
3.1.9 By contacting us via our social media pages
3.2Automated 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 and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
3.3.1 Analytics providers such as Google
3.3.2 Credit and reference checking agencies
3.3.3 Property agent networks
3.3.4Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register
4. How we use your Personal Data
4.1Our use of your personal data shall be strictly in accordance with applicable legal requirements. Data protection law requires us to have a valid reason to process your personal information for each of the different purposes for which we use that information. The law refers to each reason as a 'lawful basis'. Most commonly, we will use your personal data in the following circumstances:
4.1.1Where we need to perform the contract we are about to enter into or have entered into with our clients, occupiers and leaseholders.
4.1.2Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3Where we need to comply with a legal or regulatory obligation.
4.1.4To inform you of relevant activities within the Howard de Walden Estate.
4.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. Should you wish to opt out of such marketing communications, you may withdraw consent to marketing communications at any time by contacting us.
4.3 Below is a table outlining the purposes for which we intend to use your personal data, the legal grounds for processing, and, where applicable, the legitimate interests that justify such processing.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new leaseholder/client/occupier (a) Identity (b) Contact Performance of a contract with you
To carry out Client Due Diligence checks (a) Identity (b) Contact (c) Financial (d) Transaction (e) CDD Necessary for our legitimate interests (to background check potential tenants)
To process your agreement including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Conducting any credit or background checks to verify your identity
Necessary for our legitimate interests to define types of leaseholder / client / occupiers for our products and services to develop our business and to inform our marketing strategy
Necessary for our legitimate interests to develop our services and grow our business
Necessary to ensure that our properties remain safe
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. You will receive marketing communications from us if you have opted to do so, have requested information from us or entered into a contract for services from us or if you provided us with your details when you registered interest in one of our properties in each case, you have not opted out of receiving such marketing.
4.5 Third-party marketing
We will obtain your consent prior to disclosing any personal data to third parties for their marketing purposes.
4.6Opting out
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You can ask us to stop sending you our marketing communications including newsletters or details of properties at any time by contacting us: Marketing Department, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163 or by email: marketingandcommunications@hdwe.co.uk Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship we have with you.
4.7Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For more information about what cookies we use and how you can manage these cookies see our cookies policy
5. Disclosures
of your Personal Data
5.1Where necessary, we may share your personal data with relevant third parties for the operation of your contract with us, for example with:
Internal third parties
External third parties to enable us to provide maintenance and service facilities
Specific third parties listed in the table above
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 policy.
Third parties with whom we are under a duty to disclose or share your personal data to comply with any obligations or protect our rights or the safety of our customers or others.
5.2We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We generally 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 will only transfer your personal data out of the UK where appropriate safeguards have been put in place to ensure that your personal data and your privacy rights are protected.
7. Data Retention
7.1 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.
7.2 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 leaseholder/client/occupiers (including Contact, Identity,
Financial and Transaction Data) for seven years after they cease being leaseholder/client/occupiers.
7.3 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.
8. Your Rights
8.1 You have a number of rights under data protection laws in relation to your personal data. When exercising any of the rights set out below, we may ask you for information to confirm your identity and, where applicable to help us locate your personal information.
8.2 You have the right to:
8.2.1 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.
8.2.2 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.
8.2.3 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.
8.2.4 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.
8.2.5 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.
8.2.6 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.
8.2.7 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.
8.3 If you wish to exercise any of the rights set out above, please contact us using the contact details set out below.
8.4 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.
8.5 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.
8.6 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.
9. Third Party Links
This 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.
10. Changes
to this
Privacy Notice
We may update this privacy notice from time to time by publishing a new version on our website and advise you to regularly check www.hdwe.co.uk for the latest version.
11. Contact Details
11.1 The Data Protection Officer (DPO) 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 legal rights (including an opt-out mentioned in this privacy notice), please contact the DPO using the following details: Data Protection Officer, Howard de Walden Estates Limited, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163, Email: DPO@hdwe.co.uk
11.2 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).
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We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Glossary
Lawful Basis
“Legitimate interest” means our business’s necessity to conduct and manage operations effectively, which enables us to give you the best service and most secure service and 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 a 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 as required by law or in accordance with a regulatory obligation to which we are bound.
