Our registered office is at 169 Newhall Street, Birmingham, B3 1SW

This is a notice to tell you our policy about all information that we record about you. It covers both information that could identify you and information that could not.

We are extremely concerned to protect your privacy and confidentiality. We understand that all users of our web site are quite rightly concerned to know that their data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. Our policy is both specific and strict. It complies with UK law. If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.

Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected at this site.

Here is a list of the information we collect from you, either through our web site or because you give it to us in some other way, and why it is necessary to collect it:

1.     What is personal Data?

Personal data is, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers

 

2. Where we get personal information from?

·        Information we collect when you visit our website

·        Information we collect directly from you, either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet

·        Information provided to us by third parties

·        Information from publicly available sources, for example, Companies House, Land Registry

2. What information we collect from you

We may collect some or all of the following personal information depending on the service we are completing for you:

·         Full Name

·         Email address

·         Contact telephone numbers

·         Postal address

·         Date of birth

·         Gender

·         Next of kin

·         Job title

·         Profession

·         Financial information, such as earnings

·         Payment information (bank account and debit card details)

·         Your marketing preferences

·         Your communication preferences

Further information may be requested from you during the course of our relationship which is relevant to the provision of specific services.

3. Basic identification and contact information

Your personal information may be used for the following purposes:

·         to comply with our legal and regulatory obligations

·         to provide and manage your account;

·         to provide and manage access to our site;

·         to provide you with the services which you request;

·         for verifying your identity for security purposes;

·         to provide property management services;

·         to communicate with you

·         for marketing our services and products;

·         Information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.

3.1 Credit Scoring

We use the services of a third party for carrying out automated decision and/or credit scoring to determine if we are able to provide a service. This helps make fair and reasonable decisions and we will always contact you to discuss any outcomes.

3.2 Vouch, Rental Exchange (for managed tenancies)

We have teamed up with Vouch to take part in The Rental Exchange. The Rental Exchange is a way to strengthen your credit report without you needing to take on new credit. The scheme enables us to share details about the rent you pay with Experian on a monthly basis. This is then included in your credit report, meaning you will then be recognised for paying your rent on time.

Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Vouch to use the information supplied to them to assist other landlords and organisations to:

·        assess and manage any new tenancy agreements you may enter into;

·        assess your financial standing to provide you with suitable products and services;

·        manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;

·        contact you in relation to any accounts you may have and recovering debts that you may owe;

·        verifying your identity, age and address, to help other organisations make decisions about the services they offer;

·        help to prevent crime, fraud and money laundering;

·        screen marketing offers to make sure they are appropriate to your circumstances;

·        for Vouch to undertake statistical analysis, analytics and profiling,

·        and for Vouch to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.

4. Lawful basis for processing

Empire Lettings & Property Management processes your information under any of the following lawful conditions:

4.1 Performance of a contract – this is where the collection and processing of your data is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract

4.2 Legal obligation – this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example verification of identity and fraud prevention

4.3 Consent – where we process information under consent we will seek your clear and unambiguous consent before processing your data

4.4 Legitimate interests – some information is processed by Empire Lettings & Property Management as part of its legitimate interests which include network and information security, opting out of communications, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided

5. Retention of your personal information

Personal data is only retained for as long as necessary for the purpose of processing. Retention periods can vary based on the purpose the data was provided, the requirements of the business and the lawful reason for processing.

There are some legal requirements which apply to personal data retention; our minimum retention period is 12 months and the maximum period is 7 years from the date the business transaction is ended.

Where there are no legal requirements, data is destroyed or deleted;

·         when you withdraw your consent

·         when the data is no longer up to date

·         the purpose for which is was provided is no longer valid

5.1. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

6. Your domain name and e-mail address

Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded.

We shall not under any circumstances divulge your e-mail address to any person who is not an employee or contractor of ours and who does not need to know, either generally or specifically.

This information is used:

6.1. to correspond with you or deal with you as you expect.

6.2. in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our site;

6.3. to send you news about the services to which you have signed up;

6.4. to tell you about other of our services or services of sister web sites.

7. Information you post on our website

Information you send to us by posting to a forum or blog is stored on our servers. We do not specifically use of that information except to allow it to be read, but you will see in our terms and conditions that we reserve a right to use it in any way we decide.

8. Website usage information

We may use software embedded in our website (such as JavaScript) to collect information about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page, and how we perform in providing content to you.

9. Financial information relating only to your debit cards

This information is never taken by us either through our website or otherwise. At the point of payment, you are transferred to a secure page on the website of WorldPay / SagePay / PayPal / MoneyBookers or some other reputable payment service provider. That page may be dressed in our “livery”, but it is not controlled by us. Our staff and contractors never have access to it.

10. Note on padlock symbols and other trust marks

Many companies offer certification and an icon or other small graphic to prove to site visitors that the site is safe. Some certify to a high level of safety. We do not handle information about your credit card so do not subscribe to any such service. However, we suggest you assess this notice to judge that we do take your privacy seriously.

11. Financial information about your direct debit or debit cards

When you have agreed to set up a direct debit arrangement, the information you have given to us is passed to our own bank for processing according to our instructions. We do keep a copy.

We are registered under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved “originators” of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.

12. Credit reference

To assist in combatting fraud, we share information with credit reference agencies so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

13. Business and personal information

This includes all information given to us in the course of your business and ours, such as information you give us in your capacity as our client. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect you to reciprocate this policy.

We keep information which forms part of our business record for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it.

14. Third party advertising

Third parties may advertise on our web site. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

15. Cookies

Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we may use cookies:

15.1. to record whether you have accepted the use of cookies on our web site. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you.

15.2. to allow essential parts of our web site to operate for you.

15.3. to operate our content management system.

15.4. to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.

15.5. to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.

15.6. to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.

15.7. to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.

15.8. to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.

15.9. to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.

15.10. to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube’s privacy-enhanced mode.

16. Calling our office

When you call our office, we may collect Calling Line Identification (CLI) information. We use this information to help improve the efficiency and effectiveness of our help line.

Telephone calls either to or from our teams may be recorded for compliance, training and monitoring purposes. Please note any recordings will be held for 2 – 4 weeks before being deleted (this variance is due to storage capacity).

17. Sending a message to our support system

When you send a message, we collect the data you have given to us in that message in order to obtain confirmation that you are entitled to receive the information and to provide to you the information you need. We record your request and our reply in order to increase the efficiency of our business / organisation. We may keep personally identifiable information associated with your message, such as your name or email address.

18. Third party content

Our web site is a publishing medium in that anyone may register and then publish information about himself or some other person. We do not moderate or control what is posted. If you complain about any of the content on our web site, we shall investigate your complaint. If we feel it may be justified, we shall remove it while we investigate. Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content which offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

19. Content you provide to us

If you provide information to us through social media platforms, with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the World, you have no control whatsoever as to how it is used.

20. Marketing information

With your permission we pass your email address and name to selected associates whom we consider may provide services or products you would find useful. You may opt out of this service at any time by instructing us at info@empirelpm.com.

21. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.

22. Affiliate information

This is information given to us by you in your capacity as an affiliate of us or a customer or client of ours. Such information is retained for business use only. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect any affiliate to agree to reciprocate this policy. As an exception to this, we have the right to disclose your first name and URL of your affiliate connection to other affiliates and to any other person or organisation, on and off site. The reason is solely to enable us to mention winners and others whose performance as an affiliate is in some way outstanding.

23. Disclosure to Government and their agencies

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

24. Review or update personally identifiable information

At any time you may review or update the personally identifiable information that we hold about you by contacting us at info@empirelpm.com. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

25. Sale of your personal information

Except as specified above, we do not rent, sell or otherwise disclose any of your information to any person outside our business.

26. Data may be “processed” outside the UK

Our web sites are hosted in the EU. We also use outsourced services in countries outside the EU from time to time in other aspects of our business. Accordingly data obtained within the UK may be “processed” outside the UK and data obtained in any other country may be processed within or outside that country.

27. Compliance with the law

This confidentiality policy has been compiled so as to comply with the law of every jurisdiction in which we aim to do business. Under the GDPR, you have the following rights;

a. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.

b. The right to access the personal data we hold about you.

c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 30.

d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 30.

e. The right to restrict (i.e. prevent) the processing of your personal data.

f. The right to object to us using your personal data for a particular purpose or purposes.

g. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h. Rights relating to automated decision-making and profiling.

28. Removal, modification and viewing of your information

If you wish us to remove personally identifiable information from our web site, you may contact us at info@empirelpm.com. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

29. Your right to complain

Any complaints will be handled under our complaints procedure. A copy can be requested by contacting info@empirelpm.com

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

30. Our contact information

Should you wish to contact us regarding this privacy policy, your personal data and data protection, including to make a subject access request, please use the following details:

by email: info@empirelpm.com

by phone: 0121 541 8850

by post: Empire Lettings & Property Management, 169 Newhall Street, Birmingham, B3 1SW

31. Changes to this Policy

Any changes we may make to this policy in the future will be posted on this page. Please check back from time to time review this Policy and keep up to date.