1.1 Spence Willard Limited and Kingston and Grist Limited (“We”, “Our”, “Spence Willard”) jointly operate this website and are committed to protecting and respecting your privacy. Spence Willard use the principal of ‘Legitimate Interest’ as the lawful basis for collecting and processing incoming personal data and subsequent ongoing communication regarding property-related matters, for example this could include property matches and marketing information. Separately, where we may approach our clients for cross-selling any products or services, we use the principle of ‘Consent’ as the lawful basis to conduct business. It is easy to withdraw consent (opt-out) by unsubscribing from the communication e-mailed to you or by e-mailing email@example.com with your request.
1.3 For the purpose of the General Data Protection Regulations (GDPR) 2018 (the Regulations), the data controllers are Spence Willard Limited registered at Waterside House, 72a High Street, Cowes, Isle of Wight, PO31 7NE and Kingston and Grist Limited, registered at Spence Willard, The Square, Yarmouth, Isle of Wight, PO41 ONE.
2. Information we may collect from you
Our aim is to maintain your data as accurately as possible and to collect data for a specified, explicit and legitimate reason. The data should be limited to what is necessary for us to provide you with property-related information or undertake business transactions for you. Fair and transparent treatment of your data is essential.
We may collect and process the data about you outlined in the document on the following link:
Spence Willard GDPR Matrix
2.1 Information you give us:
You may give us information about you by filling in forms on our site www.spencewillard.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you search for a property, list your own property, request a valuation on our site, enter a competition, promotion or survey, and when you report a problem with our site.
2.2 Information we collect about you:
With regard to each of your visits to our site we may automatically collect the following information:
2.2.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); 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 methods used to browse away from the page and any phone number used to call us.
2.3 Information we receive from other sources:
We may receive information about you if you use any other websites we operate or the other services we provide. We may also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
3. Uses made of the information
We use information held about you in the following ways:
3.1 Information you give to us
We will use this information:
3.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
3.1.2 to notify owners of properties you tell us you are interested in of your interest;
3.1.3 to store your property preferences and search criteria so that we may contact you with details of properties which may be of interest to you;
3.1.4 to provide details of your property to interested parties if you ask us to provide property marketing services (which we will display on our site, at our offices, in marketing emails and on information sheets we produce to market your property);
3.1.5 to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
3.1.6 to provide you, with information about services we feel may interest you. If you are an existing customer, we may contact you by electronic means (e-mail or SMS), or by post with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you;
3.1.7 to ensure that content from our site is presented in the most effective manner for you and for your computer.
3.2 Information we collect about you
We will use this information:
3.2.1 to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
3.2.3 to allow you to participate in interactive features of our service, when you choose to do so;
3.2.4 as part of our efforts to keep our site safe and secure;
3.2.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
3.2.6 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3.3 Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Disclosure of your information
4.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.2 We may share your information with selected third parties including:
4.2.1 individuals or organisations interested in a property you own if you ask us to provide property marketing services;
4.2.2 individuals or organisations who own a property if you indicate to us that you are interested in that particular property;
4.2.3 business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
4.2.4 advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
4.2.5 analytics and search engine providers that assist us in the improvement and optimisation of our site.
4.3 We may disclose your personal information to third parties:
4.3.1 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;
4.3.2 if Spence Willard Limited or Kingston and Grist Limited or substantially all of either company’s assets are acquired by a third party, in which case personal data held by that company about its customers will be one of the transferred assets; and
4.3.3 if 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 Terms of Website and other agreements; or to protect the rights, property, or safety of Spence Willard Limited, Kingston and Grist Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Where we store your personal data
5.2 Unfortunately, the transmission of 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 your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5.3 You may request details of personal information which we hold about you under the Data Protection Act 1998, however a small fee may be payable if your request is clearly unfounded, repetitive or excessive.
If you would like a copy of the information held on you please write to us at Spence Willard, 72a High Street, Cowes, Isle of Wight, PO31 7NE or email firstname.lastname@example.org.
5.4 If you believe that any information we are holding on you is incorrect or incomplete, please write to us at Spence Willard, Waterside House, 72a High Street, Cowes, Isle of Wight, PO31 7NE or email us email@example.com, as soon as possible. We will promptly correct any information found to be incorrect.
6. Your rights
Your data protection rights are as follows:
1. The right to be informed
2. The right of access
3. The right of rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. The right not to be subject to automated decision-making including profiling
6.2 Our site 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 or such third parties use of your personal data. Please check these policies before you submit any personal data to these websites.
7. Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information can be found on the ICO website www.ico.org.uk).
Spence Willard is registered with the Information Commissioners Office: Reg no: Z3151382
Kingston & Grist is registered with the Information Commissioners Office: Reg no: Z7793766
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