Purpose of this privacy statement

The Shanly Group respects your privacy and is committed to protecting your personal data.

This privacy statement sets out how the Shanly Group collects and processes your personal data, including but not limited to your use of our websites regardless of where you visit them from (including any data you may provide through our websites when you sign up to our newsletters or make an email enquiry) and it tells you about your privacy rights and how the law protects you.

It is important that you read this privacy statement together with any other privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements the other notices and is not intended to override them.

Controller

This privacy statement is issued on behalf of the Shanly Group, which is comprised of Sorbon Homes Limited, Shanly Homes Limited, Sorbon Estates Limited, Sorbon Investments Limited, Shanly Partnership Homes Limited and all associated, subsidiary, holding, related or connected companies, so when we mention the Shanly Group, "we", "us" or "our" in this privacy statement, we are referring to the relevant company or companies in the Shanly Group responsible for processing your data, acting as joint controllers or processors (as the case may be).

 The Shanly Group is not required (nor are its constituent companies required) to appoint a data protection officer but if you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact our Data Privacy Team using the details set out below.

Contact details

Data Privacy Team - Shanly Group,
24-26 Aylesbury End
Beaconsfield
Buckinghamshire
HP9 1LW

Email address: dataprivacy@shanlygroup.com

Telephone number: 01494 671331

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.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

If you fail to provide personal data

Where we need to collect personal data by law, or 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 our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To decide whether to enter into a contract with you

(a) Identity

(b) Contact 

(a) Necessary to protect our legitimate interests
To register you as a new customer

(a) Identity

(b) Contact 

(a) Performance of a contract with you 

Administration purposes

(a) Managing payments, fees and charges;

(b) Collection and recovery of money owed to us, including the tracing of your whereabouts. 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and communications 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to ensure the payment and recovery of debts due to us) 

Management of our relationship with you which will include:

(a) Managing payments, fees and charges;

(b) Collection and recovery of money owed to us, including the tracing of your whereabouts.

(c) Notifying you about changes to our terms or privacy policy

(d) Asking you to leave a review or take a survey


(e) carrying out works to remedy snagging items concerning a new-build property (via one of our customer care teams), a claim under a new-build warranty/guarantee scheme, or the making a maintenance request in relation to a managed residential and/or commercial property. 

(a) Identity

(b) Contact

(c) Financial


(d) Transaction


(e) Profile


(f) Marketing and communications 

(a) Performance of a contract with you


(b) Necessary to comply with a legal obligation


(c) Necessary for our legitimate interests (to keep our records updated, to recover debts or other monies due to us and to study how customers use our products/services) 

Managing risks relating to our business(es), including credit risk, fraud risk and operational

risk 

(a) Identity


(b) Contact


(c) Financial


(d) Transaction


(e) Profile 

(a) Necessary for our legitimate interests (assessing your creditworthiness and making affordability decisions, including where you are a prospective tenant or guarantor for a short-term residential letting or commercial letting and for the development of risk management policies, models and procedures used both in the management of our relationship with you and within our business(es) generally). 

Enable you to partake in a prize draw, competition or complete a survey

(a) Identity


(b) Contact


(c) Profile


(d) Usage


(e) Marketing and communications 

(a) Performance of a contract with you


(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) 

Administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity


(b) Contact


(c) Technical 

(a) 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)


(b) Necessary to comply with a legal obligation 

Deliver relevant content and marketing material to you and measure or understand the effectiveness of the marketing material we provide to you, including If you have expressed an interest in a specific property and/or development. 

(a) Identity


(b) Contact


(c) Profile


(d) Usage


(e) Marketing and communications


(f) Technical 

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)
Use data analytics to improve our websites, products/services, marketing, customer relationships and experiences

(a) Technical


(b) Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy) 

Make suggestions and recommendations to you about products or services that may be of interest to you, including the provision of information concerning a specific property and/or development, type of property and/or development or similar properties and/or developments to those in which you have expressed an interest. 

(a) Identity


(b) Contact


(c) Technical


(d) Usage


(e) Profile 

Necessary for our legitimate interests (to develop our products/services and grow our business) 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us in connection with our properties or developments, where you have previously purchased or let a property from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any company outside the group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

Owing to the global nature of internet and cloud-based infrastructure, your personal data may be transferred outside the UK and the European Economic Area. Whilst some countries have adequate protections for personal data under the laws applicable in those countries, in other countries steps will be necessary to ensure appropriate safeguards are in place. We use a number of cloud-based applications and support services provided by third party providers who (and whose servers) are based outside the EEA. We take appropriate steps to ensure that any such third parties provide an adequate level of protection in relation to any information you provide.

By providing your personal data to us in accordance with this policy, you consent to any such transfers of any information outside of the EEA.

Data security

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. In addition, we limit access to your personal data 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You acknowledge that the transmission of information (including your personal data) to us via the internet is not completely secure. Although we will do our best to protect your Information as set out above, we cannot completely guarantee the security of information (including your personal data) transmitted to us via our websites or by e-mail.

Making a request to access to access your personal data

Article 15 of the General Data Protection Regulation ((EU) 2016/679) (GDPR) grants you the right to access your personal data held by us , including the right to obtain confirmation that we process your personal data, receive certain information about the processing of your personal data and obtain a copy of the personal data we process.

In order to make it easier for you to make sure you have provided us with all relevant information, and for us to process your request, we would invite you to complete our data subject access request form which can be downloaded here Once completed the form should be submitted electronically by e-mail to dataprivacy@shanlygroup.com.

Alternatively, the completed form may be sent to:

Data Privacy Team - Shanly Group,
24-26 Aylesbury End
Beaconsfield
Buckinghamshire
HP9 1LW

No fee usually required

You will not have to pay a fee to access your personal data (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 may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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