Introduction

Personal information (often referred to as personal data) is any information which relates to an individual who can be identified.

Data Controller

For the purpose of EU General Data Protection Regulation ((EU) 2016/679) the data controller (i.e the person responsible for your personal information) is Carey  Group Plc.

How to Contact Us

If you have any questions about this privacy policy including any requests to exercise your legal rights please contact us by using the contact details below:

Postal address:

Carey Group Privacy Manager
Carey House, 
Great Central Way, 
Wembley, Middlesex, 
HA9 0HR.  

Email: communcations@careysplc.co.uk

If you are unhappy about the way in which we have handled your personal information, please let us know using any of the contact details above. You also have the right to complain to the Information Commissioner’s Office who is the UK’s supervisory authority for data protection issues (their website is at https://ico.org.uk/). 

Any reference to “we”, “us” or “our” in this privacy policy is a reference to Carey Group Plc.

Information we collect from you

This may include your name, postal address, email address, telephone number, the reason for your move, your requirements in relation to a property, your budget and the financial method you intend to use to purchase a property.

Purposes for which we will use your personal information and our legal basis for doing so

We will only use your personal information when we have a legal basis for doing so. 

The personal information that you provide to us will be used for the following purposes, relying on the following legal bases:

  • Contact Details
    Purpose
    (a) to respond to your query and to register your interest in one of our new home developments (if applicable)
    (b) to make suggestions to you regarding other new home developments which may be of interest to you (if you have already registered an interest in one of our developments and have not asked us not to contact you)
    (c) to notify you about changes to our privacy policy
    (d) to ask you to complete a survey
    (e) to enable you to participate in competitions

    Legal Basis
    (a) The processing is necessary in order to take steps at your request prior to entering into a possible contract
    (b) The processing is necessary for our legitimate interest of marketing and growing our business
    (c) The processing is necessary to comply with a legal obligation relating to changes to our privacy policy
    (d) The processing is necessary for our legitimate interest of monitoring our visitor’s opinions of us and our website
    (e) The processing is necessary for the performance of a contract with you (the contract which is formed when you enter a competition)
  • Reason for your move
    Purpose
    This information enables us to better select a property which is suitable for your needs. 

    Legal basis
    The processing is necessary for our legitimate interest of improving our service offering to you.
  • Your requirements in relation to a property
    Purpose
    This information enables us to better select a property which is suitable for your needs. 

    Legal basis
    The processing is necessary for our legitimate interest of improving our service offering to you.
  • Your budget
    Purpose
    This information enables us to focus on properties that are within your budget.

    Legal basis
    The processing is necessary for our legitimate interest of improving our service offering to you.
  • The financial method you intend to use for your purchase
    Purpose
    This enables us to understand the timescales for completion of a property purchase and the third parties with whom we may need to liaise. 

    Legal basis
    The processing is necessary for the performance of a contract with you.

Marketing

If you have registered an interest in one of our new home developments we would like to send postal and email communications to you and make telephone calls to you regarding that development and other developments which may be of interest to you.  You will be given the opportunity to opt out of receiving these communications at the time which we collect your information.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your personal information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, if you decide to purchase a new home from us we will need to share your personal information with our solicitors to liaise with you regarding the legal process of the sale, NHBC in relation to the insurance warranty provided with your property, maintenance companies to fix any issues you may have with your property within the warranty period and the local authority and utility providers in order to transfer the local council tax account to you and the various utility accounts to you.

We may also disclose your personal information to third parties:

  • If we conclude that is required by law or in good faith believe that access, preservation or disclosure of the data is reasonably necessary to protect the rights, property, or safety of Carey Group Plc or any member of its group, its users or the public.
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
  • If Carey Group Plc or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.

In all such circumstances we will use reasonable efforts to ensure that the minimum possible personal information is shared and the parties with which the information is shared are subject to an agreement that obliges them to process your personal information on our instruction and with appropriate confidentiality and security measures.

Where we store your personal data (Transfers outside of the EEA)

Some of our service providers are based outside of the European Economic Area (EEA) so their processing of your personal information will involve a transfer of your personal information outside of the EEA.

Whenever we transfer your personal information outside the EEA we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. 
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data protection breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention of your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes listed above and/or to exercise our legal rights or comply with our legal obligations.

To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In some circumstances you can ask us to delete your personal information. Please see further information within Your Legal Rights section below. 

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

Your Legal Rights

Under data protection laws, you have the following rights in relation to your personal information: 

  • Request access to your personal information
    This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of personal information that we hold about you
    This enables you to have any incomplete or inaccurate information we hold about you corrected. Please note, we may need to verify the accuracy of any new details you provide.
  • Request erasure of your personal information
    This enables you to ask us to delete personal information where there is no good reason for us continuing to process it. This may also apply where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to delete your personal information to comply with local law. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing
    This enables you to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your personal situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Right to withdraw consent
    You may withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request to transfer information
    This enables you to request the transfer of your personal information to you or a third party. We will transfer the data in a structured, commonly used, machine readable format. This right applies only in respect of automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to make a complaint to a supervisory authority
    You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance. 

A full list of the data protection authorities in the EU, and the relevant contact details can be found at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

If you wish to exercise any of the above rights, please contact us using the details provided in the How to Contact Us section above. 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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