At The Venmore Group we respect the privacy of our clients and visitors to our websites. This policy is concerned with how we collect information, what we do with it and what controls you have.
Your Privacy
The Venmore Group consists of Bradshaw Farnham & Lea, Ball & Percival, Venmore, Venmore Auctions, Venmore Commercial, Venmore Surveys & TVG Lettings.
We are passionate about property and providing high levels of customer service in our efforts to help people sell their property and find their dream homes.
We take our duty to process your personal data very seriously and we will never sell or rent your personal information to other organisations.
This policy explains how we collect, manage, use and protect your personal data.
We may change this document from time to time to reflect the latest view of what we do with your information. Please check back frequently; you will be able to see if any amendments have been made by the date it was last updated.
Please see below for more information on how and why we use your personal details:
Who are we?
In this policy, references to The Venmore Group, or to ‘we’ or ‘us’ are to BFL Estate Agents Ltd who are registered in England 06734039, BFL Auctions Ltd who are registered in England 06734044 and Bradshaw Farnham Lea Ltd who are registered in England 04786094 at 18 The Crescent, West Kirby, Wirral CH48 4HN and TVG Property Management Ltd who are registered in England 12185103 at 17 Alvaston Business Park, Middlewich Road, Nantwich, Cheshire, CW5 6PF.
What personal data we collect and how we use it
What we need
The Venmore Group is what’s known as a ‘data controller’ of personal information provided to us. We obtain basic personal data (like your name, postal address, telephone number and email address) that you provide to us through our website, emails, phone conversations, documents you provide to us or when you visit one of our branches, for example when you:
- Enquire about specific properties for sale or for rent
- Ask us to value your property
- Register for our email newsletters
- Participate in one of our surveys
- Interact with us on our social media sites
If you are buying or selling property with us, we are required to collect further information from you to satisfy the Money Laundering Regulations 2017, this will be to allow us to prove your identity and your address. We will be very clear with you that we wished to collect such information, our reason for doing so and we would only do so with your specific consent and permission.
Any credit / debit card payments taken by The Venmore Group are processed over either a cloud-based system or using a card machine. In both systems the information is not retained by The Venmore Group. Any paper receipts which are produced do not show full account details and are disposed of securely, once processed. Cloud based receipts are generated through the system and are sent to the relevant party via email.
Why we need it
We collect your personal data in connection with specific activities such as property updates, communicating with vendors regarding the marketing of their homes, communicating with vendors and purchasers regarding an ongoing property transaction, newsletter requests, feedback, competition entries, information you provide in public forums on our sites and applications.
The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites. However, if you choose to withhold requested information, we may not be able to provide you with certain services.
Our marketing
Sometimes, with your consent, we will process your personal data to provide you with information about our properties or services that you have requested or are expecting.
On other occasions, we may process personal data when we need to do so to fulfil a contract (for example if you are selling your property with us and we are providing you with feedback following viewings), or where we are required to do so by law or other regulatory bodies.
The Venmore Group also process your data when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, newsletter requests, feedback, competitions and those of other carefully selected organisations. Please see the section on ‘Legitimate Interest’ for further details.
How we obtain your details
We will also hold information about your details so that we can respect your preferences for being contacted by us.
We collect your personal information a number of ways:
· When you provide it to us directly.
· When you provide permission to other organisations to share it with us (including Facebook or Twitter).
· When we collect it as you use our websites or apps.
· When you have given it to a third party and you have provided permission to pass your information on to us.
· From publicly available sources (where possible) to keep your information up to date (e.g. the Post Office’s National Change of Address database).
We combine the information from these sources with the information you provide to us directly.
From time to time we may pay for the contact details of people who might be interested in hearing from us in future. Before we purchase contact information, we always check the wording used when your information was originally collected, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
When providing permission for 3rd party organisations to share your data you should check their Privacy Policies carefully to understand fully how they will process your data.
Anything else?
All the personal data we process is processed by our staff in the UK. Data will remain resident in the UK for the purposes of IT hosting and maintenance.
On occasion, some of our 3rd parties hold data outside the European Economic Area (EEA). Where this takes place, the relevant company adhere to the EU-U.S. Privacy Shield framework, which ensures that personal data can be transferred outside the EU in compliance with the GDPR’s data transfer requirements.
If you would like to change the way you hear from us or no longer wish to receive direct marketing communications from then use the update preferences / unsubscribe section of any email communication or use the contact form on our 'Contact Us' page.
Legitimate interests
We have a number of lawful reasons that mean we can use (or 'process') your personal information. One lawful reason is something called 'legitimate interests'. Broadly speaking Legitimate Interests means we can process your personal information if:
· We have a genuine and legitimate reason
and
· We are not harming any of your rights and interests.
Please read the 'Legitimate Interest' section for more information.
Sharing your information
We only disclose information to third parties or individuals when obliged to by law, for purposes of national security, taxation and criminal investigations and the following:
· If you have agreed that we may do so.
· When we use other companies to provide services on our behalf, e.g. processing, communicating with clients regarding properties or services, sending mail and emails, sending appointment confirmations via text message, customer reviews, analysis and assessment, when using auditors/advisors or processing credit/debit card payments. We work closely with all our 3rd party providers to ensure we have carried out our due diligence and that they are working within the guidelines provided by the GDPR.
(Please note that this sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Privacy Policy).
· To our subsidiaries (i.e. the companies owned by The Venmore Group).
· If we receive a complaint about any content you have posted or transmitted to or from one of our sites, to enforce or apply our Terms & Conditions or if we believe that we need to do so to protect and defend the rights, property or personal safety of The Venmore Group, our websites or our visitors and for other lawful purposes.
· If we merge with another organisation to form a new entity, information may be transferred to the new entity.
· We may disclose aggregate statistics about our site visitors, supporters, customers and sales to describe our services and operations to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information.
Accuracy of data
All data is confirmed at the point of collection. Should your information change at any time, please notify us by either updating your preferences on an email communication or by filling out a contact form on our Contact Us page, alternatively, you can email us at [email protected]
Email Preference Service
Please note that we are unable to cross reference our ongoing database with the Email Preference Service, therefore should you sign up to the EPS whilst already registered on our database, please be aware that this will not automatically remove your details from our system. Please use the update preferences / unsubscribe feature in any email communication, fill in the contact form on our Contact Us page, alternatively, you can email us at [email protected].
Retaining your information
We hold your information only as long as necessary for each purpose we use it, below are examples of some of our retentions to give you an idea of how long we hold your information for.
- Basic personal information after registering with us looking for property / considering selling or renting your home.
We will hold this information with the intention of processing it under the ‘Legitimate Interest’ basis, for the purposes of direct marketing to keep you informed of any services that may be of interest to you for a period of 10 years. This is based on what we’ve always known to be the average period that someone would move home again. In recent years we have seen this average increase to over 20 years, however, we do not feel that is an accurate balance under the definition of ‘Legitimate Interest’.
- Personal information relating to the purchase / sale / rent of a property
This will be held securely for a period of 7 years in line with The Property Ombudsman’s current guidance
- When purchasing / selling / renting a property with us, personal information proving your name and address which will be held securely for a period of 5 years in line with the Money Laundering Regulations 2017.
- Any personal information held pertaining to a survey carried out by us will be held securely for a period of 6 years in line with the Royal Institute of Chartered Surveyors (RICS) guidelines.
- If you decide to request that we have no further contact with you, we will keep some basic information in order to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information.
How do we protect your data?
All data is held securely on our systems which are designed and maintained following industry best practise for storing and securing personal information.
Portable devices, such as laptops, are encrypted and all of our client software packages are password protected.
All of our staff are trained on Data Protection processes and are aware of our internal procedures should a security breech be identified. Employees data protection training is renewed annually to ensure security and integrity is maintained.
Your details on the web: Please read our Cookie Policy below.
What are your rights?
A new data protection law, starting in May 2018, gives everyone a number of very important rights. These are:
· Transparency over how we use your personal information (right to be informed).
· Request a copy of the information we hold about you, which will be provided to you within one month (right of access).
· Update or amend the information we hold about you if it is wrong (right of rectification).
· Ask us to stop using your information (right to restrict processing).
· Ask us to remove your personal information from our records (right to be 'forgotten').
· Object to the processing of your information for marketing purposes (right to object).
· Obtain and reuse your personal data for your own purposes (right to data portability).
· Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
If you would like to know more about your rights under the data protection law see the Information Commissioners Office website.
Remember, you can change the way you hear from us, withdraw your permission for us to process your personal data or exercise any of your above rights at any time by using the update preferences / unsubscribe section of any email communication or use the contact form on our 'Contact Us' page.
How to contact us
If you wish to talk through anything in our privacy policy, find out more about your rights or obtain a copy of the information we hold about you, please contact our data protection team (details at the bottom of this page) who will be happy to help. If you wish to raise a complaint on how we have handled your personal data, you can contact our data protection officer who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
Our data protection officer can be contacted by writing to:
Data Protection Officer
Prospect House
Columbus Quay
Riverside Drive
Liverpool
L3 4DB
Or by emailing: [email protected]
If you wish to talk to us about anything in the policy or the information we hold about you, please contact our data protection team:
- By telephone: 0151 236 6746
- By email: [email protected]
- By post: Prospect House, Columbus Quay, Riverside Drive, Liverpool, L3 4DB
3rd Party Companies
At The Venmore Group we work with a selection of 3rd party companies in order ensure that we are able to provide you with the highest level of service.
| Company Name | Foojit |
|---|---|
| What does the company do? | Secure Print & Post system |
| Example of data provided | Name & address |
| Reason for providing data | For the fulfilment of sending individual items in the post |
| Company Name | Expert Agent |
|---|---|
| What does the company do? | Cloud based estate agency software |
| Example of data provided | Name, Address, Contact numbers, email address, property search criteria, Proof of Identity and Residency (if buying / selling a property with us). |
| Reason for providing data | To fulfil the request of our clients by marketing their properties, providing prospective purchasers with suitable properties and communicating with both vendors and purchasers whilst assisting with progressing property transactions. |
| Company Name | Reputation.com |
|---|---|
| What does the company do? | Online Reputation Platform |
| Example of data provided | Name, email address and address of property sold / purchased |
| Reason for providing data | To fulfil review requests to all vendors and purchasers who have completed a property transaction through us. |
| Company Name | Brief Your Market |
|---|---|
| What does the company do? | Digital Marketing Platform |
| Example of data provided | Name, address, contact numbers & email address |
| Reason for providing data | To send out tailored digital marketing to our client base. |
| Company Name | CoCreate |
|---|---|
| What does the company do? | Cloud based Auction Membership System |
| Example of data provided | Name, address, contact numbers, email address, document upload facility |
| Reason for providing data | To fulfil the request of our clients by allowing them to manage their membership online and keep their personal details up-to-date |
| Solicitor Company Name | Pipedrive |
|---|---|
| What does the company do? | Cloud based company management & diary system |
| Example of data provided | Solicitor company name, company address, point of contact name, contact numbers, email address. |
| Reason for providing data | To record communication and appointments with our panel of solicitors. |
| Company Name | Unique IQ |
|---|---|
| What does the company do? | Auction Administration System |
| Example of data provided | Name, address, contact numbers, email address and address of property sold / purchased. |
| Reason for providing data | To fulfil the request of our clients by marketing their properties, uploading and hosting legal packs and communicating with both sellers and buyers during a property transaction. |
| Company Name | PayProp |
| What does the company do? | Cloud based Lettings and Property Management software |
| Example of data provided | Name, address, contact numbers, email address, document upload facility, payment details, records of maintenance works |
| Reason for providing data | To fulfil the request of our clients by managing their rental properties, providing statements, paying rent, communicating with both Landlords and Tenants whilst assisting with progressing property transactions. |
| Company Name | Let Alliance |
| What does the company do? | Cloud based Tenant Referencing software |
| Example of data provided | Name, address, contact numbers, email address, document upload facility, payment details, referencing checks. |
| Reason for providing data | To fulfil the request of our clients by referencing prospective Tenants prior to Tenancy commencement. |
Company Name |
ISurvey |
| What does the company do? | Cloud based Inspection software |
| Example of data provided | Name and address of property |
| Reason for providing data | To fulfil the request of our clients carrying out inspections at the beginning, during and at the end of tenancies in order to record the condition of the property. |
| Company Name | Docusign |
| What does the company do? | Cloud based ESignature software |
| Example of data provided | Name, address, contact numbers, email address, Tenancy Agreements. |
| Reason for providing data | To fulfil the request of our clients by facilitating online signatures for Tenancy Agreements. |
| Company Name | Typeform |
| What does the company do? | Cloud based information collection |
| Example of data provided | Name, address, contact numbers, email address, payment details. |
| Reason for providing data | To fulfil the request of our clients by collecting all information needed to be able to commence marketing of a property and listing the property to the online portals. |
| Company Name | Dropbox |
| What does the company do? | Cloud based collaboration software |
| Example of data provided | Name, address, contact numbers, email address, payment details. |
| Reason for providing data | To enable collaboration between staff members |
Legitimate interests
Under the new data protection law starting in May 2018 we have a number of lawful reasons that we can use (or 'process') your personal information. One of the lawful reasons is called 'legitimate interests'.
Broadly speaking Legitimate Interests means that we can process your personal information if:
- We have a genuine and legitimate reason and we are not harming any of your rights and interests
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.
We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our 'Legitimate Interests'.
Our interests
The following are some examples of when and why we would use this approach:
- Direct Marketing: We will send postal and email marketing which we feel will be of interest to you, making sure where possible that this is tailored to your interests.
- Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our clients.
- Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us provide you with the most relevant information as long as this does not harm any of your rights and interests.
- Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
- Due Diligence: We may need to conduct investigations on potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.
We will also hold information about you so that we can respect your preferences for being contacted by us.
Your interests
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. 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 consent or are otherwise required or permitted to by law).
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using the update preferences / unsubscribe section on any email communication or our contact form on the 'Contact Us' page.
This document was last updated: October 2020
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