Tenant Privacy Notice
1. Important Information
and who we are
1.1 The Howard de Walden Estate respects your privacy and is committed to protecting your personal data as one of our tenants.
1.2 This privacy notice for tenants and prospective tenants informs you how Howard de Walden Estates Limited collects and processes your personal data through all your engagements with us whether it be through tenancy enquiries, 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 Howard de Walden Estates Limited (referred to as HowarddeWaldenEstates, HdWE, we, us or our in this privacy notice) is the controller and responsible for your personal data. Please find our contact and legal information at the end of this Privacy Notice.
2. The Data we Collect About you
2.1 Personal data, or personal information, means any information about an individual from which that person canbeidentified. 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 wehave grouped together as follows:
2.1.1 IdentityData includes - first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, picture on any identity document received.
2.1.2 ContactData includes - billing address, delivery address, email address and telephone numbers.
2.1.3 CommunicationsDataincludescorrespondenceormessages(including emails, WhatsApp messages or SMS) that you send to us.
2.1.4 FinancialData includes - bank account and payment card details.
2.1.5 TransactionData includes - details about payments to and from you, deposits and other details of services you have purchased from us and charges you may have incurred.
2.1.6 TenancyDataincludesthetenancystartdate,tenancyenddate,property address, guarantors (where applicable), service request details, appointment windows, appointment records, inspection reports, inventories andcheck-in/out reports.
2.1.7 ProfileDataincludes-yourusernameandpassword,servicespurchased by you, your interests, preferences, feedback.
2.1.8 UsageData includes - information about how you use our services.
2.1.9 MarketingData - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.1.10
2.1.11
ClientDueDiligence(CDD)Data–detailscontained withinidentification documents, financial background information, and personal details from prospective and current tenants.
TenantVulnerabilityData –details abouttenant vulnerabilities including health data and information about disabilities, mental or physical wellbeing.
2.1.12 CCTVData – video images collected of you at our estates.
2.2 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 our lease or tenancy services). In this case, we may have to cancel a service you have with us but wewillnotify you if this is the case at the time.
2.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personaldata changes during your relationshipwith us.
3. How is your Personal Data Collected
3.1 We use different methods to collect data from and about you including through:
Directinteractions. You may give us your Identity, Contact and Financial Data by going through our client due diligence process and background checks, filling in forms or agreements or by corresponding with us by post, phone, email or otherwise in relation to renting our properties. This includes personal data you provide when you:
ď‚· Express interest in our properties
ď‚· Apply for our services
ď‚· Enter into a tenancy withus
ď‚· Subscribe to our service or publications
ď‚· Request property details to besent to you
ď‚· Give us your identity documents for us to carry out background checks
ď‚· Give us some feedback
3.2 Thirdpartiesorpubliclyavailablesources. We may receive personal data about you from various thirdparties and public sources as set out below:
ď‚· Analytics providers such as Google
ď‚· Credit and reference checking agencies
ď‚· Property agent networks
ď‚· Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
ď‚· Client Due Diligence providers
4. How we use your Personal Data
4.1 Our 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 data for each of the different purposes for which we use that information. The law refers to each reasonas a 'lawful basis'
4.2 Generallywedonotrelyonconsentasalegalbasisforprocessingyourpersonaldataother 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 tomarketing 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 legalgroundsforprocessing,and,whereapplicable,thelegitimateintereststhatjustifysuch processing.
Purpose/Activity
To facilitate and communicate with you regarding your tenancy application
To carry out Client Due Diligence checks including credit or background checks to verify your identity.
Typeofdata
To register you as a new leaseholder/client/occupier
To manage your tenancy.
To communicate with you regarding your tenancy.
Identity Data
Contact Data
Communications Data
Identity Data
Contact Data
Financial Data
Transaction Data
CDD Data
Identity Data Contact Data
Communications Data
Identity Data
Contact Data
Tenancy Data
Financial Data
Transaction Data
Contact Data
Tenancy Data
Communications Data
Necessary for our legitimate interests (to manage your application).
Necessary for our legitimate interests (to verify your identity and address history and background check prospective and current tenants)
Performance of a contract with you
To manage payments, fees and charges
Identity Data
Contact Data
Financial Data
Transaction Data
Performance of a contract with you
To collect and recover money owed to us
Identity Data
Contact Data
Financial Data
Necessary for our legitimate interests (to communicate with you regarding your tenancy).
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us).
Purpose/Activity
To notify you about changes to our terms orprivacy policy
Typeofdata
Lawfulbasisforprocessing includingbasisoflegitimate interest
Transaction Data
Identity Data Contact Data
Profile Data
To send our newsletter or an invitation to anevent to you
To use data analytics to improve services, marketing, leaseholder/client/occupiers relationships and experiences
Identity Data
Contact Data
Profile Data
Marketing Data
Technical Data Usage Data
Necessary to comply with a legal obligation.
Where you have provided your consent to us sending you marketing communications.
To make suggestions and recommendations to you about properties orservices that may be of interest to you
Identity Data
Contact Data
Communications
Data
Technical Data
Usage Data
Profile Data
To respond to or assist public authorities. Identity Data Contact Data
Communications Data
Tenancy Data
Profile Data
Technical Data
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 for our legitimate interests (to ensure that our properties and tenants remain safe).
To ensure the security of our buildings and staff.
CCTV Data
Necessary for our legitimate interests (to protect our tenants, staff and buildings).
4.4
SpecialCategoryData
We may collect Special Categories of Personal Data about you including information aboutyourvulnerabilitiesandhealthdata.Belowisatableoutliningthepurposesforwhich weintendtouseSpecialCategoriesof PersonalData andthelawfulbasisforprocessing.
4.5
Marketing
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 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 or ifyouhave optedtoreceivemarketingcommunications fromus and, in each case, you have not opted out of receiving such marketing.
4.6 Third-partymarketing
We will obtain your consent prior to disclosing any personal data to third parties for their marketing purposes.
4.7 Optingout
You can ask us to stop sending you our marketing communications including newsletters ordetailsofproperties atany time by followingtheopt-out links providedin any marketing or communication message or by contacting us at any time at Marketing Department, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163 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.
5. Disclosures of your Personal Data
5.1 Where necessary we may share your personal data with relevant third parties set out below for the operation of your contract with us, for example with:
ď‚· Internal third parties within the Howard de Walden group of companies;
ď‚· External third parties to enable us to provide maintenanceand service facilities;
ď‚· SpecificthirdpartieslistedinthetablePurposesforwhichwewilluseyourpersonal data above;
ď‚· Thirdpartieswithwhomweareunderadutytodiscloseorshareyourpersonaldata to comply with any obligations or protect our rights or the safety of our tenants, customers or others.
ď‚· 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.
5.2 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 andin accordance with our instructions.
6. International Transfers
WewillonlytransferyourpersonaldataoutoftheUKwhereappropriatesafeguards(such as the UK International Data Transfer Agreement) 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 useor disclosureof your personaldata,the purposes for whichwe process your personal dataandwhetherwecanachievethosepurposesthroughothermeans,andtheapplicable legal requirements.
7.3 We retain CCTV Data for a period of 30 days unless we have a legitimate interest in retaining footage for a longer period.
7.4 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 casewe 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 Requestaccess 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.
Please note that where you exercise your right of access, we are required by law to carry out a reasonable and proportionate search for your personal information. When respondingto yourrequest, exemptions(such as wheredisclosingyour informationwould reveal legally privileged information or third-party personal data) may apply, meaning that you may not always receive all the personal information that we process about you. We consider and apply exemptions on a case-by-case basis.
8.2.2 Requestcorrectionofthepersonaldatathatweholdaboutyou.Thisenablesyoutohave 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 Requesterasure of your personal data. This enables you to ask us to delete or remove personaldatawherethereisnogoodreasonforuscontinuingtoprocessit.Youalsohave 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
yourinformationunlawfullyorwherewearerequiredtoeraseyourpersonaldatatocomply withlocallaw.Note,however,thatwemaynotalways beabletocomplywithyour request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
8.2.4 Objecttoprocessing 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 andfreedoms.
8.2.5 Requestrestriction of processing of your personal data. This enables you to ask us to suspendtheprocessingofyourpersonaldatainthefollowingscenarios:(a) ifyouwantus 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 Requestthetransfer of your personal data to you or to a third party. We will provide to you,ora thirdparty youhavechosen,yourpersonaldatain astructured,commonly used, machine-readable format. Notethat this rightonly applies toautomated 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 Withdrawconsent at anytimewherewearerelyingonconsenttoprocess your personal data. However, this will not affect the lawfulness of any processing carriedout before you withdrawyourconsent.Ifyouwithdrawyourconsent,wemaynotbeabletoprovidecertain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
8.2.8 Complaintousabouthow weuseyourpersonaldata.Pleaseseethecomplaints section below.
8.3 Ifyouwishtoexercise any oftherights set outabove, pleasecontact us using the contact information below.
8.4 Youwillnothavetopayafeetoaccess yourpersonaldata(ortoexerciseanyoftheother 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. Wemay 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. Changes to this Privacy Notice
We may update this privacy notice from time to time by publishing a new version on our website andadvise you to regularly check www.hdwe.co.uk for the latest version.
10. Contact Details
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,includinganyrequeststoexerciseyourlegalrights(includinganopt-outmentioned inthisprivacy notice),pleasecontact the DPOusingthefollowing details:DataProtection Officer, Howard de Walden Estates Limited, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163, DPO@hdwe.co.uk, Web: www.hdwe.co.uk
11. Complaints
From19June2026,youwillalsohavetherighttocomplaintousabouthowwehandle yourpersonal dataor other people’sinformation. Whereyoumakeacomplaint,wewill acknowledge your complaint within 30 days and respond to it without undue delay.
If you have a complaint about how we manage your information, please contact us at companysecretary@hdwe.co.uk orDPO@hdwe.co.uk orwritetousfortheattentionof the Company Secretary, 23 Queen Anne Street, London W1G 9DL.
If,aftercompletingourinternalcomplaintsprocedure,youremaindissatisfied,youhave the right to escalate your complaint to the Information Commissioner’s Office by telephone on 0303 123 1113 or at: https://ico.org.uk/make-a-complaint/dataprotection-complaints/
12. Glossary
(a) LawfulBasis
“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 onyou (both positive and negative) andyour rights before we process your personal data for our legitimate interests. We do not use your personaldata 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 onyou in respect of specific activities by contacting us.
“Performance of acontract” 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 witha legal or regulatory obligation”means processing your personal data as required by law or in accordance with a regulatory obligationto which we are bound.
(b)
SpecialCategoryData
This includes information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.