Personal information is information which can identify you as a living individual, whether by itself or when used in conjunction with other information which we hold or are likely to hold. We take our obligations under the Act seriously. To this end, we have a Data Protection Officer and internal policies which relate to the protection of personal information. In addition, we regularly train our staff on data protection compliance.
What personal information about you do we collect and otherwise process?
You would need to submit certain personal information to us in order to register to use the “Customer Area” or “Business log in” pages of this website; to obtain direct (ie unsolicited) marketing information about the products and/or services of FSL Residential, our parent company and companies carefully selected by FSL Residential; and to participate in our online ordering process.
The personal information about you which we collect and otherwise process may include:
- your name and business and/or personal contact details (including email address, postal address, telephone numbers (mobile and fixed line) and delivery address information if you order products and/or services from us);
- information regarding your experiences with our products and/or services;
- your FSL Residential username and password (you will be asked to provide these every time you login to use this website);
- your direct marketing contact preferences and consents (please refer to the section “Direct Marketing” below for more information);
- (if you are a residential customer) credit/debit card details and bank account details for the purpose of setting up direct debits;
- (if you are a business customer, ie if you are acting on behalf of a company, partnership or sole trader) bank account details for the purpose of setting up direct debits and information about business operations, which may include some personal information; and
- information you provide in any “free text” boxes on this website (i.e. blank spaces where you are free to insert comments).
This list is not exhaustive and it may be updated in the future. It is a fair reflection of some of the personal information about you which we collect through this website (and which is provided to us by other means).
What is sensitive personal data?
This is a more sensitive category of personal information which relates to (e.g.) a person’s race, sexual life, criminal allegations or offences, trade union membership or their mental or physical health.
We do not actively collect sensitive personal data from our customers. However, it would be relevant to the extent that you choose to send this type of information to us, for example if you submit a query to us through the “Customer Area” of this website which refers to the particular requirements you have for a residential property, based on the condition of your health or any disability.
We make sure that sensitive personal data is subject to additional controls. We would use it only in order to deliver our services to you, to meet your requirements or to deal with any requests made by you. We would only disclose it to any of the third parties referred to in the section “Who do we share your personal information with?” in the event that they need to know it (eg if a third party service provider is making adjustments to a property in accordance with the information you have provided to us) and subject to appropriate confidentiality obligations (as may be appropriate).
What do we do with personal information which we hold about you?
The legitimate purposes for which we use your personal information may include use for the following purposes:
- to carry out internal record keeping and audits;
- to administer this website and our contract or other relationship with you, including in order to provide our products and/or services to you (for example, to put you in touch with estate agents and other appropriate third parties (meaning any other person or organisation) in accordance with your instructions);
- to obtain payments from you for our products and/or services (this is why we collect credit/debit card details and bank account details);
- to analyse the way in which you use this website with a view to improving the products and/or services we offer and our marketing and advertising activities and for market research purposes related to improving the same including online surveys (we may contact you ourselves for this purpose or ask third parties to do so on our behalf – please refer to the section “Who do we share this information with?” below);
- to analyse patterns and trends of use and the uptake of our products and/or services;
- to deal with and respond to any communication, enquiry or application which you submit to us;
- to process job applications which you submit to us through this website;
- to send you direct marketing information about the products and/or services of FSL Residential, its parent company and of companies carefully selected by FSL Residential (but only when you provide the appropriate consents to permit this – please refer to the section “Direct Marketing” below); and
- to comply with our legal, regulatory and other good governance obligations.
This list is not exhaustive and it may be updated in the future. It is a fair reflection of some of the current purposes for which we may use the personal information about you which we collect through this website (and which is provided to us by other means).
Who do we share your personal information with?
Except as otherwise set out in this section, we will not transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission or are permitted or required to do so by law or legal process.
- We may disclose your personal information to third parties which provide services to us including (for example) organisations which we engage to conduct marketing and/or research on our behalf; organisations which assist us in providing our products and/or services to you; organisations which we use to fulfil a contract concluded with you or which provide other business support services to us (for example, database storage providers which store the FSL Residential databases containing names and contact details used for direct marketing purposes). In accordance with the Act, we will impose restrictions and standards in our written contracts with service providers to ensure they keep your personal information secure and use it only for the purposes for which it was provided to them.
- We may disclose your personal information to our parent company and third parties carefully selected by FSL Residential so that they may send you direct marketing about their own products and/or services (but only when you provide the appropriate consents to permit this – please refer to the section “Direct Marketing” below).
- We may sell your personal information to third parties where necessary as part of our legitimate business processes (for example, in the event that our shares are purchased by third parties; in the event that our management or administration is to be taken over by third parties or in the event that our assets (for example, our customer databases or contact lists) are purchased by third parties). Should we do this we would ensure it was carried out in accordance with the Act.
- We may be required by law or legal process to release your personal information to local or central government authorities, official agencies or legal authorities (ie courts, tribunals, police or security services). In order to maintain the integrity of this website and safeguard the interests of its customers and subscribers, we will comply with any such request. In addition, we may be required to disclose your personal information to government authorities for tax or other purposes. In other circumstances we may also decide that there is a genuine reason for us to disclose your personal information to legal authorities and that a disclosure would be justified and lawful under the Act.
- Your personal information may be passed to and used by our parent company which, like [agent name] is based in the UK. We would pass your personal information to our parent company to permit it to provide services to us which relate to you or to send you direct marketing about its own products and/or services (but only when you provide the appropriate consents to permit this – please refer to the section “Direct Marketing” below).
- In addition, there may be circumstances in which it is necessary for us to disclose your personal information to external companies or organisations in order to protect our customers or our own legitimate interests. Such disclosures would be permitted under the Act provided they were necessary to safeguard those interests and were proportionate bearing in mind your interests.
Will your personal information be transferred outside Europe?
We may share your personal information with our service providers and this may involve transferring it to countries outside Europe whose data protection laws may not be as extensive as those which apply to us. At this time we do not envisage any such transfers but if we do transfer your personal information to a country outside Europe, we will ensure that we do this in accordance with the Act (for example, by putting in place an appropriate data transfer agreement). We will do this with a view to ensuring that the level of protection which applies to your personal information processed in these countries is similar to that which applies within Europe.
What if you are using this website from outside the UK?
What about anonymised information?
How do we protect your personal information?
In order to prevent unauthorised access or disclosure, damage or loss to/of (as appropriate) your personal information, we implement suitable physical and electronic, organisational and technical security measures in accordance with our obligations under the Act. This may include encryption (for example, credit/debit card details are encrypted on the FSL Residential IT system).
You are responsible for maintaining the confidentiality of your username and password which relate to your access to certain pages of this website and/or any account you set up with us. You agree to accept responsibility for all activities which occur in relation to the same. You should not permit other people to use your username and password. Please contact us promptly if you believe your username or password may have been compromised. We will not be responsible to you if there is unauthorised access to your login details or unauthorised activity on this website as a result of someone else using your login details, unless we caused this to happen because of negligence.
Despite our efforts regarding security it is important to bear in mind that the internet is not a secure means of communication. Personal information communicated through the internet may be intercepted by other people. We cannot guarantee the security of personal information sent to us through this website. You accept that you use this website at your own risk.
This website is not intended for use by minors under the age of 13. Minors under the age of 13 should not submit any personal information to us through this website. Parents and guardians should remind their children to handle their personal information securely and responsibly on the internet.
Cookies and web beacons
We may use “cookies” on our website. Cookies are data files which store information on your hard drive or browser that means that our website can recognise that you have visited our website before. They make it easier for you to maintain your preferences on this website, and by seeing how you use the website, we can tailor it to your preferences and measure your use of it.
You can, should you choose, disable the cookies from your browser and delete all cookies currently stored on your computer. On Microsoft Internet Explorer, this can be done by selecting ‘Tools/Internet Options’ and reviewing your privacy settings or selecting ‘delete cookies’. You can find out how to do this for your particular browser by clicking ‘help’ on your browser’s menu or by visiting http://www.allaboutcookies.org/manage-cookies/index.html. However, many of our website features will not function if you disable cookies.
We may also use electronic images known as “web beacons” on this website and in communications generated from using and/or registering on this website, such as promotional emails. Web-beacons usually work in conjunction with cookies and they are used for similar purposes.
Updating and obtaining access to or copies of your personal information
If any of your personal information which we hold becomes out of date or inaccurate, please let us know by contacting us by email or by post using the contact details in the section “How to contact us” below. You would need to put your request in writing. We will amend your personal information if we believe it contains factual errors or is out of date.
If you wish to obtain access to or copies of the personal information which we hold about you please contact us in the same way. In some circumstances we may provide access not copies. We may charge a nominal fee in order to cover some of our administration costs in responding to your request. We are permitted to do this under the Act.
Direct marketing and third party “fair processing notices” and consents
FSL Residential, our parent company and third party companies carefully selected by FSL Residential because they offer products and/or services which we believe may be of interest to you, may wish to contact you by post, telephone, fax, email, SMS and other electronic methods of marketing which may become relevant in the future in order to provide you with marketing information about the products and/or services and/or special offers of FSL Residential, our parent company and our carefully selected companies.
To this end, we may collect personal information from you for direct marketing purposes through this website or by other means such as through paper forms issued to you, email exchanges with you, meetings with you and telephone conversations with you.
We will make it clear on the relevant pages of this website if personal information which we collect may be used for direct marketing purposes. We will do the same should we collect your personal information by other means for this purpose. At the same time we will seek your consent to receive direct marketing or we will permit you to opt-out of receiving this (depending on what is required under applicable laws).
We will ensure that any direct marketing sent by electronic means would provide you with a simple way to refuse further electronic marketing. For example, SMS messages may tell you to text ‘STOP’ to a telephone number and emails may tell you to send a request to an email address to stop further emails. Should you refuse further electronic marketing, as soon reasonably possible it would be noted that you had changed your mind. This means that your personal information (including your contact details) may still be held in a repressed form but only to ensure that we maintain a record telling us not to contact you for the same direct marketing purposes.
If at any other time you wish to change your mind about receiving direct marketing from us please contact us by email or post using the details in the section “How to contact us” below.
In addition, third parties such as estate agents, letting agents, lenders, banks, residential developers, companies operating other websites and receivers acting for banks and lenders may collect personal information from you for direct marketing purposes. We may obtain your personal information from those third parties with the intention of using it to send you direct marketing about our products and/or services (or those of our parent company). We take steps to ensure that we do this only when you provide the appropriate consents to those third parties to permit this.
Termination of your account and retention of your personal information
In accordance with the Act we will ensure your personal information is not kept longer than necessary for the relevant purpose(s) by us or by any third parties which process it on our behalf. Where personal information which we hold is known to be unreliable, irrelevant or excessive, we will securely delete it as soon as possible.
We reserve the right to terminate your access to the “Customer Area” or “Business log in” pages of this website without prior notice. If we terminate your access or if you notify us in writing that you wish to terminate your own access, we will keep your personal information thereafter only for as long as is necessary in case of any legal challenges or other problems. After that period your personal information will be suppressed in or deleted from our database(s).
How to contact us
Please use the contact us page on the website.