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.
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.
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.
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'
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
· 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.
· 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.
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’.
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.
We will also hold information about you so that we can respect your preferences for being contacted by us.
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