© 2019 WD Real Estate Ltd

This Privacy Notice explains what data we process, why we process it, how it is legal and your rights.

  1. About us and this notice

  2. Useful words and phrases

  3. What information we collect? 

  4. Why we process your personal date?

  5. How is processing your data lawful?  

  6. When will we delete your data?  

  7. Who will have access to your personal data?

  8. Your rights 

1. ABOUT US AND THIS NOTICE

This Privacy Notice is provided by WD Real Estate Ltd ("WDRE" or "we" or "us") who is a 'controller' for the purposes of the General Data Protection Regulation (EU) 2016/679. This Privacy Notice applies to our tenants, joint venture investors, clients and prospective investors who are interest in our services, as well as all our website visitors. 

Our company is incorporated in England and our registered office is at 83 Sterndale road, London, W14 0HX (registered company number 10742687). We are also registered with the Information Commissioner's Office as a data controller (registration reference ZA346016). 

We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.

How to contact us
If you need to contact us about this Privacy Notice, use the details below :

  • Privacy Manager: Walter Davis 

  • Address: 83 Sterndale Road, London, W14 0HX, UK

  • Telephone number: 020 7602 3116

  • Email: walter@wdrealestate.co.uk

If you would like this Privacy Notice in another format (for example: audio, large print, braille), please contact us.

Changes to this Privacy Notice
The latest version of this Privacy Notice can always be found at www.wdrealestate.co.uk

We may change this Privacy Notice from time to time. We will alert you by posting a notice on our website when changes are made.

2. USEFUL WORDS AND PHRASES

Please familiarise yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice: 

Controller - This means any person who determines the purposes for which, and the manner in which, any personal data is processed.

Criminal offence data - This means any information relating to criminal convictions and offences committed or allegedly committed. 

Data Protection Laws - This means the laws which govern the handling of personal data. This includes the General Data Protection Regulation (EU) 2016/679 and any other national laws implementing that Regulation or related to data protection.

Data subject - The person to whom the personal data relates.

ICO - This means the UK Information Commissioner's Office which is responsible for implementing, overseeing and enforcing the Data Protection Laws.

Personal data - This means any information from which a living individual can be identified. This will include information such as telephone numbers, names, addresses, email addresses, photographs and voice recordings.  It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions). It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.

Processing - This covers virtually anything anyone can do with personal data, including:

  • obtaining, recording, retrieving, consulting or holding it;

  • organising, adapting or altering it;

  • disclosing, disseminating or otherwise making it available; and

  • aligning, blocking, erasing or destroying it.

Processor - This means any person who processes the personal data on behalf of the controller. 

special categories of data - This means any information relating to:

  • racial or ethnic origin;

  • political opinions;

  • religious beliefs or beliefs of a similar nature;

  • trade union membership;

  • physical or mental health or condition;

  • sexual life; or

  • genetic data or biometric data for the purpose of uniquely identifying you.

 

3. WHAT PERSONAL DATA DO WE COLLECT?

Information provided by you - We collect some or all of the following information from you when you become a tenant, potential client or client of WD Real Estate Ltd, when you visit our website, or communicate with us directly (whether by email, telephone, post or the website):  

 

Personal data - Contact/ID data - Your personal details such as your name, your job title, your employer, email, copy of your passport, mobile phone number and home contact details. If you become a tenant, our letting agent may employ a 3rd party referencing company to check that you are a suitable tenant as we comply with the UK Government’s Right to Rent policy. If you become a client or tenant, we may look you up on Linked In and collect further details on your career history to assist with understanding your ability to secure a mortgage for a property if you are considering using a mortgage to purchase a property using our sourcing services.

Bank Account data - Typically our tenants pay their rent by standing order either to the letting agent or directly where we do not use a letting agent. When we use a referencing company, they will obtain bank account details and may carry out a credit check to confirm that our potential tenants will have the ability to pay their rent every month.

For investor clients, and we ask our clients to pay our fees directly, so don’t usually collect bank account data.

For both tenants and investors any bank account data we collect is held safely and securely and we never disclose it to 3rd parties.   

Online and usage data - If you view our website, for example pages you visit, we may record your IP address, web browser, operating system, geographical location and similar, as standard from Google Analytics. Your activity from our email communications, for example whether you have opened an email from us and what links you have clicked on.


Personal information about other individuals - If you provide us with information about other individuals, you confirm that you have informed the relevant individuals accordingly. For example, 2 or 3 people wanting to rent a flat together from us, or if you want to enter into a joint venture for property investment with two or more parties.

 

4. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (please see section 'How is processing your data lawful' for further detail). 

  • If you are going to be a tenant, to understand your ability to pay the rent and ability to look after our building that you might live in

  • If you are seeking our help to acquire a property to live in or rent

  • If you are going to be a joint venture partner or investor, to gain a better insight into how we can help you acquire a building that will fit with your existing property portfolio and financial investments 

  • To send you marketing communications keeping you informed of new properties available to rent or to buy 

  • To provide general customer support services

  • For compliance, accounting/audit, regulatory, legal and fraud prevention purposes

 

PURPOSE

  • To send you information about properties available to rent. This includes details about the property, location, proximity to public transport, number of bedrooms and expected rent. We may own this property directly or in a joint venture with one of our investors.

  • To send you information about properties to buy that suit your investment objectives. For clients who ask us to find a property to buy, this will include details of the property location, asking price, number of bedrooms, proximity to public transport and infrastructure and things like the nearest food weekend market

  • To send you information about property development opportunities. This includes details of the property location, asking price, development potential, ability to secure planning permission and ability to work in a joint venture way with us, with a number of other parties or in a larger joint venture or via one of the institutional or retail crowd funding platform we work with.

  • For compliance and fraud prevention. This is to cover our legal obligations with regard to regulation and tax etc.   

5. HOW IS PROCESSING YOUR PERSONAL DATA LAWFUL? 

Personal data - We are allowed to process your personal data for the following reasons and on the following legal bases:

 

Legitimate Interests : We are permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing  your personal data which is in the interests of WD Real Estate Ltd. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible.  

You can object to the processing that we carry out on the grounds of legitimate interests. See the section headed "Your Rights" to find out how.

Contract : It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of your contract.

Legal obligation : We are subject to legal obligations to process your personal data for the purposes of complying with applicable regulatory, accounting and financial rules, health and safety and to make mandatory disclosures to government bodies and law enforcements. 

Consent  : Sometimes we want to use your personal data in a way that is entirely optional for you. On these occasions, we will ask for your consent to use your information. You can withdraw this consent at any time.

Special categories of data : We are allowed to process your special categories of personal data for the following reasons and on the following legal basis:

Legal claims : We need to process your personal data if, we are required to process your personal data to defend or establish a legal claim.

Manifestly public personal data : The processing relates to information that you have made public, for example, information made public on a public social media platform like Linked In or Facebook.  

6. WHEN WILL WE DELETE YOUR DATA

We will hold your personal data during the time that you are an existing or potential client, investor or tenant. We are required by law to retain information for accounting purposes for a period of 7 years. At any time you can request to see the data that we hold regarding you.

 

7. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

Here are some of our key service providers that act as our processors who we may need to share your personal data with. 

  • Google Analytics (analytics provider)

  • My Deposits (tenant deposit security)

  • We may also share your personal data with the local councils for Landlord Licensing, the police, other law enforcements agencies, auditors or regulators where we are required by law to do so.

  • Over time, this may expand as our business grows and we offer more services.


Transfers of your personal data outside the EEA

We may need to transfer your personal data outside the European Economic Area.

Any transfer of your data will be carried out in accordance with the law to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms. If you want to know more about how data is transferred, please contact us using the details in the section above. 

How we keep your personal data secure

We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities. 

WHEN WILL WE DELETE YOUR DATA? 

Our main rule is not to keep your data for longer than we need to in order to meet all the purposes we included in the section "Why do we process your personal data?". 

For example, if you are a tenant, we will keep your data for the time your tenancy  lasts; then, we will keep that data if we need it to comply with a legal obligation or for research or statistics purposes, but if we do not need all the data you provided at first instance, we will delete the remaining data. 

 

8. YOUR RIGHTS

As a data subject, you have the following rights under the Data Protection Laws: 

  • the right to object to processing of your personal data;

  • the right of access to personal data relating to you (known as data subject access request); 

  • the right to correct any mistakes in your information;

  • the right to ask us to stop contacting you with direct marketing;

  • the right to prevent your personal data being processed;

  • the right to have your personal data ported to another controller;

  • the right to withdraw your consent;

  • the right to erasure; and

  • rights in relation to automated decision making. 

These rights are explained in more detail below. If you want to exercise any of your rights, please contact us on walter@wdrealestate.co.uk

We will respond to any rights that you exercise as soon as possible at the very least within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.

  • Right to object to processing of your personal data. You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.

    If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed "How is processing your personal data lawful". 
     

  • Right to access personal data relating to you
    You may ask to see what personal data we hold about you and be provided with:

    • a copy of the personal data;

    • details of the purpose for which the personal data is being or is to be processed; 

    • details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers; 

    • the period for which the personal data is held (or the criteria we use to determine how long it is held); 

    • any information available about the source of that data; and

    • if we carry out an automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision or profiling.

To help us find the information easily, please provide us as much detail as possible about the type of information you would like to see. 

  • Right to correct any mistakes in your information. You can require us to correct any mistakes in your information we hold. If you would like to do this, please let us know what information is incorrect and what should replace it.
     

  • Right to restrict processing of personal data
    You may request that we stop processing your personal data temporarily if: 

    • you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;

    • the processing is unlawful but you do not want us to erase your data;

    • we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or

    • you have objected to processing because you believe that your interests should override our legitimate interests.
       

  • Right to data portability. You may ask for an electronic copy of your  personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
     

  • Right to withdraw consent You may withdraw any consent that you have given us to process your personal data at any time. This means that we will not be able to carry out any processing which required use of that personal data.
     

  • Right to erasure You can ask us to erase your personal data where:

    • you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;

    • if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data; 

    • you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or

    • your data has been processed unlawfully or not been erased when it should have been.
       

  • Rights in relation to automated decision making You have the right to have any decision that has been made by automated means and which has a significant effect on you reviewed by a member of staff and we will consider any objections you have to the decision that was reached. 

What will happen if your rights are breached?

You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.

 

Complaints to the regulator

It is important that you ensure you have read this Privacy Notice - and if you do not think that we have processed your data in accordance with this notice - you should let us know as soon as possible. You may also complain to the ICO. Information about how to do this is available on their website at www.ico.org.uk.