194 Upper Richmond Road
London SW15 2SH
Tel: 020 8780 1100
Fax: 020 8780 0872
139 Lower Richmond Road
London SW15 1EZ
Tel: 020 8780 3604
Fax: 020 8789 5952
Privacy Policy
Warren (London) LTD Privacy Statement

Information covered by this statement

This Privacy Statement applies to the use and processing of personal information collected and used by Warren (London) LTD. Information concerning the make-up of Warren (London) Ltd can be found in the ‘about us’ section of the website. Please note, this statement only applies to those Warren (London) LTD members who are domiciled within the European Economic Area and adequate countries. For information concerning the collection, use or processing of personal information by any other entities any of our affiliates, business partners or suppliers (whether or not trading under the name Warren (London) LTD) please contact us directly via email, by phone or post.
The phrases “Warren (London) LTD”, “us” or “we” shall, when used herein, mean those members of Warren (London) LTD on behalf of and in respect of whom this statement is made.

By using Warren (London) LTD website and otherwise providing your personal information to Warren (London) LTD, you agree to the collection, use and sharing of your information in accordance with this statement. Please read this Privacy Statement carefully and contact us if you have any questions.

Personal information is information, or any combination of separate pieces of information, that could be used to identify you.
Should you have any queries in respect of this statement or our use of personal data, please contact our Director Michael Crowther – mike@warrenputney.co.uk who is the appointed person responsible for overseeing compliance of Data Protection matters.


The Information collected by Warren (London) LTD


We may collect information about you from a variety of sources. This includes information we collect directly from you and information we collect about you from other sources.

Information we collect directly from you

We collect information directly from you when visit, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:

Name
Email address
Postal address
Telephone and/or fax number
Date of birth
Demographic information
Payment information and bank account details
Future communication preferences
Telephone number
Information we collect when you contacted by you

We may obtain information about you from other sources, including publicly available sources, such as the Land Registry, social media platforms or referral agents, etc. Examples of information we may collect from other sources are:

Name.
Postal address.
Email address.
Date of birth.
Income level.
Publicly observed activities or information made available by you to the public, such as blogs, videos, internet postings, and user generated content.

How Warren (London) LTD uses this information


We use the information we collect to provide you products and services or other content tailored to your interests, and to conduct other (Warren London) LTD business operations. The following are examples of how we may use the information we collect:

Answer your questions or respond to your requests.
Develop new products and services
Create and manage your record.
Process payment for purchases, fees or other services.
Protect against or identify possible fraudulent transactions.
Send you email and/or postal messages with information about Warren (London) LTD and other content we think may be of interest to you.
Telephone you about Warren (London) LTD products and information that we think may be of interest to you.
Develop and provide marketing tailored to your interests, including interest-based marketing.
Personalise your experience by presenting products and information tailored to you.
Allow you to participate in social sharing on our websites.
Analyse the use of, and develop, our products, services and marketing. Enforce our Terms and Conditions and otherwise manage our business.

Warren (London) LTD will only collect, process and store your personal information when it has a lawful basis for doing so.
Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data. We will only use your personal data when it is lawful for us to do so. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

The legal bases upon which we may process your personal data include:-


Consent

We may collect and process your personal data with your explicit consent, for example, where you have requested a call back from us or you have opted-in to receiving specific marketing materials, newsletters and updates from us.


Legitimate interest

In certain circumstances, we will process your data in our legitimate interests, i.e. in a way which might reasonably be expected as part of running our business. We shall never process your personal data in our legitimate interests if to do so would materially impact your rights, freedom or interests.
Where you have provided us with your personal details in the course of our business, we may for example use your address or email details to send you direct marketing information, telling you about particular properties that may become available or about products and services that we think you may be interested in.


Contractual obligations

In certain circumstances, we will also need your personal data to comply with our contractual obligations.
For example, if we are required to provide a landlord management service, we would need the landlord’s bank account details to process payments to them and we may also need to collect the name, address details, and telephone number of the tenant and pass these to our contractor to enable them to arrange an appointment to undertake repairs. In this scenario the processing of personal information may also be in our legitimate interest.


Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we may be required to provide certain information to HMRC when accounting for rental payments received by us on behalf of a landlord.


Information sharing

The success of our business depends on your trust, and we do not sell your personal information to marketers outside of Warren (London) LTD. We share your personal information within Warren (London) LTD and as described in this statement. We do not share personal information with marketers outside of Warren (London) LTD unless you consent to such sharing, or as described within this statement.


Co-promotions with Carefully Selected Business Partners

We from time to time may collect personal and other information for a co-promotion or joint program with a business partner and share your information with that business partner if it is our legitimate business interest. For these programs we will make clear at the point of collection that the information will be shared with Warren (London) LTD and the participating business partner and ask for your consent as required by applicable laws.


Third-party service providers

We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your personal information with them. We provide our service providers with only the personal information they need in order to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.


For example, we may rely on a 3rd party service provider to:
Fulfil your service requests and answer your questions.
Host our sites and deliver our email or other communications.
Take actions on our behalf.
Analyse our data, sometimes combined with data from other sources, to send you communications.
Conduct research and analyse data to improve our products, services and sites.
Perform other services that we request.

Where permitted by law, we combine personal information about you that Warren (London) LTD has collected with personal information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use Warren (London) LTD data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Statement as indicated above.


We may transfer or otherwise process your personal information:

As part of the sale of a Warren (London) LTD brand to another company.
When we have received your instruction to pass the sale of your property to another agent
To protect, defend or exercise the rights and property of Warren (London) LTD (including enforcing our Terms and Conditions).
When required by law and/or government authorities.
We share aggregated and/or anonymous information that does not identify you for Warren (London) LTD business purposes. For example, we may disclose the number of visitors to Warren (London) LTD sites or services. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

Personal Information Retention Period

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.
Aggregated and non-personal information.


Your Communication Options

We give you choices about how we communicate with you.

Email Communications

You can stop receiving promotional email messages from Warren (London) LTD by following the opt-out instructions provided in any such message you receive.

Postal Mail

You can stop receiving promotional postal mail from Warren (London) LTD by following the opt-out instructions that may be included within those communications.
PLEASE NOTE: We will honour your request to stop receiving promotional email, text and postal messages from Warren (London) LTD as practicable. However, we may continue to send you service-related communications. We may keep information for record keeping to ensure we fulfil your request not to send particular types of messages.
Please note you may receive communication for a short period after you have updated you preferences whilst we update our systems.


You and your information

To the extent provided for by applicable law, you have certain rights in respect of the management of the personal data we hold about you.


Access

We take steps to keep your personal information accurate. Some Warren (London) LTD programs provide access to update personal preferences. You can contact Warren (London) LTD to amend update or remove any information that you provided when you registered online. Check where you registered to learn if you can view or update your information there.
If information access and update are not available where you registered, contact Warren (London) LTD to Have the information amended accordingly Warren (London) LTD does not charge for this service and responds to reasonable requests in an appropriate timeframe.


Data Deletion

You can delete your information record at any time, we deal with your request as necessary under applicable law. (providing there is no legal basis for Warren (London) LTD to retain the data) This will erase any personal information in your account that we have about you.


Other rights

To the extent provided by applicable law, you have the right to request rectification of your personal data; to obtain restriction of the processing of personal data; to object to the processing of personal data (including direct marketing) and to data portability. To exercise any of these rights, please contact us as described below.


Consent

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by contacting us unless we have a legitimate or legal reason not to. We will cease processing your personal data as soon as reasonably practicable and necessary under applicable law following our receipt of your withdrawal.


Contacting the Information Commissioners Office (ICO)

If you consider that we have processed personal data in violation of applicable law, please contact us as described below. If you consider that we have processed personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the Information Commissioners Office (www.ico.org.uk).
We would however appreciate the opportunity to deal with your complaint prior to notifying the ICO. Please contact mike@warrenputney.co.uk.


Links to Third Party Sites and Social Media

Warren (London) LTD site may include links to third-party sites. Warren (London) LTD does not control these third-party sites, and we encourage you to read the privacy statement of every site you visit.


Information Security

Warren (London) LTD is committed to keeping personal information secure. We have implemented technical, administrative and physical procedures designed to protect personal information from loss, misuse or alteration.
We limit access to personal information to those who have a business need. We keep personal information only for so long as deemed reasonably necessary.
If you require any further information, please contact us directly.


Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Statement.


Children’s privacy

Our Sites are not directed to children under the age of eighteen and we do not knowingly collect personal information from children under the age of eighteen on our Sites.


Updates to our Privacy Statement

We may, from time to time make changes to our Privacy Statement. We will post any changes and indicate the effective date when this Privacy Statement is updated. If we make any material changes to this Privacy Statement, we will notify you by sending an e-mail to the e-mail address you most recently provided us or by posting notice of the changes on this site.




Last update 24/05/18