TWENTY TWENTY PROPERTY
We are committed to protecting and respecting your privacy. We use the personal information you share with us to tailor our services to your requirements, and to provide the best possible user experience when dealing with us or when using our website.
Who we are:
Twenty Twenty Property (SW) Ltd. are a company dealing in residential sales, with our only office in Silverton, Devon.
Twenty Twenty Property (SW) Ltd., 26 Fore Street, Silverton, Devon, EX5 4HP. Twenty Twenty Property is a trading name. Our registered office is Quayside House, Highland Terrace, Barrington Street, Tiverton, Devon, EX16 6PT. Registered in the United Kingdom, No. 12245105. Email: firstname.lastname@example.org Tel: 01392 549900
What information do we collect?
When carrying out business activities in relation to the valuation, sale and purchase of property we collect the following information that you will need to provide to us:
- Your full name
- Your telephone number(s)
- Your address and the property address (if different)
- In the case of a company, your registered office address and the address to contact you (if different)
- Your email address
- Proof of identity documentation to comply with the current Anti Money Laundering Regulations. We will need to take our own copies of (usually) your passport and photo driving licence, and we will often require taking copies of recent bank statements or utility bills. All copies of identification documentation and copies of any financial information, that is needed for our records, will be scanned and saved onto our password protected database, with the original copies shredded and disposed of.
- Data collected in relation to our Cookies Policy – please see this for further information.
This information that we hold may be supplied to us by you by visiting our office, email, telephone, our website, social media or a third party.
Information collected from other sources
In order to identify the legal owners of properties and land that we market, and properties we let, we obtain from the Land Registry office copy entries to verify the legal names of the legal owners. This information is already a matter of public record.
When we take instructions from a Company to sell, buy, or let a property/land we will usually cross check information provided to us with what is available on the Companies House database. Again, this is a matter of public record.
Property portals such as: Rightmove, Zoopla and Prime Location, send us your personal data when you have requested them to do so.
How do we use personal information?
The primary use of your information is in order to provide a service to you and for the following purposes:
When carrying out business activities in relation to the valuation, sale or purchase of property we collect the following personal information that you provide to us:
- Your property address when arranging a valuation/ market appraisal.
- Your email address to send you our Privacy Notice/ Policy, our Terms of Business and Agency Agreement (when you are selling with us) and property details (when you are buying with us); and general correspondence that occurs within the nature of our business.
- Your communications with us, including a record of emails and phone correspondence between us both.
- Any questions, queries and feedback etc. that raise to us, we will likely liaise with buyers/sellers and/ or third parties.
- When you are not the property’s legal owner, we will request details from you to prove your ability to sell the property i.e. Grant of Probate, Power of Attorney, Guardianship Order.
- As a seller/vendor, when you accept an offer on your property or when you have an offer accepted as a buyer, we pass your name, address and the property address (if different) to both your lawyer and to the buyer’s/seller’s lawyer.
- To aid the transaction process, we also pass your name and the property address which you are selling/buying to other lawyers and agents in the chain. We will never pass them your contact details or proof of identity documentation without your prior permission.
- For ‘new build’ properties, we will pass on your personal contact details to the developer, usually detailing these on the developer’s reservation form, which will be signed by you and you will receive a copy of.
- We may offer to introduce you to a mortgage broker or surveyor, but we will always seek your consent first to pass on your contact details.
Whether information has to be provided by you, and why.
The ‘official’ name for the current UK money laundering regulations is: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
To comply with the current money laundering regulations, we are obliged to obtain from you— and also verify—copies of your photo identification, such as a valid passport or a valid photo driving licence, together with proof of address documentation, such as a recent bank statement or utility bill. We may ask for your National Insurance number.
If you are a non-British passport holder, we may ask for further information including sight of a UK Biometric Residency Permit (BRP). We will ask to see original documents, make our own copy, which we will then certify as a true copy of the original and which we will store electronically. For security reasons we arrange to securely destroy paper copy documents that we have made. In the case of a purchase under the regulations we are usually required to see ‘proof of funds’ and ‘source of funds’ and if we take a copy of documentary evidence again, we will store this electronically and then securely destroy the paper copy.
This proof of identity personal information must be provided by you to us, to enable us to comply with law, and we will inform you whether you are required to provide this information to us. When selling a property this will be at an early stage, and well before the property being launched to the market. When buying a property, we must have your proof of identity documentation and proof of the source of your funds before we can issue a Memorandum of Sale.
What legal basis do we have for processing your personal data?
The legal basis which relates to our use and other processing of your personal data under the applicable GDPR/Data Protection laws may include:
- Processing that is necessary for the performance of a contract: this includes such things as administering and managing your account, where you sign up online with Twenty Twenty Property, on the telephone or in person and the services relating to that;
- Processing that is necessary for our own ‘legitimate interests’ or those of our nominated third parties such as:
- For management and audit of our business operations.
- For our own direct marketing communications which we send to you about our own products and services, which we will send to you from time-to-time to ‘keep in touch’.
- For market research and analysis.
- Processing that is necessary to comply with a legal obligation such as:
- To process your request for personal data or when you seek to exercise your rights under GDPR/Data Protection or for compliance with legal and regulatory requirement.
- Processing that is based on your ‘consent’ – such as:
- When we collect your data for our direct marketing communications about products and services available from Twenty Twenty Property or from other nominated third parties.
- Where, in very limited circumstances, you provide us with special categories of data.
We will never ‘opt you in’ to receive contact from us. We will always seek your permission to do so at the first opportunity. At any stage, should you wish to remove your consent, this can be done by contacting Twenty Twenty Property or following the link that will come at the bottom of mail out communications i.e. emailed property matches.
When do we share personal data?
We always treat personal information confidentially and with the utmost of care, but we will also pass your details to the following organisations who carry out certain activities on our behalf as part of us providing our service to you:
- Alto software Limited (part of Zoopla): Our provider of the computer software that we use to manage the property data and client information that we store.
- Social Media: On occasion we will advertise properties ‘For Sale’ on social media
- Agency Express: our third-party board erection contractor.
We will also disclose your personal information to third parties:
- If our company or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
Transfer of your information outside the European Union (EU) / European Economic Area (EEA):
We are not aware of any reason where it may be necessary to transfer your personal information outside the EU/EEA or to an international organization. Should a request for such information be sent to us by a law enforcement agency we would only ever do so at the insistence of the UK’s National Crime Agency.
How do we secure personal data?
All data is stored in a secure, password protected cloud-based system. All devices that we use are also separately password protected. All staff are trained and sign an undertaking to commit to the procedure to maintain the absolute confidentiality of all personal information.
How long do we keep your personal data for?
You have the right to unsubscribe from receiving communications from us at any time, but this cannot affect the lawfulness of any processing activity we have carried out prior to you unsubscribing. You can opt-out by clicking the link to unsubscribe in the email footer or you can contact us at: email@example.com or by writing to: Data Protection Officer, Twenty Twenty Property, 26 Fore Street, Silverton, EX5 4HP.
We will retain your personal data for different periods of time depending on the service you have chosen, and which may be for a longer period than that for which we need to hold your data to provide those services, for example, where we are under a regulatory or statutory duty to hold your data for a longer period or need to retain it in the event of a legal claim or complaint.
We will store your data as follows:
When selling a property:
2 years after the date of the end of relationship between you and us:
- When we value your property and you decide not to market it with us.
- When we value your property, market it but a sale doesn’t occur.
6 years after the date of the end of relationship between you and us:
- When we act on your behalf and complete a sale.
- When we value your property and agree a sale but does not complete.
When you are an applicant looking to buy a property:
2 years after the date of the end of relationship between you and us:
- When you register as an applicant to view properties and either do not make an offer at all or do not make a successful offer.
6 years after the date of the end of relationship between you and us:
- When you register as an applicant/buyer with us to view properties, and you make an offer which is accepted but the purchase does not exchange or if it does successfully exchange/ complete.
Your rights in relation to personal data
Under the General Data Protection Regulation, you have a number of important rights that you can exercise free of charge. In summary, these rights are:
- Transparency over how we use your personal data and fair processing of your information
- Access to your personal information and other supplementary information
- Require us to correct any mistakes or complete missing information we hold on you
- Require us to erase your personal information, in certain circumstances
- Receive a copy of the personal information you have provided to us or have this information be sent to a third party, this will be provided to you or the third party in a structured, commonly used and machine-readable format;
- Object at any time to processing of your personal information for direct marketing
- Object in certain other situations to the continued processing of your personal information;
- Restrict our processing of your personal information in certain circumstances;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual- rights/
If you want to exercise any of these rights, please:
- Email, phone or write to our Data Protection Officer
- Please be prepared to provide additional information so that we can identify you, and we are very likely to contact you to request further information to verify your identity. For security reasons we must be sure it is you who are requesting the right or rights that you wish to exercise.
- We will respond to you within two weeks from when we receive your request
Automated Decision Making
We do not use Automated Decision Making in the course of our business.
How to contact us or make a complaint
We hope that you are happy with our service and that our Data Protection Officer can resolve any issues or complaints that arise but if you wish to contact us then please do so by contacting our data protection officer, Adam Dibble either by email: firstname.lastname@example.org or calling 01392 549900.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) this will be in the country/state where you work, normally live or where the alleged infringement of data protection laws occurred. The UK supervisory authority is the Information Commissioner’s Office who can be contacted at https://ico.org.uk/concerns/