Privacy Notice

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we collect, process and look after your personal data and tell you about your privacy rights and how the law protects you.

1 Important Information and who we are

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how we collect, store and process your personal data, including any data you may provide through our Website, visit one of our developments or otherwise, when you submit an enquiry, apply for or obtain a reservation or submit information to us in connection with the purchase of a property.

Our website www.snapeproperties.co.uk (the Website) is owned and operated by Snape Properties Limited (“We”). Our Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice that 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 notice supplements the other notices and is not intended to override them.

This policy should be read in conjunction with the following policies and terms which also apply to our processing of your personal data:

  • any other agreement (including a Reservation Agreement) entered into with us in connection with a property purchase.

1.2 Controller

We are the controller and are responsible for your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

1.3 Contact Details

Company name: Snape Properties Ltd
Company number: 01850600
Registered office: 1 Daisy Way, Louth, LN11 0FS
Contact: Office Manager
Email address: eloise.snape@snapeproperties.co.uk

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.

1.4 Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on 21st November 2024 previous versions can be obtained by contacting us.

We may change this privacy notice from time to time. If so, we will notify you by website update or otherwise.

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

2 The data we collect about you

2.1

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes residential address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about reservations and payments to and from you and other details of transactions that you have had with us.

  • Technical Data includes internet protocol (IP) address, your login data, 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 our Website.

  • Profile Data includes your username and password, reservations or purchases made by you, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Unless we expressly advise you otherwise, 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.

2.2 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, by not supplying us with your Contact, Financial and Identity Data we will not be able to process the sale of your selected property, and we will have to cancel your transaction with us. We will notify you if this is the case at the time.

3 How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms such as our Reservation Forms (either online or in one of our developments) or by communicating with us by post, phone, text message, email or in person or via one of our social media pages. This includes personal data you provide when you:

  • submit an enquiry to us;

  • book a viewing of one of properties;

  • to verify your identity;

  • to provide you with our aftersales service;

  • to facilitate the provision of warranties with a property;

  • contact us about a potential development site;

  • apply for a reservation or property, or for any of our other products or services;

  • giving us feedback

4 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:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

4.1 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 for the following purposes.

To register you as a new or potential customer

  • Type of data

    • Identify

    • Contact

  • Lawful basis for processing including basis of legitimate interest

    • Performance of a contract with you

To arrange a viewing of one of our properties

  • Type of data

    • Identify

    • Contact

  • Lawful basis for processing including basis of legitimate interest

    • Performance of a contract with you

To process your enquiry, reservation or transaction including:

  • Including:

    • Manage payments, fees and charges

    • Collect and recover money owed to us

    • Liaising with third parties (including solicitors, estate agents, financial advisors, accountants and warranty providers) in connection with your transaction

  • Type of data

    • Identity

    • Contact Financial

    • Transaction

    • Marketing and Communications

  • Lawful basis for processing including basis of legitimate interest

    • Performance of a contract with you

    • Necessary for our legitimate interests (to recover debts due to us and to progress the sale of our property)

To manage our relationship with you which will include:

  • Including:

    • Notifying you about changes to our terms or privacy policy

    • Asking you to leave a review or take a survey

    • Dealing with post-completion and administrative matters following your purchase of a property

  • Type of data

    • Identity

    • Contact

    • Profile

    • Marketing and Communications

  • Lawful basis for processing including basis of legitimate interest

    • Performance of a contract with you

    • Necessary to comply with a legal obligation

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

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

  • Type of data

    • Identity

    • Contact

    • Technical

  • Lawful basis for processing including basis of legitimate interest

    • 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)

    • Necessary to comply with a legal obligation

4.2 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.

5 Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External third parties

  • Professional advisers acting as processors or joint controllers including solicitors, financial advisors, mortgage advisors, estate agents, management companies, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

  • Warranty providers based in the UK who provide warranty cover for new properties.

  • After-sales teams (both internal and external) who provide services in connection with the maintenance of new properties.

  • Customer satisfaction survey providers, who review your property-buying experience.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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 purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6 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.

7 Data Retention

How long will you use 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.

Should you purchase a new home your information will be retained for a minimum period of ten years. This data is retained in accordance with legislative requirements and in connection with the provision of warranty cover by third parties.

Where no property purchase occurs, your personal data will be deleted or destroyed after 2 years. We retain data for this period for administrative purposes, including to facilitate a subsequent enquiry from you.

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.

8 Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

9.1 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.

9.2 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.

9.3 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.

10 Third-party links

The Website 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 Website, we encourage you to read the privacy notice of every website you visit.

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