Privacy Policy – Dated 26th November 2018 – Foxglove Investments Group Limited (and subsidiary companies)

1. Privacy policy for Foxglove Investments Group Limited and subsidiary companies. Below we set out the basis on which we process your personal information, including what information we hold about you, how we may use it and what rights you have in relation to that information.

2. In this policy we refer to ourselves as “we”, “us”, “our” and “Foxglove”.

3. Our holding company name is Foxglove Investments Group Limited (Company Number 09314837). In your dealings with Foxglove you may deal with any one of our subsidiary companies who may also be handling your personal data. All of our companies are involved in property letting or development. Our subsidiary companies are:

a. Foxglove Investments Homes Limited 11021665
b. East Coast Living Limited 10730282
c. Foxglove Investments (Property) Limited 10446497
d. Foxglove Investments (Central) Limited 09825432
e. Foxglove Investments (Developments) Limited 10140287
f. Foxglove Investments (Central 2) Limited 10131032

4. Our main point of contact for data protection queries is Stuart Astbury. Email [email protected] or write to us at 8a Wednesday Market, Beverley, HU17 0DG

5. CONSENT
a. By giving us your personal information whether that is because you are a customer, tenant or potential customer and whether that is directly given to us by email or telephone or through an estate agent or other third party, you agree and consent to our processing of your personal information in accordance with this policy.

6. DATA CONTROLLER
a. Foxglove and its subsidiaries are “data controllers”. As a data controller we decide how we hold and use your personal information.

7. DATA COLLECTION
a. We may ask for or otherwise collect the following personal information from you:
i. Contact details such as your name, address, contact telephone number and email address;
ii. Copies of passports, driving licences or birth certificates;
iii. Your bank account details when setting up payments for tenancies or taking payments for deposits (or for checking your identity);
iv. We may also collect details of your visits to any of our websites. This information is collected through cookies, including the IP address of your computer or device used to access the sites. Please see our cookie section below for further details of cookies used on this website.
b. Ways in which we collect your data:
i. We may collect your data when through our websites when you register your interest to purchase a property from us or requesting a brochure.
ii. When you make contact with our agents to enquire about letting a property or buying a property from us.
iii. Through Facebook likes, follows and other interaction as well as other social media platforms such as Twitter and Instagram.
iv. If you ever contact us in any other way, for example by telephone, letter or email.

8. COOKIES

a. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

b. We use traffic log cookies (Google Analytics) to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Here are our main cookies:

c. Google Map – Persistent cookie set by Google maps. On some pages we embed interactive maps using Google Maps.

d. Google Analytics – These cookies are used to collect information about how visitors use our site.

e. YouTube – Persistent cookie set by YouTube – if viewing an embedded video on our web site.

9. AUTHORITY

a. In completing an online form or enquiring to buy a property you are consenting to our use of yours and any other persons data that you have provided (such as a joint applicant for a tenancy). If you do provide another persons data we will assume that you are have their consent to disclose it.

b. The law requires us to have a lawful justification for using your data. Depending on whether you are a prospective customer or a new tenant/customer will determine what that purpose is. These various legal justifications for which we can use your data are set out below. Any of the following justifications may apply:

i. We are fulfilling a contract to you;
ii. We have to comply with a legal obligation;
iii. Processing your data is in our legitimate interest (this is important for us. We have a legitimate interest in processing your data as it’s a key part of our business to do so). We need that information to let a property or sell a property to you).
iv. Where you’ve given your consent;
v. Protecting your vital interests;
vi. When it is in the public interest.

10. SPECIFIC USE OF YOUR DATA
a. Here is a list of all the main ways that we may use your personal information, and which of the lawful reasons we rely on to do so.

Purpose Legal basis
To provide you with information about properties for sale: This is in our legitimate interests. You have expressed an interest in a property and we want to provide you with information to enable you to make that choice.
To notify you about changes to our business or new opportunities: We may need to update you on our development sites or inform you about properties that may be of interest to you. This is in our legitimate business interests.
To perform our legal and contractual obligations. For example where we have a contract or lease between us when you are buying a property or renting a property from us. We need to process the data to fulfil the contract. and to comply with our legal obligations.
To provide you with information about Help to Buy. The Help to buy Scheme requires very specific information to be processed so we may need to do this in our legitimate interests and also where we have a legal obligation to do so.
To provide you with information about LABC or similar warranty providers We’ll do this if there is an agreement for you to have the benefit of an LABC insurance policy.
To process an application from you for a tenancy and the ongoing management of your tenancy, including arranging maintenance on your property. Our legitimate interests to help us operate our business and our legal obligations to check tenants right to rent property and of course to fulfil any contractual obligations to you.

11. Emailed Marketing
a. The main way in which we market to you is to provide you with information after you have expressed an interest in a property. This may include sending you updates on site development via email, sending you brochures or our agents calling you directly.
b. We will only use your personal information in this way either because you have given your consent or we have a ‘legitimate interest’.
c. We will stop marketing our properties to you if you ask us to. You just need to contact us using the contact details above or on our website.
d. We will only send you email marketing information if you’ve given your consent to us doing so and you can of course withdraw your consent at any time. Please just contact us using the contact details above or click on the ‘unsubscribe’ link in our emails.

12. SHARING YOUR INFORMATION WITH THIRD PARTIES
a. We will not sell your personal data to any other organisations for any purpose but there are occasions when your data does need to be disclosed to or processed by third parties.
b. We share information with our managing agents, estate agents and contractors. We wont seek your further consent to sharing that information as we need to do so to run our business. This is in our legitimate business interests. Other parties who may receive your information include:
i. Mail chimp/other email providers;
ii. Homes England/Other governmental funding bodies;
iii. Local Authority Building Control so that they can provide you with your new home warranty
iv. Utility providers (where you move in or leave a property);
v. Local councils (for example if we need to prove occupation of a property or to confirm council tax details)
c. We may also share information when required by law for example where ordered by the courts.
d. We may also share information with the courts or our advisers if we are taking legal action against you.
e. As we operate a group structure we may transfer your data within our group and subsidiary companies and they may transfer data to us. We may in the future sell our business and your data may be transferred to a buyer.

13. Sending data outside of the EEA
a. If you have signed up for a mailing list for example to receive a sales brochure then your data will be collected on a database by a third party contractor called MailChimp. MailChimp may store your data outside of the European Economic Area (‘EEA’). As part of that service with MailChimp we have entered into a contract which stipulates how they handle and protect your data. They also operate their own separate privacy policy which you can see here https://mailchimp.com/legal/privacy/#contacts

14. How long do we keep your data for:
a. We will keep your personal information on file in case we think any of our future developments which may be of interest to you. If you want us to remove your data you can inform us as at any time.
b. If we’re holding data which we collected to fulfil a legal obligation (such as right to rent information) we will keep this for up to 6 years. We will only keep this data so that we can prove compliance with our legal obligation. We wont use it for any other purpose.
c. We will keep your data secure by storing it appropriately in our offices and password protecting electronic documents which hold it.

15. Access to your information.
a. You can write to us at any time to ask us what personal information we hold about you. Any request needs to be made in writing.
b. We will provide a copy of your information free of charge unless you are making repeated requests for the same information or your request is more extensive than a normal reasonable request for information. We will only charge you our legitimate administrative expenses for the time incurred in retrieving the requested data.
c. We’ll endeavour to provide a response within 14 days and we will never take longer than a month to respond.

16. Other rights relating to your data
a. Right to rectify your personal information – You have the right to have information rectified (i.e. corrected).
b. Right to be forgotten – You may ask us to delete the information that we hold about you. We may have reasons which prevent us from deleting your information (for example if you are still our tenant or if the information must be retained to fulfil a legal obligation).
c. Right to restrict its use – You may have the right to have the processing of your personal information restricted unless we have a legal obligation preventing us from doing so.
d. Right to object to its use – You may object to the processing of your personal information when we are using it for commercial reasons or where we are directly emailing you.
e. Right to data portability – You also have the right to receive, move, copy or transfer your data to a third party.

17. Variations to this policy
a. We may edit or amend this policy from time to time.
b. If we make any substantial changes we will notify you either by emailing you a new copy or by including an update on our websites.

18. Complaints/Requests
a. If want to make a complaint or a request for information please do so by using the contact details above.
b. You can also raise your complaint with the Information Commission at the following address Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF