Privacy Policy

ABOUT THIS POLICY

This policy describes how we use your personal data when you use our website (www.denburyhomes.co.uk), enquire about or buy one of our properties. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

This policy tells you:

• Who we are and how you can contact us
• Our data compliance manager
• What personal data we collect about you
• What we use your personal data for
• Cookies
• Consent and other legal grounds for processing your personal data
• Personal data you are legally obliged to provide
• Your rights to know what personal data we hold and to control how we use it
• Automated decision making and profiling
• When we will share your personal data with others
• How we keep your personal data safe
• How we use your personal data for marketing
• When we will send your personal data to other countries
• How long we keep your personal data
• How you can make a complaint
• How we keep this policy up to date

Who we are and how you can contact us

We are Denbury Homes Limited (company registration number 02162164), with registered offices at Denbury Homes, Westley Bottom, Bury St Edmunds, Suffolk, IP33 3WD.

Denbury Homes Limited act as data controllers and are referred to as “Denbury Homes”, “we” or “us” in this policy.

You can contact us in writing at Denbury Homes, Westley Bottom, Bury St Edmunds, Suffolk, IP33 3WD or if you would like to speak to us please call us on 01284 653 090.

Our data compliance manager

We have appointed a data compliance manager who acts as our primary point of contact for any questions or concerns you may have regarding our handling of your personal data.

You can contact our data compliance manager using the detail set out in the Who we are and how you can contact us section above. Please mark your correspondence “FAO Data Compliance Manager”.

What personal data we collect about you

We collect:

• personal data that you provide to us. You may share your personal data with us when you enquire about our properties or when you contact us about a property you are in the process of buying or have already bought. The personal data that you provide to us may include your name, address, e-mail address and phone number, details of your household and professional advisors and other details that may be relevant to your property purchase.
  
• personal data that we receive from third parties. We may receive personal data about you from other companies that we engage with in relation to your property purchase or that we contract to help us maintain your property. For example, we may receive details concerning a mortgage you obtain to fund your property purchase or information regarding the sale of another property you currently own from your mortgage broker, estate agent or solicitor (or from professional advisors acting for another party in the same chain) or we may receive feedback from our specialist contractors that we instruct to make repairs or alterations to your property.
  
• personal data about your use of our website. This is technical information and includes details such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or properties 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), and any phone number used to call our customer service number.

What we use your personal data for

We use your personal data in the following ways:

• personal data that you provide to us is used to:
  • provide you with the information that you request from us and handle your property purchase
  • provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
  • manage and administer our business
  • review and improve our properties
  • review and improve our customer service experience
• personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
• personal data about your use of our website is used to:
  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
  • as part of our efforts to keep our site safe and secure
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • to make suggestions and recommendations to you about our properties and developments that may interest you

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

Consent and other legal grounds for processing your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:

• we are entering into and carrying out our obligations under a contract with you
• we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our customer service) and our doing so will not interfere with your privacy rights
• we are subject to legal obligations that require us to use your personal data in certain ways (such as disclosing information to HM Revenue & Customs)

The most common situation in which we will process your personal data on the grounds of consent is where we wish to send marketing communications to you. Please refer to the section on How we use your personal data for marketing to read about our marketing practices.

In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent.

You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.

To help you better understand the legal grounds we rely on for different types of processing, we have set out an overview of the main processing activities we undertake and the relevant legal grounds below:

Categories of personal data used	Purpose	Legal basis
Name and contact details	To respond to your enquiries regarding our properties	Legitimate interest (in growing our business and developing new customer relationships) and/or contractual necessity
Name and contact details, details of your household and professional advisors, transaction history	To enable your purchase of a property	Contractual necessity and/or legitimate interests (to facilitate timely and efficient transactions)
Name and contact details, transaction history	To manage our relationship with you e.g. to keep your details up to date and notify you of any changes to our contractual documents or privacy policies	Contractual necessity and/or legitimate interests (to keep our records updated and maintain our customer relationship)
Name and contact details, transaction history, details of your interests and preferences, technical data about your use of our website and your marketing preferences	To send you appropriate marketing communications in accordance with your marketing preferences	Consent and/or legitimate interests (to grow and develop our business)
Name and contact details, transaction history, technical data about your use of our website	To manage and administer our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Legitimate interests (to run our business, provide administration and IT services, ensure network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercises) and legal obligations
Name and contact details, transaction history, details of your interests and preferences, technical data about your use of our website and your marketing preferences	To develop and improve our website and our customer relationships and experience]	Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to improve our products and services and to inform our marketing strategy)

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to proceed with a property purchase.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right (or any of the other rights described below) by sending our Data Compliance manager a written request at any time. Please mark your letter “Data Subject Request” and send it to our Data Compliance Manager (see the section on Our data compliance manager for contact details).

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
• have inaccurate personal data corrected, blocked or erased
• object to decisions being made about you by automated means or to your personal data being used for profiling purposes
• restrict our use of your personal data
• require that we delete your personal data (the “right to be forgotten”)
• require that we provide you, or anyone that you nominate, with a copy of personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

• the business partners, suppliers and sub-contractors we work with to enable you property purchase and to assist in dealing with any snagging issues following your purchase:
  • legal service providers who assist us in relation to your conveyance
  • accountancy service providers who advise us in relation to the general management and administration of our business
  • building contractors who may deal with snagging issues
  • our building warranty provider, NHBC. For more information about NHBC, please read their Privacy Notice at HTTP://WWW.NHBC.CO.UK/LEGAL/PRIVACYPOLICY/
  • utility service providers who provide essential utilities and services to your property
  • financial service providers who administer agreements on our behalf e.g. shared equity loans
  • IT support providers who keep our internal systems and networks running smoothly
  • analytics and search engine providers that assist us in the improvement and optimisation of our site
  • HM Revenue & Customs

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website TERMS OF USE or other agreements we may enter into with you; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:

• only storing your personal data on our secure servers
• using appropriate encryption technique’s including file encryption, point to point encryption and SSL and TLS
• ensuring that our staff receive regular data security awareness training
• keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
• maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
• enforcing a strict policy on the use of mobile devices and out of office working
• limiting access to data on a need to know basis
• adopting IT authentication

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about, or buy, one of our properties and have not opted-out of receiving our marketing communications
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our properties
• you have specifically asked to receive marketing communications

We may contact you for marketing purposes by email, telephone and post.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about particular types of properties or developments in specific locations or you may ask us not to send you any marketing communications at all.

You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

You can opt out of receiving our marketing communications at any time by following the unsubscribe instructions you will find in each marketing communication or by contacting us at any time using the details in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

We do not send your personal data outside Europe.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice this means that we will keep:

• your name and contact details for marketing purposes until you tell us you no longer wish to receive our marketing communications or until we are notified that the contact details we hold are no longer current
• a record of property purchase (including a copy of your conveyance records and details of any aftercare services) for 11 years from property purchase.
• complaint records for 11 years from property purchase.

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

If you have any questions about our data retention practices please contact data compliance manager (see the section on Our data compliance manager for contact details).

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact our data compliance manager to discuss this using the contact details set out in the Who we are and how you can contact us section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.

Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

This is policy version V1.2 which came into effect on 4th June 2018.