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Privacy Notice

 

THE HELLIER LANGSTON (HL) PRIVACY NOTICE PROVIDES INFORMATION ON HOW HL AND ANY OF ITS REPRESENTATIVE OFFICES AND ANY 3RD PARTY PROVIDERS COLLECT, USE, SECURE, TRANSFER AND SHARE YOUR INFORMATION.
The Hellier Langston (HL) privacy notice provides information on how HL and any of its representative offices and any 3rd party providers collect, use, secure, transfer and share your information.

Hellier Langston has its head office at:

Hellier Langston
Ground Floor
E1 Fareham Heights
Standard Way
FAREHAM
Hants
PO16 8XT

HL serves various lenders, investors, developers, commercial businesses, corporations, local authorities, housing associations and the general public via the following business units/divisions. Full details of our services provided can be found on our website.

1. Types of information collected
Typically HL collect:

Title
Employer switchboard numbers
DX number
Tenure details for property requirement
First name
Company address
DX exchange
Price band of property requirement
Middle name
Personal email
Landlord details
Surname
Employer email
Tenant details
Residential address
Personal numbers
Lease details
Job title
Employers annual turnover
Size of your property requirement
Department
Size of company you work for
Type of property you are looking for
Employer/ registered company name
Company website
Area of your property requirement

1.1 Methods of Collection
In the general conduct of business, HL collects information relevant to the services being sought across the range of services it offers (listed previously) from:

Yourself
The HL Website
“trusted” sources including Property Portals
through consent to third parties disclosing information about you to us that they have collected
Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our offices or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers. In addition, you may choose to submit information directly to us via several methods, including:

through HL and affiliates websites
in response to marketing or other communications
through social media
by signing up for a HL product or service
through participation in an offer, program or promotion
in connection with an actual or potential business or employment relationship with us
at events, conferences, and seminars
You may also agree to third parties disclosing information about you to us that those third parties have collected.

We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytics services on our websites and mobile apps the analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.

"Your Rights and Choices" section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected.

1.2 Purposes of collection
Generally, we will collect, use and hold your information for the purposes of:

Assessing applications for and providing HL products / services
Conducting business, developing relationships with HL and affiliates
Process payments / transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities
Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes
Create and manage any accounts, associated authentication criteria (IDs and passwords) you may have with HL
Provide, administer and communicate with you about HL products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.
Compile business directories, including business contact information
Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
Developing new products and services
Managing communications, assess effectiveness and optimisation of advertising
Functionality of our websites, mobile applications other digital assets
Evaluate your interest in employment and contact you regarding possible employment opportunities
Enforce HL “Terms of Use”, and / or other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over HL or its affiliates.
Comply with industry standards and HL policies
In order to provide focussed marketing and information
Anti-Money Laundering

In addition to help you with a property related service we have to comply with certain regulations for example the “Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (referred to as “the Regulations).” HL are required to obtain certain information from you to comply with regulations. The information provided will only be used by HL in relation to complying with the Regulations and will not be shared with any other party outside unless we are required to do so under law.

If you decide to enter in to a business relationship with HL to comply with certain regulations:

We will require two separate Identification documents one primary and one secondary document even if it appears on both lists. The information may be required at various stages of the process depending whether you are:

Purchasing (or Selling)
Primary documents - proof of ID

Valid Passport with MRZ
Valid full UK photo driving licence
Valid full UK Driving licence (Non photo, paper) issued before 1998
Valid EU/EEA/Switzerland photo driving licence.
Valid EU/EEA/Switzerland national Identity Card.
Valid UK Armed Forces ID Card.
Valid UK Biometric Residence Permit (copy of both sides.)
Valid Blue disabled drivers pass. (With photo)
Valid Freedom Pass
Valid Local Authority Bus Pass.
Department for Works & Pensions letter confirming pension details including National Insurance Number dated within the last 12 months.
Secondary documents - proof of residence (home.)

Valid full UK photo driving licence.
Valid full UK Driving licence (Non photo, paper) issued before 1998.
Local authority council tax bill (dated within the last 12 months).
UK Bank / Building societies statements/bills showing activity, dated within the last six months. Including account number and sort code. (Internet printed acceptable.)
UK mortgage statement (dated within the last 12 months.) (Internet printed acceptable.)
Utility bill dated within the last 6 months including - Electricity bill (with MPAN number), Landline, Gas, Satellite TV, Water. (Internet printed acceptable.) (Not mobile phone bills.)
Her Majesty’s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement (dated within the last 12 months) with National Insurance number.
Department for Works & Pensions letter confirming pension details and NI Number. (Dated within the last 12 months).
We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search will not affect your credit rating.

1.3 Lawful basis of processing
HL processes your information under the following:

Performance of a contract: where you enter into a contract with HL and we need to process your information as part of this contract
Legitimate interests: some information is processed by HL as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller
Public interest: some information is processed in accordance with public interest such as relocations
Consent: where we process information under consent we will seek you clear and unambiguous consent prior to processing your data
2 Information we share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to:

Vetted affiliates and partners / Financial Institutions / Insurance Companies for business facilitation to provide required services, such as mortgages, insurance cover etc.
Formally contracted service providers to perform services on our behalf:
Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
Helpdesk, Call Centres etc.
We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements

Councils, health and care providers
Law firms
Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies
Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
Prospective employers requesting references via your written consent
On websites, features can be accessed where we partner with other entities that are not affiliated with HL. These include social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties' privacy policies if you use the relevant features.

HL reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect / use your information consistent with our Privacy Notice. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.

2.1 How long do we keep information for?
We will keep information for a reasonable amount of time in order to perform the purposes listed above.

We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However HL reserves the right to keep information for longer if we feel that this is in the legitimate interests of HL.

2.2 International data transfers
HL may transfer the personal information collected about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g. via program specific privacy notice).

2.3 Profiling
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential un-authorised activities, HL engages profiling activities via direct use or anonymisation of sensitive personal information.

2.3.1 Direct profiling
Direct profiling is engaged for the fair and lawful purposes, to provide HL the ability to enforce HL “Terms of Use”, legal reporting as may be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over HL or its affiliates; including, but not limited to:

Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.
Background checks for existing and new employees, clients, business partners, affiliates
Financial Viability analysis / reports
Business partner / client portfolio position, performance, risk positions
Anti-money laundering
Tax reporting
Credit defaulting / exposure

2.3.2 Indirect profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:

Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.
Compiling and communicating promotional and marketing information about products and services that HL, affiliates and other organisations that we have affiliations with have and that may be of interest to you.
Conducting market research
Facilitating our internal business operations, including the fulfilment of any legal requirements.

2.4 Your rights and choices
Your rights regarding the sensitive / personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.

2.5 Access and correction
You may have the right to:

obtain confirmation that we hold personal information about you
request access to and receive information about the personal information we maintain about you
receive copies of the personal information we maintain about you
The right to access personal information may be limited in some circumstances by local law requirements.

To exercise these rights, please contact us as set forth below.

2.6 Update and correct inaccuracies in your personal information
If you feel that the information we hold about you in incorrect or inaccurate you can contact us outlining the information you feel is incorrect of inaccurate

If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint. We will provide you with access to information we hold about you:

2.7 Object to the processing of your personal information
If you would like to object to any processing of your information by HL you can contact us outlining what processing of information you would like to object to.

2.8 Have the information blocked, anonymised or deleted.
If you would like HL to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised.

To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified in the “How to Contact Us” section below.

2.9 Opting out of processing
You can at any time tell us not to send you marketing communications by

e-mail karen@hlp.co.uk
unsubscribing via the “unsubscribe link” within the marketing e-mails you receive from us, or
contacting HL as indicated below.

2.10 Use of cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can use the cookie control popup to control the use of cookies that aren't essential to the website working. Your web browser will also have settings that allow you to prevent any website creating cookies on your computer.

The table below explains the cookies we use and why.

Cookie

Name

Purpose

Cookie preference

cookieconsent_status

This is used to remember your choice on whether to allow cookies on this website.

Website functionality

sourcesession

csrf_source_cookie

These cookies are essential to the functioning of the website and provide security and control access.

Cloudflare

__cfduid

This is set by Cloudflare which is used to provide security and speed up the website. More information can be found on Cloudflare's website.

Google Analytics

_ga

_gat

_gid

These cookies are set by Google Analytics and are used to monitor the pages you go to during a visit to the website. You can find out more about how we use Google Analytics below.

 

Google Analytics

We use Google Analytics to help us monitor visits to the website so that we can make improvements. The information collected is anonymous and is not used in a way that could identify you. We do not implement (or allow Google to) any tracking that could be used to target adverts to you.

If you would prefer us not to collect your website usage data you can opt out by disabling cookies using the cookie control popup on this website. You can also opt out of Google Analytics across all websites by visiting http://tools.google.com/dlpage/gaoptout.

You can find out more about how Google protects collected data at https://support.google.com/analytics/answer/6004245

2.11 Withdrawal of Consent
If we obtain your information by consent you have the right to withdraw any consent you previously provided to us.

If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information.

HL will apply your preferences going forward. Doing so will mean that you cannot take advantage of certain HL and affiliate products, services and promotions.

The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.

You can exercise your right to prevent data processing by following the instructions on the pages where we collect your data or alternatively invoke the right to be forgotten by clicking the Unsubscribe: stop all email communications link listed on all our email communications.

On receipt of this request we will remove your personal data from our central CRM system and all email marketing will cease with immediate effect

3 How to Contact Us / Complaints and Feedback
If you:

would like to make a complaint about a breach of your personal information, applicable privacy laws / principles or a concern about HL privacy practices
would like access and/or update information or preferences you provided to us
You can get in touch through the website

You also may e-mail us at:

karen@hlp.co.uk

Or write to us at:

Matthew Poplett

Data Protection Officer
Hellier Langston
Enterprise House
Ocean Village
Southampton
SO14 3XB

If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us via the details in the "How to Contact Us" section below.

To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.

If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.

3.1 How We Protect Personal Information
The security of your personal information is very important and HL is committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. We use SSL encryption on a number of our websites from which we transfer certain personal information.

HL stores personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it.

4 Updating this privacy statement
We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.

June 2018

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