Mandale Homes of Mandale House 5 Neville Road, North Tees Industrial Estate, Stockton-On-Tees, United Kingdom, TS18 2RD (we, our or us) are committed to protecting and respecting your privacy. We are the data controller of any personal data we process for our business purposes and are responsible for this personal data.
This policy sets out the basis on which any personal data we collect from you, our buyers, tenants, customers, prospective buyers, tenants and customers and website users, will be processed by us.
2. Information we may collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you such as:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data 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 goods or services).
3. How is your personal data collected?
We only collect data from and about you that you may give us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you, for example, enquire about a property and arrange a viewing; create an account with us; request a brochure; enter a promotion or survey; or give us some feedback.
Monitoring: We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
Credit checking: To enable us and other companies in our group to make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). If you provide false or inaccurate information and we suspect fraud, we may record this.
4. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or buyer, or to register your interest as a potential customer or buyer.||Performance of a contract with you (or expectation of a contract with you).|
|To add you to our mailing list or to send you information we believe you will be interested in.||Legitimate interest to manage our relationships with customers, visitors & buyers|
|To manage the sale of a property to you, including:
to manage all accounts payments, fees and charges; and to collect and recover money owed to us; and
to complete your property warranty, utility and supplier agreements
|Performance of a contract with you
|To manage our properties and developments||Performance of a contract with you and our legal obligation|
|To respond to any website and telephone queries or complaints||Consent if you have asked us to respond, and for our legitimate interests to manage our relationships with customers, visitors and buyers.|
|To ask you to leave a review or take a survey, or to participate in market research.||Necessary for our legitimate interests, to keep our records updated and to understand how customers use our products/services, to develop them and grow our business.|
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Necessary for our legitimate interests, for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||In some instances, this may be necessary for our legitimate interests, to develop our products/services and grow our business, and we may send you marketing information on this basis if you have given us your details in the course of a sale or pre-sale negotiations, and we are marketing similar products or services. We will give you the opportunity to opt out of marketing in every instance of contact.
In others we will only send you marketing emails or communications if we have your consent.
5. Disclosure of your personal data
We may need to share your personal information with any member of our Mandale Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may share your 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 finance partners, warranty providers, and utility, interior or maintenance suppliers;
- analytics and search engine providers that assist us in the improvement and optimisation of our website;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services; and
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if all, 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; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, for example to local authorities, or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org
7. International Transfers
We do not in the course of our standard business functions transfer your personal data outside the European Economic Area (EEA).
We only transfer personal data out of the EEA where we have ensured adequate safeguards are implemented, or where the transfer is necessary for the conclusion or performance of a contract in the interest of the data subject.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, and only authorised staff or third parties can access and use personal data. However, the transmission of information via the internet is not completely secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We keep personal data in line with our following retention schedule.
We will not keep your personal data in an identifiable form for longer than is necessary for the purposes for which the data is processed, including for the purpose of satisfying any legal, accounting or reporting requirements. Once your personal data is no longer needed, it is deleted or anonymised in accordance with our data retention guidelines.
By law we have to keep basic information about our customers, clients, suppliers and contractors for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (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.
|Type of data||Retention Period||Reason for retention|
|Visitor Book||Destroyed weekly||Legal obligation with regards to health and safety monitoring|
|Complaints & responses||Retained for 8 years from date of first complaint, or until 1 year after NHBC or similar warranty expires, whichever is soonest||Information retained in case complaint is ever escalated with the warranty provider.|
|Accident books||10 years from date of accident||To ensure that records are kept in case of a back dated review|
|Telephone logs||max 3 months||To protect our and your interests|
|Property ownership and services responsibility database||10 years from completion of last unit on development||Service providers can currently back-charge up to 10 years of bills. To review this if legislation changes|
|Services responsibility forms||10 years from completion of last unit on development. Emails are archived after 18 months.||Service providers can currently back-charge up to 10 years of bills. To review this if legislation changes|
|Credit card payments||Credit card receipts are retained until no longer than 2 weeks. Electronic record retained for 6 years.||As long as necessary and in accordance with accounting record retention regulations. We are fully compliant with PCI DSS|
|Financial and accounting information, including purchase orders, invoices, remittances, receipts||6 years||In accordance with accounting record retention regulations.|
|Buyer details||Emails deleted as soon as details uploaded & sales enquiry form completed.||No retention|
|Sales progression database||6 years||In accordance with accounting record retention regulations.|
|Details from sales enquiry forms||After direct marketing is completed, information used is stored within direct marketing log on the server. Retained for 5 years from date of DM campaign.||In accordance with GDPR regulations|
|Web & telephone enquiries||Max 6 month retention||To ensure that customer care standards can be maintained and audited.|
|Sales Enquiry Forms||Destroyed once last plot on site has completed. (Purchaser enquiry forms retained in plot file)||To protect your interests and for the performance of a contract with you.|
|Plot file||3 years from completion of the last plot||To protect our & your interests|
|Tenant Database||For period of lease||So this can be referred to in case of any queries|
|Call reports||1 year||To review calls & customer service|
|Buyers contact details||Until warranty period has expired on last plot of that development||Customer service|
|Buyers snagging database||5 years from completion of last unit on development||Customer service and for record if any claims raised through warranty provider|
|Buyer correspondence||5 years from completion of last unit on development||Customer service and for record if any claims raised through warranty provider|
10. Third Party Links
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
11. Your rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”).
Request correction of any inaccurate personal data that we hold about you.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Complain you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.