Registered in England and Wales with the company number 07734524
Our VAT registration number is 122704646
Our registered office is 19-20 Bourne Court Southend Road, Woodford Green, Essex, United Kingdom, IG8 8HD
We take your privacy seriously and protecting the confidentiality and integrity of personal data is a critical responsibility. You can find out more here and in other related policies and notices about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you now and the further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the products and services we provide to you.
Our Data Protection Officer is responsible for overseeing this policy. The Data Protection Officer provides help and guidance to make sure we apply the best standards to protecting your personal information. Our Data Protection Officer can be reached by email at firstname.lastname@example.org or by post, Data Protection Officer, Aston Rowe, 103-105 Churchfield Road, London, W3 6AH if you have any questions or concerns about how we use your personal information
Personal information we collect from you
We may collect and use the following personal information about you:
• Your name and contact information, including email address and telephone number and company details if applicable
• Information to enable us to check and verify your identity, e.g. your date of birth
• Your gender information, if you choose to give this to us
• Your billing information, transaction and payment card information
• Your professional or personal online presence, e.g. LinkedIn profile, if you share it with us
• Your contact history, transaction and instruction history with us
• Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if you are a potential tenant applying for a tenancy
• Information to enable us to undertake Anti Money Laundering and Terrorist Financing electronic checks on you
• Information about how you use our website, IT, communication and other systems
• Your responses to surveys, competitions and promotions
This personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may on rare occasions also collect information from publicly accessible sources, e.g. Companies House or HM Land Registry. We may also collect information from other publicly accessible sources such as:
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent
We use your personal information under the legitimate interest basis for using and processing. Legitimate Interest may be used as a basis for processing when we have a business or commercial reason to process your information, so long as this is not overridden by your own rights and interests.
When we use and process your personal information for our legitimate interest, we will consider and balance any potential impact on you and your rights under data protection and any other relevant laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your valid consent or are otherwise required or permitted to by law).
The table below explains what we use (process) your personal information for and our reasons for doing so:
We use your personal information for Reasons why
To provide services to you For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Aston Rowe For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, range of services or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations
Updating and enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: —existing and former customers; —third parties who have previously registered with us or expressed an interest in our services; —third parties with whom we have had no previous dealings For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers and contacts. For our legitimate interests, when such information is in the public domain
Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
We do not collect, use or process special category personal information, such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation.
Marketing and communications data
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 will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
• Contacting us by post, 103-105 Churchfield Road, London W3 6AH (attention: Data Protection Officer) or by telephone at 020 8992 3600, or email@example.com
• Using the ‘unsubscribe’ link in marketing emails
Sharing your personal information with or getting your personal information from others
We will share personal information within our offices and with others outside Aston Rowe where:
1. We need to do that to make products and services available to you,
2. Market products and services to you; or
3. Meet or enforce a legal obligation or where it is fair and reasonable for us to do so.
We will only share your personal information to the extent needed for those purposes.
Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents.
Name of third party Purposes for carrying out Processing
The Property Software Group CRM
Webdadi Website designer
123-reg Email provider
Letref Tenancy referencing
Brief your market Marketing solution
Adobe Systems Software Ireland Limited (Adobe Ireland) - Echosign Electronic signatures
How long your personal information will be kept
We will hold 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.
• If 'consent' is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent are still valid. We review the status of your consent every twelve (12) months and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
• If we process your data on the basis of 'legitimate interests', we will retain your data for so long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
• All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims.
Transferring your personal information out of the European Economic Area
We do not transfer your personal information out of the EEA
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal information (the right of access)
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information—in certain situations
Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object: The right to object:
• At any time to your personal information being processed for direct marketing;
• In certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interest.
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
Email, call or write to us— see below: ‘Contacting us’; and
• Let us have enough information to identify you;
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• Let us know what right you want to exercise and the information to which your request relates
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Our contact details:
103-105 Churchfield Road, London, W3 6AH
020 8992 3600