HUMBERTS PRIVACY (GDPR) POLICY

Humberts UK Limited (“We”, “Our”, “Ours”) are committed to protecting your personal data and respecting your privacy. This Privacy Policy (together with our Terms of Business) relates to Our use of any personal data and how We collect it from you, how We use and process it, your rights, how you can manage the use of your personal information, procedures that We have in place to safeguard your privacy, how We use cookies and how you can contact us or make a complaint.

Whenever you provide such information, We are legally obliged to use your information in line with all applicable laws concerning the protection of personal data.

For the purpose of Data Protection Laws, the Data Controller is Humberts UK Limited and We decide how and why personal data that We collect is used. We can be contacted at Second Floor, A2Z House, 24-26 Milford Street, Salisbury, Wiltshire, SP1 2AP.
E-mail privacy@humberts.com.

The information We collect

We gather personal information for business purposes in order to provide you with the services you have requested or to comply with Our regulatory obligations. The personal information We typically collect includes:-

• Name
• Address
• Contact telephone number(s) and e-mail address(es)
• Title Plans and proof of ownership documents
• Information to enable us to check and verify your identity
• Property information or preferences related to the purchase, sale or let of a property
• Financial and other personal information required for the purposes of effecting a sale, purchase or tenancy

When you visit Our website We will automatically collect the following information:-

• Technical information, including the Internet Protocol Address (“IP address”) used to connect your computer to the internet.
• Your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (“URL”), clickstream to, through and from Our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.

We may combine the information you provide to us with the information We collect from you.

How We use the information We collect from you

We may process the information We gather for the following purposes:-

• We have a legitimate interest to process your personal information to perform the duties requested by you, these include, but are not limited to, purchasing, selling, tenancy or professional services.
• We have a contractual obligation to process personal information to initiate a contract in relation to purchasing, selling, letting or professional services.
• To meet legal or regulatory obligations such as obtaining proof of identity.
• To provide you with marketing information on related services.  It is your right to request to be opted out of this any any time.  
• Where We require consent for marketing communications We will ask for this consent clearly and separately.

Sharing your Data

We may share your data with third parties, either directly or in passing, for the following purposes:-

• To ensure the fulfilment of Our contractual duties to you such as, but not limited to, arranging an Energy Performance Certificate (“EPC”), erection of “For Sale” board (or similar).
• We may also share your personal information with Our subcontractors who are involved in the provision of Humberts services, payment providers, credit reference agencies.
• To provide you with financial services or conveyancing services from Our nominated providers.

We do not sell your personal information to third parties.

How we protect your information

We take the security and privacy of personal information extremely seriously and have strict internal procedures which cover the storage, access and disclosure of such.

All information you provide to Us is stored on Our secure servers. 

If Our business is sold, if We sell or buy any business or assets, We will provide your personal information to the seller or buyer (but only to the extent that we need to, and always in accordance with data protection legislation).

You and your information

You have certain statutory rights in respect of the management of personal data We hold about you and a summary of these rights appears below.  You may exercise any of these rights by contacting us at privacy@humberts.com.

• You are entitled to receive confirmation as to whether your personal information is being processed by Us, as well as various other information relating to Our use of your personal information.
• You also have the right to access all your personal information held by Us.
• You have the right to require Us to rectify any inaccurate personal information we hold about you.
• You have the right to require Us to erase your personal information in the following circumstances:-
  • Where We no longer need to use your personal information for the reasons We told you We collected it for
  • Where We needed your consent to use your personal information and you have withdrawn your consent
  • Where you object to Our use of your personal information and We have no compelling reason to carry on handling it
  • Our handling of your personal information has broken the law
  • We must erase your personal information in order to comply with a law We are subject to
    
    

How long We retain your data for

We may hold your data for a length of time deemed necessary to meet any of the following requirements:-

• Where We are obligated by law to retain information
• Where We deem We have a legitimate interest to retain your information such as following up on market appraisal, valuation or client meeting have conducted.

It is your right to request removal of your data at any time.  Please contact privacy@humberts.com if you wish to exercise your right.

What happens if We change our Privacy Policy

If We change our privacy policy we will post the changes on Our Website and may places notices on other pages of the website as appropriate.

Cookies

A “cookie” is a small text file stored in your browser by websites that you visit.  The information it stores is used to identify your preferences and help you navigate through our website.  We use cookies to obtain information as to how you our website, improve your online experience and to personalise your browsing on repeat visits.  By continuing to browse the website you are agreeing to Our use of cookies. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide you consent.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which We do not have any control over.  These cookies are likely to be analytical/performance cookies or targeting cookies.

Most browsers allow you to refuse to accept cookies and you should refer to your browser Help or Tools for how to do this.  Please be aware that disabling cookies may negatively affect the functionality and use of Our website and that of others.

How to make a complaint

We are subject to the regulatory body that overseas Data Protection law (the Information Commissioners Office (“ICO”).  If you have any concerns regarding the use of your personal data please e-mail privacy@humberts.com.  

If We are unable to resolve your complaint to your satisfaction you may contact the Information Commissioners office at www.ico.org.uk.

Data Protection

The terms “Controller”, “Data Subject”, “Processor”, “Processing”, and “Personal Data” have the meaning as set out in the Data Protection Act 2018, the General Data Protection Regulations (EU) 2016/679 and any other laws relating to the protection of personal data and the privacy of individuals in relation to data that is processed under this policy.  

To the extent that Humberts UK Limited acts as a Controller, it shall:-

• Ensure that it has a legal basis for processing any relevant shared Personal Data (“a processing condition”).
• In respect of the relevant shared Personal Data, ensure that privacy notices are clear and provide sufficient information to Data Subjects to enable them to understand what, of their Personal Data, the disclosing party is sharing with the receiving party, the circumstances under which it will be shared, the purposes for the data sharing and either the identity of the receiving party or a clear description of the type or organisation that will receive the Personal Data.
• Undertake to inform Data Subjects, in accordance with Data Protection legislation, of the purpose for which We will process your Personal Data and provide all information necessary to ensure that Data Subjects understand how their Personal Data will be processed by the receiving party.
• Not retain or process Personal Data for longer than is necessary to carry out the relevant purpose (“Purpose”) and delete your relevant Personal Data when the Purpose is complete.
• Notify Data Subjects as soon as is reasonably practicable, after becoming aware of a security breach (even if such a breach has not yet been fully investigated); and (where applicable) handle any security breach in an expeditious and compliant manner.

To the extent that Humberts UK Limited acts as a Processor, it shall:-

• Process Personal Data only to the extent necessary for the purpose of providing services in accordance with any instructions
• Implement and maintain appropriate technical and organisational measures in accordance with the relevant data protection legislation to ensure a level of security appropriate to the risks that are presented by such processing, in particular from accidental or unlawful destruction, loss alteration, unauthorised disclosure of, or access to personal data, taking into account the state of the art, the costs of implementation, the nature and scope, context and purpose of processing and the likelihood and severity of risk in relation to the rights and freedoms of Data Subjects.
• Not transfer Personal Data outside the EU.
• Ensure that employees or other persons authorised to process Personal Data are subject to appropriate obligations of confidentiality.
• Not engage any third party to carry out its Processing obligations under this policy without informing the Data Subject and ensure that such third parties will be subject to processing obligations equivalent to those set out above.
• As soon as is reasonably practicable and without undue delay, notify the Data Subject about any request (including subject access request) or complaint received without responding to that request (unless authorised to do so).
• Maintain appropriate records and information in compliance with data protection legislation and make available such records and information necessary to demonstrate Our compliance with these provisions.

If you wish to amend or request that We delete your personal data please e-mail privacy@humberts.com.

If you have queries or feedback on this policy, on our website or how we are using your data please e-mail privacy@humberts.com.

Issue date: October 2022.
Review date: December 2022.
Author: Head of Marketing