PRIVACY POLICY

INTRODUCTION

Britannic Holdings Corporation is committed to handling your personal information or “personal data” in a responsible manner. We follow four guiding principles when it comes to your privacy:

Transparency: We work hard to be transparent about what personal information we collect and process.
Simplicity: We strive to use easy-to-understand language to describe our privacy practices to help you make informed choices.
Control: We give you control over the personal information you provide to us, including how it is used, shared, and retained.
Security: We adopt administrative, technical and physical safeguards to ensure the safety of your personal information.

This privacy statement explains how we look after your personal data and 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 notices we may provide on specific occasions when we are collecting or using your personal data (for example if you reserve one of our new homes) 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.

BRITANNIC HOLDINGS CORPORATION Limited

This privacy statement is issued on behalf of the Britannic Holdings Corporation Group so when we mention “Britannic Holdings Corporation”, “we”, “us” or “our” in this privacy statement, we are referring to the relevant company responsible for processing your personal information in accordance with this privacy notice and in compliance with the relevant data regulation and law. Britannic Holdings Corporation Limited is the data controller and responsible for this website.

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the data protection manager using the details set out in the “Contact us” section at the end of this statement.

CHANGES TO THE PRIVACY STATEMENT AND INFORMING US OF CHANGES TO YOUR PERSONAL DATA

This version was last updated on 30 September 2020.

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.

THE DATA WE COLLECT ABOUT YOU

We may collect information from you when you:

fill in a form either face to face, or over the telephone
fill in a form on our website or a third party’s website
send us an email or letter
enter into a transaction with us
subscribe to one of our services or publications
enter into a competition or promotion
request marketing to be sent to you
give us some feedback
interact with our website, which may automatically collect some technical data
use our social media pages, which are monitored by a third-party company on our behalf
visit or call one of our developments.

The information collected may include the following:

your first name, middle name, maiden name, last name, marital status, title, date of birth and gender
your contact details, including your address, a business address, email address and telephone numbers (fixed line and mobile)
technical information such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
information about how you use our website, products and services
information including your preferences in receiving marketing from us and your communication preferences
information you have provided to third parties, such as via a property portal or website or when you comment on one of our social media pages
CCTV or telephone call recording, which we use on some of our premises to provide a safe and secure environment for our employees or for training and monitoring purposes for our customer services team.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The collection and processing of data of individuals under the age of 18 is subject to us gaining consent from the individual’s parent or guardian and that is the lawful basis for such processing. If you are using our website and are under the age of 18, you should obtain your parents’ or guardians’ permission before you contact us.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

To provide you with details of our developments and new homes or other products and services we may offer
To inform you of special promotions and offers
To contact you if you have asked us to provide you with for information about one of our developments
Where we need to comply with a legal or regulatory obligation
To carry out website analytics
To carry our market research and development of our products and services
Social media and website promotion and advertising.

More detail relating to the legal basis on which we use your personal data is set out below:

Purpose/Activity

Lawful basis for processing including basis of legitimate interest (where applicable)

To register you as interested in receiving marketing communications for one or more of our development sites

Consent

Asking you to leave a review or take a survey

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

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

(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)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(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

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

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)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

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

To make suggestions and recommendations to you about goods or services that may be of interest to you

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

Social media and website promotion and advertising

Consent

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email, post or text message or for any social media and website promotion and advertising. You have the right to withdraw consent to marketing at any time through the unsubscribe link embedded within any emails that are sent to you or by contacting us to unsubscribe by post or email (see the “Contact us” section below).

MARKETING

We strive to provide you with choices regarding the use of our personal data for marketing and advertising. For example, when we collect your contact details, we ask you to specify your preferences for how we contact you, whether by telephone, post, email or SMS.

We do not share or sell personal data to third parties outside Britannic Holdings Corporation for their marketing purposes. Some of our advertising campaigns are managed and issued by a third party marketing or PR agency on our behalf, but those third parties will only contact you on our behalf with information about Britannic Holdings Corporation's products and services.

You will receive marketing communications from us if you have requested information from us or purchased goods or services 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.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting the Group’s data protection manager at any time (see the “Contact us” section below).

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for other reasons.

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.

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.

WHO WE MAY SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in this privacy statement:

other companies in the Britannic Holdings Corporation Group who also act as controllers or processors

service providers acting as processors based in the UK who provide IT and system administration services to the Britannic Holdings Corporation Group

Britannic Holdings Corporation Group’s appointed marketing, PR or advertising agencies for the purpose of running the Britannic Holdings Corporation Group’s marketing campaigns, carrying our market research, surveys and customer focus groups.

professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services

HM Revenue & Customs, regulators and other authorities

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own marketing purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (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.

HOW LONG WILL YOU KEEP MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

Request access to your personal data
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us (see the “Contact us” section below).

YOUR RIGHT TO MAKE A COMPLAINT TO THE ICO

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.

Our full contact details are:

Full name of legal entity: Britannic Holdings Corporation Limited

Name or title of Group Data Protection Manager: Group Company Secretary & General Counsel

Email address: office@britannicholdings.com

Postal address: Tattersall House, East Parade, Harrogate, HG1 5LT