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Privacy Policy

This privacy notice sets out how we will process personal data we collect from or
about you, or which you provide to us. Please read this notice carefully to
understand why data is being collected and what we do with that data.
Our website and services may contain links to independent websites which are not
provided by us. Such independent sites are not under our control, and we are not
responsible for and have not checked and approved their content or their privacy
policies.
We may change the privacy notice from time to time by amending this page.
For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU
2016/679, the data controller is Carringtons Estate Agents a company registered in England
under company number 08784531, whose registered address is Turnbull House, 226
Mulgrave Rd,Cheam ,Surrey,SM2 6JT

What type of information will we collect from you?
The personal information we collect from you will typically include the following:
 Full name and contact details (including your contact number, email and
postal address)
 Information relating to your identity where we are required by law to collect
this to comply with the Money Laundering Regulations 2017 and the
Immigration Act
 Information on your close connections where we are required to conduct
conflicts of interests under regulatory obligations
 Your banking details where required such as where you are letting a property
or, where renting, to set up an approved tenancy deposit account for you and
arrange for rental payments
 Information on any access requirements you have necessary to enable us to
find suitable properties for you, which may consist of special category
personal data comprising details of any disability or other health information
about you

 Details about your areas of interest where we wish to send you marketing
information about similar products and services
 Usage information about your visits to our website (which enable our website
to remember information about you and your preferences) and use of our site.
[Please read our 'Cookie Policy' for further details.] This may include
information about your visit, including [the full Uniform Resource Locators
(URL),] [clicks through to and from our site (including date and time),]
[products you viewed or searched for'] [page response times,] [download
errors,] [length of visits to certain pages,] [page interaction information (such
as scrolling, clicks, and mouse-overs),] [methods used to browse away from
the page,] [OTHER] and any phone number used to call our customer service
number
 Other technical information, including what devices you use to connect to our
App, device location data where this function is not disabled by you on your
device, [the Internet protocol (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,] [operating system and platform
 Your communications with us, including a record of the email or telephone
correspondence created when you contact us as part of a product or service
query
Where we need to collect personal data by law (for example to meet our obligations
to prevent fraud and money laundering) or under the terms of a contract we have
with you and you fail to provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example, to
provide you with our services). In this case, we may have to cancel a product or
service you have with us, but we will notify you if this is the case at the time.

On what basis can we process your information?
The legal grounds under data protection legislation for processing your personal data
are as follows:

 It is necessary for the performance of a contract to which you are a party, or
to take steps prior to entering into a contract with you, for us to provide you
with our products and services
 You have given us explicit consent to the processing of your personal data for
one or more specific purposes, namely 1) where you have given us consent to
receive electronic marketing by us and/or 2) to process your Special Category
Personal Data described above. You do not need to provide us with marketing
consent in order to receive our services
 It is necessary for the purposes of our legitimate interests, except where our
interests are overridden by the interests, rights or freedoms of affected
individuals (such as you). To determine this we shall consider a number of
factors, such as what you were told at the time you provided your data, what
your expectations are about the processing of the data, the nature of the data,
and the impact of the processing on you. Our legitimate interests include
processing necessary data to improve and to promote our services and
products and to better understand our customers’ interests and knowledge of
the property market and to administer the technical aspects of our service and
products.
 Where we need to comply with a legal obligation; or in rare circumstances
 Where we need to protect your interests (or someone else's interests); and/or
 Where it is needed in the public interest or for official purposes

What are we going to do with your information?
We will hold and use personal information about you in the following ways:
 To fulfil our obligations to you when providing you with our property services
 To share your information with others where necessary to fulfil our property
services for you or where acting as agent for a third party on your behalf
 To comply with our statutory and regulatory obligations, including [verifying
your identity, prevention of fraud and money laundering and to assess your
credit worthiness
 Communicate with you during the course of providing our services, for
example with your enquiries and requests

 Statistical purposes so we can analyse figures to help us manage our
business and plan strategically for the future
 To provide you, or to enable third parties to provide you, with information
about goods or services we feel may interest you, where you have provided
permission for us to do so or, if you are an existing customer only, where we
choose to contact you by electronic means (including e-mail or SMS) with
information about our own goods and services similar to those which you
have already obtained from us or negotiated to obtain from us . For those
marketing messages you can unsubscribe at any time
 Track your use of our service including your use of our App in order to
improve these
 To notify you about changes to our service
 To ensure that content from our site is presented in the most effective manner
for you and for your computer

How long we keep your data for
We will retain your personal data for different periods depending on the service you
have chosen to use us for, which may be a longer period than that for which we need
to hold your data to provide those services, i.e. where we are under regulatory or
statutory duties to hold your data for a longer period or need to retain it in the event
of a legal claim or complaint.

Who your information will be shared with
We will pass your details to the following organisations (our “data processors”) who
carry out certain activities on our behalf as part of us providing our services: INSERT
e.g. payment service providers, property management agents, credit reference and
fraud prevention agencies, cloud computing host providers, technical support service
providers, advertising networks services, email marketing services etc].
We will also pass your details where necessary to your property solicitors and those
of the other party to your transaction. We will also disclose your personal information
to third parties:

 In the event that we sell or buy any business or assets, in which case we will
disclose your personal data to the prospective seller or buyer of such business or
assets.
 If our company or substantially all of our assets are acquired by a third party, in
which case personal data held by us about our customers will be one of the
transferred assets.
 If we are under a duty to disclose or share your personal data in order to comply
with any legal or regulatory obligation, or to protect the rights, property, or safety
of our company, our customers, or others. This includes exchanging information
with other companies and organisations for the purposes of fraud protection and
credit risk reduction.

We will not share your information with third parties for marketing purposes without
first obtaining your prior consent.
Security of your data
Your data will be held on secure servers within the European Economic Area
("EEA") with all reasonable technological and operation measures put in place to
safeguard it from unauthorised access. Where possible any identifiable information
will be encrypted or minimised.
If we have given you a username and password which enables you to access certain
parts of your matter on our systems, you are responsible for keeping it confidential.
Please do not share it with anyone.
Your rights
How you can access and update your information
You have a right to request a copy of the personal information we hold about you,
known as a data subject access request. You also have the right to request that
information we hold about you which may be incorrect, or which has been changed
since you first told us, is updated or removed. These requests are free of charge and
can be sent to Nicola Hill 7 Kingston Hill Kingston upon Thames KT2 7PW.
How you can request erasure of your data

You can ask us to delete or remove personal data where there is no good reason for
us continuing to process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right to object to
processing (see below), where you have withdrawn consent for us to process it (as
explained below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local law. Note,
however, that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time of your
request.

How you can withdraw your consent
You have the right at any time to withdraw any consent you have given us to process
your personal data. Please note if you withdraw your consent it will not affect the
lawfulness of any processing of your personal data we have carried out before you
withdrew your consent. Should you wish to do so you can change your consent
preferences at any by contacting us at mail@carringtonsproperty.com

How you can restrict or object to us using your data
You can ask us to suspend the way in which we are using your information in certain
scenarios, or object to our processing your data where we are relying on a legitimate
interest ground (or those of a third party) and you feel it impacts on your fundamental
rights and freedoms, or where we are processing your personal data for direct
marketing purposes. In some cases where you object, we may demonstrate that we
have compelling legitimate grounds to process your information which override your
rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may
impact on our ability to provide our services. Depending on the extent of your
request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent
to Nicola Hill at 7 Kingston Hill , KT2 7PW

Moving your information to another organisation
In the event that we process your data by automated means where you have either
provided us with consent for us to use your information or where we used the
information to perform a contract with you, you have the right to request that we send
to you or to another organisation, a copy of the personal data we hold about you, for
example when you are dealing with a different service provider. If you would like us
to move, copy, or transfer your information please let us know by email to
mail@carringtonsproperty.com. We will respond to you within one month after
assessing whether this is possible, taking into account the technical compatibility
with the other organisation in question.

Complaints about the use of your personal data
If you wish to raise a complaint on how we have handled your personal data, you
can contact us to have the matter investigated by writing to Nicola Hill, 7 Kingston
Hill, KT2 7PW.
If you are not satisfied with our response or believe we are processing your personal
data not in accordance with the law you can complain to the UK data protection
regulator, the Information Commissioner’s Office. Further details can be found at
www.ico.org.uk or 0303 123 1113.

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