PRIVACY NOTICE

R&R (Cornwall) Ltd is committed to protecting your privacy and handling your personal information responsibly. This Privacy Notice explains how we collect, use, share and protect your personal information and the rights you have in relation to it.

In this Privacy Notice, “R&R (Cornwall) Ltd”, “Rohrs & Rowe”, “we”, “us” and “our” refer to R&R (Cornwall) Ltd. References to “you” and “your” refer to anyone whose personal information we process.

1. INTRODUCTION

R&R (Cornwall) Ltd is the controller of the personal information that it collects and uses about you.

We will process your personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended from time to time.

This Privacy Notice explains:

• what personal information is;
• what personal information we collect;
• how we collect your personal information;
• how and why we use your personal information;
• the legal bases on which we rely;
• how we share your personal information;
• how long we keep your personal information;
• how we keep your personal information secure;
• how we deal with international transfers of personal information;
• your rights in relation to your personal information; and
• how to contact us or make a complaint.

We may update this Privacy Notice from time to time, including where there are changes to the way we use your personal information, our services or applicable law. The latest version will be published on our website.

2. WHAT IS PERSONAL INFORMATION?

Personal information, also known as personal data, is any information relating to an identified or identifiable individual. This may include your name, contact details, date of birth, financial information and information about your individual needs or circumstances.

Certain types of personal information receive additional protection under data protection law and are known as “special category data”. This includes information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data used for identification, health, sex life or sexual orientation.

Information relating to criminal convictions and offences is also subject to additional legal protections.

Where we process special category data or criminal offence data, we will only do so where we have both a lawful basis for processing the information and an additional condition permitting us to process that type of information under applicable data protection law.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

The personal information we collect will depend on your relationship with us and the services you ask us to provide.

We may collect:

• your full name;
• telephone number, email address and postal address;
• information about the property you are selling or interested in purchasing;
• information about your requirements and preferences;
• information relating to offers, negotiations and property transactions;
• identity and address verification information;
• financial information where relevant to a transaction;
• correspondence and other communications with us; and
• information you provide when making an enquiry, requesting a valuation, registering for property updates or otherwise interacting with us.

Identity and anti-money laundering checks

Where required by law, we will collect information to verify your identity. This may include photographic identification, such as a passport or driving licence, and documentation confirming your residential address.

We may also carry out identity verification, anti-money laundering, sanctions or other checks where required or permitted by law.

Where you are acting on behalf of another person, or are not the legal owner of a property, we may request information demonstrating your authority to act, such as a Power of Attorney, Grant of Probate or other relevant documentation.

Buying and selling property

If you are selling a property through us, we will use your contact and property information to market the property, arrange viewings, communicate with you about enquiries and offers, and progress the transaction.

If you are looking to purchase a property, we may collect information about your property requirements, circumstances and ability to proceed with a purchase.

Where you voluntarily tell us about particular accessibility requirements or other circumstances so that we can help identify a suitable property or make appropriate arrangements, that information may in some cases constitute special category data. Where this is the case, we will only process it where permitted by data protection law.

Marketing

If you ask to receive property alerts, market updates, newsletters or other marketing communications from us, we will collect the contact details and preferences necessary to provide them.

We will maintain a record of your marketing preferences, including where you have asked us not to send you marketing communications.

Website information

When you use our website, we may collect certain technical information about your visit, such as your IP address, browser or device information and information about how you interact with our website.

Some of this information may be collected using cookies or similar technologies. Further information about the cookies and technologies used on our website, including how you can manage your preferences, is available in our Cookie Policy.

4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect personal information directly from you when you contact us, instruct us, register with us, use our website, attend a viewing, make an offer, request information or otherwise communicate with us.

We may also receive personal information about you from third parties where appropriate. Depending on the circumstances, these may include:

• solicitors and other professional advisers;
• other estate agents or property professionals;
• identity verification, anti-money laundering or screening providers;
• people acting on your behalf;
• property owners or prospective purchasers;
• referral or introducer sources; and
• publicly available sources and registers.

Where we obtain information about you from another source, we will handle it in accordance with this Privacy Notice and applicable data protection law.

5. HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?

We will only process your personal information where we have a lawful basis for doing so.

Depending on the circumstances, we may process your personal information because:

• it is necessary to enter into or perform a contract with you;
• it is necessary for us to comply with a legal obligation;
• it is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your interests, rights or freedoms;
• you have given us your consent, where consent is required;
• it is necessary to protect your vital interests or those of another person; or
• processing is necessary for a task carried out in the public interest, where applicable.

Our legitimate interests may include:

• providing, managing and improving our services;
• communicating effectively with clients and prospective clients;
• understanding the property market and the needs of our clients;
• managing and developing our business;
• maintaining accurate business records;
• protecting our business, website and IT systems;
• preventing and detecting fraud or other unlawful activity; and
• promoting our services where permitted by law.

Property transactions

We may use your personal information to:

• provide estate agency services to you;
• market a property on your behalf;
• arrange and manage viewings;
• communicate offers and other information relating to a property;
• establish the position of prospective purchasers;
• negotiate and progress property transactions;
• communicate with solicitors, professional advisers and other parties involved in a transaction; and
• comply with our legal and regulatory obligations.

Marketing

We may use your personal information to send you information about properties, services, news and other matters that we believe may be relevant to you.

Where electronic marketing is subject to the Privacy and Electronic Communications Regulations (PECR), we will only send it where we have the necessary permission to do so. This may be because you have consented to receive it or, where applicable, because the “soft opt-in” for marketing our own similar services applies.

Where we rely on the soft opt-in, you will have been given an opportunity to opt out when your contact details were collected and will be given an opportunity to unsubscribe from subsequent marketing communications.

You can ask us to stop sending you marketing communications at any time.

6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We will only share personal information where there is a legitimate reason to do so and in accordance with applicable data protection law.

Depending on the circumstances, we may share personal information with:

• solicitors, conveyancers and other professional advisers involved in a property transaction;
• sellers, prospective purchasers and their representatives where appropriate for a transaction;
• contractors and suppliers providing services to us, including IT, website, CRM and other technology providers;
• identity verification, anti-money laundering, fraud prevention or screening providers;
• professional advisers, including our accountants, lawyers and insurers;
• regulators, ombudsman services, governmental bodies, law enforcement authorities, courts and tribunals where required or permitted by law; and
• prospective purchasers, investors or advisers in connection with a sale, merger or reorganisation of all or part of our business.

Where a third party processes personal information on our behalf, we require it to provide appropriate protection for that information in accordance with applicable data protection law.

We will not sell your personal information to third parties.

7. WHAT HAPPENS IF YOU DO NOT PROVIDE INFORMATION WE REQUEST?

We need certain personal information in order to provide our services or comply with our legal obligations.

For example, if we are selling a property on your behalf, we need appropriate contact and property information in order to provide that service. We may also need identity and other information to comply with our obligations relating to anti-money laundering, fraud prevention and other legal requirements.

If you do not provide information that we reasonably require, we may be unable to provide or continue providing some or all of our services to you. We will explain where this applies when requesting the relevant information.

8. HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We take the security of your personal information seriously and use appropriate technical and organisational measures designed to protect it against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures include restricting access to personal information to employees, workers, contractors and service providers who have a legitimate business need to access it.

Personal information held electronically is stored using systems with appropriate security and access controls. Where we retain physical records containing personal information, appropriate measures are used to protect them from unauthorised access.

People working for us who have access to personal information are required to handle it appropriately and receive relevant guidance or training.

9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will retain your personal information only for as long as reasonably necessary for the purposes for which it was collected, including to meet any legal, regulatory, accounting or reporting requirements and to establish, exercise or defend legal claims.

The appropriate retention period will depend on factors including:

• the type and sensitivity of the information;
• the purpose for which we collected and use it;
• the duration of our relationship with you;
• applicable legal and regulatory retention requirements;
• relevant limitation periods for potential legal claims; and
• whether we have an ongoing legitimate business need to retain the information.

Different retention periods may therefore apply to client and transaction records, identity and anti-money laundering records, enquiries and marketing information.

Where you have opted out of marketing, we may retain limited information on a suppression list so that we can respect your preference and avoid contacting you again for marketing purposes.

When personal information is no longer required, we will securely delete, destroy or anonymise it as appropriate.

10. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

Some of our suppliers or service providers may store or process personal information outside the United Kingdom.

Where personal information is transferred to a country outside the UK, we will ensure that the transfer complies with applicable UK data protection law.

Depending on the circumstances, this may include:

• transferring personal information to a country or organisation covered by UK adequacy regulations;
• using an approved transfer mechanism, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with any required transfer risk assessment;
• where applicable, transferring information to a US organisation participating in the UK Extension to the EU-US Data Privacy Framework; or
• relying on another permitted exception or safeguard under UK data protection law.

You may contact us if you would like further information about the safeguards used for international transfers relevant to your personal information.

11. YOUR RIGHTS

Depending on the circumstances, you have a number of rights in relation to your personal information.

These may include the right to:

• be informed about how we collect and use your personal information;
• access the personal information we hold about you;
• rectify inaccurate or incomplete personal information;
• request erasure of your personal information in certain circumstances;
• restrict processing of your personal information in certain circumstances;
• data portability, allowing you in certain circumstances to receive personal information you have provided to us in a structured, commonly used and machine-readable format;
• object to processing based on our legitimate interests or certain public-interest grounds; and
• withdraw your consent at any time where we rely on consent to process your personal information.

You also have rights relating to certain decisions based solely on automated processing which produce legal or similarly significant effects.

Not all of these rights apply in every circumstance, and we may be entitled or required to continue processing information in certain circumstances despite a request from you.

Your right to object

You have the right to object at any time to the processing of your personal information for direct marketing purposes. If you object to direct marketing, we will stop using your personal information for that purpose.

Where we process your information on the basis of legitimate interests, you may also have the right to object. We will consider your objection and stop the relevant processing unless we have compelling legitimate grounds to continue or the processing is required for the establishment, exercise or defence of legal claims.

You can exercise your rights by contacting us at info@rohrsandrowe.co.uk.

We will not normally charge a fee for dealing with a request, although the law allows us to charge a reasonable fee or refuse to act in certain limited circumstances.

12. MAKING A COMPLAINT

If you have concerns about how we collect or use your personal information, we would appreciate the opportunity to address them. Please contact us using the details below.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

You can find further information about your rights and how to make a complaint here.

13. CONTACT DETAILS

If you have any questions about this Privacy Notice or would like to exercise any of your data protection rights, please contact us:

Email: info@rohrsandrowe.co.uk

Post:
R&R (Cornwall) Ltd
Beacon Place
Station Approach
Victoria
Cornwall
PL26 8LG