1. Who we are
This Privacy Notice applies to the use and processing of personal information collected by Connells Limited and its subsidiary companies.  The ICO registration numbers of these companies is detailed at the end of this notice and further information about the Group can be found on our website.

The phrases “us”, “we” or “our” will mean those businesses which are majority-owned subsidiaries of Connells Limited on behalf of and in respect of whom this Privacy Notice is made.

For information concerning the collection, use and processing of personal information by any of our third-party business partners or suppliers, please contact our representative with whom you usually deal.
2. Information covered by this Privacy Notice
i.    Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you
ii.    Special categories of personal data. This is information which is classified as sensitive (for example details of your health)

Please read this Privacy Notice carefully. If you have any questions about this notice or our use of your personal data, please contact the Connells Group Data Protection Officer by email to DPO@connellsgroup.co.uk or in writing to Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN.

Connells Limited.is part of the Connells Group, and all data protection matters are managed at Group level. Information concerning the make-up of the Connells Group can be found by visiting http://www.connellsgroup.co.uk/our-group
3. Where we get personal information from  
When you enquire or register for products and services provided by Connells Limited we may collect personal information from a variety of sources.

The majority of the personal information which we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet.

However, we may also obtain your personal data from other sources including:
•    information we collect when you visit or create an account on our websites
•    other Connells Group companies
•    companies which support advertising services that promote our services including online property portals (such as Rightmove and Zoopla), social media sites (such as Facebook and Twitter) and online advertising platforms (such as Google Adwords)
•    information provided to us by other third parties, as part of a service we are providing to you or our customers such as
•    Next of kin / delegated authorities
•    Business associates
•    Employers
•    ‘Trusted Sources’:
 - Government / Land / Police registers
 - Credit / Default Agencies
 - Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)
 - Insurance Companies
 - Other Law firms
 - Health providers
 - Third party service affiliates or suppliers who have sought your consent 
•    other publically available sources such as the electoral roll and HM Land Registry
 We will always attempt to provide you with our Privacy Notice in regards to information received from other sources than yourself if it is not deemed to be disproportionate or prejudicial

4. What information we collect
4.1 Information we collect directly from you
Depending on the type of service or product we are discussing, the following are examples of information we may collect directly from you:

Information we may collect directly from you Why we collect it
Your name, postal address, phone number, email address and details of your requirements To provide you with estate agency services to find a property to buy or sell
Your marital status, date of birth, nationality and tax status When you enter into a residential sale or letting agreement
Your date of birth, nationality and details from identity documents you provide  To perform ‘know your client’, anti-money laundering and right to rent checks, as required by law
Proof that you have sufficient funds to support any offer that you may wish to make to buy a property To ensure you able to pay the required amount of deposit
Financial information, for example, a copy of your bank statement or an agreement in principle from your mortgage provider To provide evidence of the source of funds you will be using to buy  a property
Your bank account details or payment card information Processing payments and transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Credit Checks and related dispute resolution activities
Details of your mortgage arrangements, confirmation of how long you have owned the property and details of the source of monies invested in the property when you register to sell To undertake know your client and anti-money laundering checks
Evidence that you have the right to let a property Where you are a landlord and instruct us to assist you with letting a property in Scotland
Details of any mortgage or insurance, licensing documentation and service contracts which you have in place in relation to a property you wish to let Where you are a landlord and we are providing you with letting services
Your marital status, employment details, national insurance number, nationality, residential status, bank details and credit history To carry out referencing and credit checks and the results of those checks
Details relating to your property including photographs, floor plans, energy performance certificate ratings/ home reports, property description and survey results To deliver our service to you when you engage us to market a property for you
Photographs of your property , an inspection report and inventory , to record the condition of your property at the start or end of a tenancy To deliver our service to you when you engage us to let a property on your behalf
Move in and move out dates, utility meter serial number and meter readings before a tenant moves into a property and when the tenant moves out   To deliver our service to you when you engage us to let a property on your behalf
Your move in and move out date and details of the deposit paid where you are a tenant when registering or releasing any deposit from a deposit protection scheme To deliver our service to you when you engage us to let a property on your behalf
Your name, gender, previous name, mother’s maiden name, date of birth, contact telephone numbers, current address and previous addresses, details of your health and family history , information about your status and dependents, your nationality, bank account details, savings and investments, existing financial commitments, your credit history, your mortgage requirements and existing protection arrangements To enquire or apply for mortgage or protection products on your behalf
Your communication and marketing preferences To ensure we only send you details of products and services you are interested in through your preferred communication channel

Where you ask us to help you with your life, critical illness or income protection insurances, and we collect personal information from you which is of a sensitive nature, we treat this ‘special category’ information in accordance with the additional protection it is given under data protection laws.

We may, during the course of your relationship with us, request additional information from you which is relevant to the provision of specific services.

Any telephone calls either to or from our customer service teams may be recorded for training, monitoring, compliance and security.
4.2 Information we collect when you visit or create an account on our websites
We use cookies and other technologies to collect information when you visit our web sites, including when you make use of our online chat.
We may collect personal information in connection with your use of our website, such as:   
•    your name, email address, telephone number and property address when you register for an account or use an online form to arrange a viewing, register for property alerts, request a valuation or lettings consultation, book a mortgage appointment or submit an enquiry
•    details included on any enquiry form you submit in relation to property insurance, life, critical illness or income protection, conveyancing or mortgages
•    data sent from your browser to our server which may include:
o    the time, date and duration of your visit
o    the site from which you have come (the referral URL)
o    the pages you have visited  and
o    your IP address
Details of how we use cookies are provided in Section 13 ‘Our Use of Cookies’ and in our Cookies Policy 
4.3 Information we obtain from other Connells Group companies
For activities related to providing advice on regulated mortgages and non-investment insurance contracts, Connells Limited is an appointed representative of Connells Limited and may share your information within the Group.
Connells Ltd is authorised and regulated by the Financial Conduct Authority; the Financial Services Register number is 302221.
4.4 Information we obtain from online portals
Where you contact by providing your details through online portals such as Rightmove or Zoopla, we will use the details contact you to provide the services you have requested.
4.5 Information we obtain from third parties  
Where we are required by law, or for business needs, we will obtain information about you from third parties, but only after we have your agreement to do so. For example (but not limited to) the third parties we may need to contact our credit reference agencies, banks, employers, accountants and solicitors in order to obtain references, undertake identity verification and basic criminal record checks, and validate your income level and financial history.
4.6 Circumstances under which criminal disclosures will be collected
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences. This is relevant to insurance related activities such as underwriting, claims and fraud management.

When we process any Criminal Disclosures we do so on the basis that it is in the substantial public interest to be able to provide vital insurance products as permitted by UK data protection-related laws and regulations from time to time. Information on Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as us and insurance providers, to enable customers to secure the important insurance protection that they require.
5. How we use your information
We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have. 

The following are examples of how we use the information we collect:

•    To process your registration and confirm your identity
•    To provide you with the estate agency services which you have asked us to provide, including but not limited to:
o    helping you to sell your property
o    valuing your property
o    arranging and carrying out accompanied viewings
o    finding a property to purchase
•    To provide a full lettings service for tenants, prospective tenants and landlords
•    To provide property management services
•    To arrange a survey and valuations
•    To provide advice on financial products and services, such as mortgages, insurance and protection products
•    To keep you informed of any developments in relation to any mortgage product, protection product or insurance product which we help you to take out;
•    To provide conveyancing services
•    To provide will writing and associated legal services
•    To provide property auction services
•    To create and manage your online account
•    To process payment for our services 
•    To protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent or franchise quality, integrity, compliance and security of business processes
•    To provide, administer and communicate with you about Connells Group  products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners
•    To protect a tenant’s deposit by registering it with a deposit protection scheme
•    To process the receipt and payment of rent, maintenance and tax for you if a property is being let
•    To arrange an energy performance certificate or home report inspection for you
•    To arrange an inventory check or to prepare a report on the condition of a property if it is being let
•    To ensure that utilities are in place and that utility company and local authorities are able to contact you for billing purposes when you move into a property
•    To carry out tenant referencing and credit checks to assess if you are creditworthy before you move into a property. To carry out such checks, your personal information may be shared with credit referencing companies
•    To compile business directories, including business contact information and maintain up to date client records
•    To operate, monitor, evaluate and improve our products, services and websites
•    To evaluate your interest in and suitability for employment
5.1 Customer Surveys
From time to time we may provide your information to our customer service agencies for research, survey and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may occasionally contact you including by post, email or telephone to ask you for your feedback and comments on our services.
5.2 Information about our products and services
We may also use your personal data to contact you by post, email, telephone or other electronic means to provide you with information about products and services from the Connells Group and carefully selected third parties which we feel may be of interest or relevant to your needs.
Please see Section 12 for information about how you can exercise your rights. 
5.3 Credit scoring
Some of the services provided by third parties may involve an automated decision and/or credit scoring to determine whether we are able to provide a service or product. 

Using third parties to undertake searches and collate information on our behalf helps make fair and responsible decisions. When coming to these decisions we and third parties will consider:

•    the information provided on the application form
•    information about previous account conduct, including any payment arrears  and
•    official public records information such as fraud record information and insolvency records
Any credit scoring methods used by third parties are regularly tested to ensure they remain fair, effective and unbiased.
For further information about automated decisions or credit scoring, please contact the Connells Group Data Protection Officer by email at DPO@connellsgroup.co.uk
6. Who we share your information with
We may share your information both within the Connells Group of companies and also relevant third party business partners, both for the purposes set out in this Privacy Notice, or for other purposes approved by you.
6.1 Connells Group
We may share information within the Connells Group of companies for the following purposes:

•    where services are provided by one Connells Group Company to another pursuant to an intra-company
•    for the purpose of administering our business
•    to provide you with information about products and services
•    for any other purpose agreed by you
6.2 Third Party service providers
Where we engage third party service providers to provide products (such as mortgages, house and contents and family protection insurances and utility services) or other business services and operations, we provide them with only the personal information they need to perform the service or provide the product we request. We contractually require them to securely protect the information, and not to use it for any other purpose.
Indicatively - but not limited to - we may disclose your information to the third parties listed below for the purposes listed:

Third party Why we share your personal information 
Approved contractors To install for sale or to let boards, to appoint managing agents and building maintenance contractors, to arrange EPC visits, to arrange for contractors to provide safety & statutory tests and to take inventories
Surveyors To undertake a structural or Homebuyers survey
Firms on our conveyancing panel To provide home conveyancing services
Our panels of mortgage lenders   To progress your enquiry or application for a residential or buy to let mortgage application
Ageas Insurance Limited To progress your enquiry or application for buildings and contents insurance
Aviva To progress your enquiry or application for a term insurance, critical illness cover and income protection
Other insurance companies we work with To progress your enquiry or application for insurance
Rent and Legal insurance providers To set up landlord insurances, and in the event of a claim
Solicitors To pursue a claim for breach of tenancy
Focal Agent Ltd  To produce marketing packs for the sale of your home
Referencing Companies To check your creditworthiness, obtain tenant references  and to help prevent fraud and money laundering
TransUnion: To check credit worthiness and obtain references for tenants.  For fraud prevention, anti-money laundering checks and identity verification.
Details regarding TransUnion can be found at https://www.transunion.co.uk/legal-information/bureau-privacy-notice).
Credas: For fraud prevention, anti-money laundering checks and identity verification
The Local Council  Payment/collection of Council Tax
Law enforcement bodies including the police, HMRC and local authorities To comply with court orders or legal obligations
Landlord, tenant or Guarantor  To comply with our legal obligations where we are providing a lettings service
'OVO Energy' (Also trading as 'SSE') Where a landlord of property has asked us to arrange the property’s gas and/or electricity supply to be provided by ‘OVO Energy’ (Also trading as ‘SSE’)
The parties whose property you have viewed or on whose property you have submitted an offer  For the purposes of ascertaining in a potential fee payable for introduced parties (title, first initial, surname) or for other reasons relating to your viewing or offer on a property;
Utility Companies For payment of utility bills
Debt collection companies To assist us in recovering any monies which are owed and overdue
Deposit Protection Scheme providers To provide a Tenancy Deposit Protection Scheme
ARLA Propertymark, a professional body responsible for raising professional standards amongst letting agents If information relating to you is requested by them in order to protect your interests
The Property Ombudsman Where they are providing a dispute resolution service  in connection with letting services
Land Registry Office
Her Majesty’s Revenue and Customs (HMRC), 
Other estate agents and parties involved in the sale or purchase of your property
To support the progression of the sales chain

We also provided a link from our website to Google Maps, to show the location of a branch or a property, and to allow you to input your postcode to get directions. If you use or access Google Maps you are bound by the Google Maps/Google Earth Additional Terms of Service https://maps.google.com/help/terms_maps.html including the Google Privacy Policy https://www.google.com/intl/ALL/policies/privacy/index.html 
7. Lawful basis of processing
Connells Limited processes your information under any of the following lawful conditions:   
i.    Performance of a contract -  this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract
ii.    Legal obligation - this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example, verification of identity and fraud prevention
iii.    Consent  - where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example, to send and/or receive marketing information from other Connells Group companies
iv.    Legitimate interests - some information is processed by Connells Limited as part of its legitimate interests which include network and information security, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided. We may also process further information for Fraud prevention and detection, Risk assessment, Due diligence, Training, communication and awareness, Profiling, Acquisitions, Management Information, Compliance and Audit self-assessments.
8. Profiling
Connells Group may use direct or anonymised information to engage in data analysis, data matching and profiling activities for a variety of purposes, including, but not limited to: 
•    Business conduct 
•    Investigation and identification of fraud, money laundering and other potential unauthorised activities,
•    Financial Viability analysis / reports
•    Business partner / client portfolio position, performance, risk positions
•    Anti-money laundering
•    Tax reporting
•    Credit defaulting / exposure

9. Other situations
We may transfer or otherwise process your personal information:
•    As part of the sale of a Connells Group business to another company, or in relation to the purchase of another business
•    When we have received your instruction to pass the sale of your property to another agent
•    To enforce our terms and conditions 
•    When required by law and/or government authorities
o    Where, following a member of our staff displaying Covid-19 symptoms, we, including via the staff member, are obliged to provide names and contact details to the NHS Test and Trace Contact Tracing Team of any people that a member of our staff was in close contact within the 48 hours before Covid-19 symptoms started
•    When requested by the Property Ombudsman Service or any other consumer ombudsman or trade association
10. How long we keep your information for
We will keep your information for as long as is reasonably necessary for the purposes set out in this privacy notice, and to fulfil our legal and regulatory obligations.

In certain circumstances we have a statutory obligation to keep your personal information for a set period of time, for example, financial information (normally 7 years) for financial auditing purposes. Information is always retained in line with its purpose of processing and only for as long as necessary usually, information is kept for 7 years after last contact with you. However, this period may be extended dependent upon any legal or contractual obligations Connells Group may be required to comply with, as well as any overriding business legitimate interests. 

For further information about how long we will keep your information, please contact the Connells Group Data Protection Officer by email at DPO@connellsgroup.co.uk   
11. When we communicate with you
11.1 Service related
We will send you service-related communications and respond to any questions which you may ask.  
11.2 Marketing our services to you
Where you contact us through our website or make an enquiry in branch or on the phone, or via Rightmove or Zoopla we will use the details you have supplied to us to provide you with our general property marketing list by email.
If you choose to 'opt-out' then we will not email you any further information relating to our general property marketing list.

We may also contact you in order to provide you with information about our core products and services which we believe may be of interest to you, in accordance with your preferences including:

•    general updates in relation to the property market
•    information on mortgages, protection and insurance products and conveyancing services
We may also carry out targeted advertising to you on social media websites such as Facebook where you have already shown an interest in our services. This is done by analysing the information we collect about your interactions on our websites and making this available to social media networks.
12. How we communicate with you
For service related communications, we will contact you either by email or through the post. We may also telephone you or send you SMS messages, which may include automated SMS reminders for viewings.  
We give you choices about how we communicate promotions and offers to you.
12.1 By email
We only send you promotional emails if you explicitly select to receive these (you opt-in). You can stop receiving promotional email messages from Connells Limited by contacting your local branch or by following the link to the Marketing Preference Centre
12.2 By post
We only send you promotional postal mail if you explicitly select to receive these (you opt-in). You can stop receiving promotional postal mail from Connells Limited or by changing your preferences in the Marketing Preference Centre
12.3 Mobile Text Messages 
We will only send you promotional text messages if you explicitly select to receive these (you opt-in). You can stop receiving promotional text messages from Connells Limited by following the opt-out instructions provided in the text message or by changing your preferences in the Marketing Preference Centre
12.4 Telephone
We will only contact you by phone for promotional reasons if you explicitly select to receive these (you opt-in). You can opt out of receiving promotional telephone calls from Connells Limited by informing our telephone agents or by changing your preferences in the Marketing Preference Centre
13. Your statutory rights 
You have a number of rights concerning the personal information we use. These include the right to:
•    ask us for access to a copy of your personal information we hold about you 
•    ask us to correct your personal information
•    ask us to delete your personal information
You can delete your online account at any time. This will delete any personal information in your account that we have about you, and it will mean any data about how you’ve used the online account will be made anonymous.  
However, deleting your online account will not delete any data you’ve shared with us for reasons that are not connected with your online account. If you wish us to delete your data which is unconnected with your online account, please contact us as described below
•    withdraw your consent to use your personal information
Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time. If you withdraw your consent, your previous consent will remain valid in respect to our use of your data in relation to good or service we are still contracted to provide
If you would prefer not to receive information from Connells Limited or carefully selected third parties you can opt out by contacting your local Estate Agency Branch, or by changing your preferences in the Marketing Preference Centre
We will act to respond to your request to stop receiving promotional email, phone, text or postal messages from Connells Group as quickly as is practicable (around 10 working days, as systems take time to replicate). We will keep information for record keeping purposes, to ensure we fulfil your request not to send particular types of messages.
•    ask us to restrict the use of your personal data, including direct marketing
•    object to our use of your personal data
•    object to an automated decision, including profiling (for example, in terms of credit risk)
•    lodge a complaint with the Information Commissioner’s Office, if you object to the way we use your personal information. For more information please go to www.ico.org.uk  
If you wish to make a request for access to a copy of your personal data, please write to the Connells Group at Group Legal Services, Bridgegate House, 5 Bridge Place, Lower Bridge Street, Chester CH1 1SA or email DSAR@connells.co.uk
If you wish to exercise any of your other rights, please write to the Connells Group Data Protection Officer at Connells Group, Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN or email DPO@connellsgroup.co.uk
We will acknowledge your request and let you know what we will need from you to carry out your request. Every effort will be made to respond to or comply with your request as quickly as possible, and we will ensure our systems are updated as soon as is practicable in response to your request.

Should we feel the need to verify your identity, identification will be requested within the one month time frame and only limited to what is necessary for confirmation. Once we are satisfied we will then process your request. 

Should we refuse to comply with a request we will inform you of this within the one month time frame and provide an explanation outlining our justification, our internal complaints procedure and your right to complain to a supervisory authority and to enforce your rights through a judicial remedy.
14. Our use of cookies
A cookie is a small file placed on your device when you visit a website that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and to store your preferences when using a particular site. It may contain a unique identifier to ensure that you are not shown the same information and/or are only shown information you have stated that you are interested in.
Our security software may use your IP address and browser version to help protect our systems and provide diagnostic information in the case of an issue.
Further information about our use of cookies is provided in our Cookies Policy 
You can change your cookie preferences by clicking here.
15. How we protect your information 
We store your personal information on our computer systems and in our paper records.
We have implemented strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information.
The information that we collect is stored in a secure facility with restricted physical access.
We also use a number of security measures to prevent electronic access.
Where - in line with this Privacy Notice - information is shared with third parties, similar security measures are used to protect your information.
16. Data Transfers
If we need to transfer data outside the European Economic Area (EEA) and the country it’s transferred to is not on an approved list for having adequate security controls in place, we will limit when we do this and the amount of personal data we send. We will also ensure that there is adequate protection in place before sending anything to other countries outside the EEA by imposing contractual obligations on the recipients to ensure the security and confidentiality of your data.
17. Children’s privacy
We do not offer any products or services to children. In certain circumstances (for example a mortgage application or in relation to a tenancy) we may need to collect the name and date of birth of children from mortgage applicants and share this with the selected mortgage provider.
18. Links to other websites
Our websites, other electronic portals and documentation may provide links to other websites for your convenience and information. These may operate independently from us and have their own privacy notices or policies, which we strongly suggest you review.
Where linked websites are not owned or controlled by us, we are not responsible for their content or data privacy practices.
19. Our Promise to you
When you provide us with this information, you agree to the collection, use and sharing of your information in accordance with this data privacy notice. Our promise to you is that
•    We’ll work with other businesses to put together offers we think you might like
•    You are in control of your data
•    You can change your privacy settings at any time
•    If you don’t think the data is correct tell us and well put it right
•    We will keep your data secure
•    We also promise to collect, process store and share your data safely and securely and to make sure the businesses we work with do the same
 Contact Information  
You can exercise your rights, raise a query or concern, report a breach or make a complaint by contacting the applicable business unit or: 

Emailing: Dataprotection@Connellsgroup.co.uk  

Writing to: 

Connells Group Data Protection Officer 
Connells Group, 
Cumbria House, 
16-20 Hockliffe Street, 
Leighton Buzzard, 

To assist us in responding to your request in a timely and satisfactory manner please provide as much detail as possible during your contact with us.

How to Lodge a Complaint  
If you remain unsatisfied with the way in which Connells have handled your data or dealt with your request / complaint you have a right to raise this with the relevant Supervisory Authority and to seek to enforce your rights through a judicial remedy.

Information Commissioner’s Office 
Wycliffe House
Water Lane
Tel: 0303 123 1113 
Website: https://ico.org.uk/concerns/

The ICO currently recommends you contact them within 3 months of your last contact with us. 

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Tel: +353 (0)761 104 800
Website: www.dataprotection.ie
19. Updates to our Privacy Notice
We will occasionally update our Privacy Notice, so we suggest that you review this Notice from time to time. If we make substantial changes to our Privacy Notice, we will endeavour to inform you directly about these changes.

Date updated – 25/03/2021