WHAT IS THIS?
Key-Lets is the data controller of your personal data. Key-Lets is the trading name of Key-Lets Accommodation at 12 Parkhouse Street, Ayr KA7 2HH.
Key-Lets is committed to protecting and respecting your privacy and will comply with all applicable data protection laws in all our dealings with your personal data.
As data controllers, we want you to feel both informed and empowered when it comes to the handling and usage of your personal information. In this privacy statement, we explain how and why we collect and use personal data, which is information relating to an identified or identifiable living person. We will only use your personal information lawfully in accordance with the General Data Protection Regulation 2018 (‘GDPR’).
This policy may change from time to time so re-visit this page occasionally to ensure that you are aware of any changes.
When you visit our site, we collect anonymous data from our cookies. This means we can see number of users, page views and visits within a selected timeframe, but we cannot link this information back to you as an individual.
When you sign up to receive content or downloads from us you are actively opting in to receiving marketing communications from us. You can unsubscribe or opt-out from our emails at any time. Every email we send you will have an ‘unsubscribe’ link in it.
If you download any of our free content or buy anything from us we securely store personal data such as you name, address and contact details. We may also share this information with our third-party delivery partners so that we can get your goods delivered to you. We only share your financial data with our trusted third-party payment provider when it is required to fulfil your order. We do not store any of your card details on our system, so your financial information and data is fully secure.
Personal data may also be used to send triggered emails, such as cart abandonment, notifications, and purchase confirmation emails for instance. We may also use this information to personalise our marketing, for example, to suggest products or services related to your previous purchases or interests. It may also be used to send you special offers and product news by email.
You can opt out of this at any time by unsubscribing from our mailing list or contacting us: email@example.com
What information do we collect?
We may collect and process the following data about you:
•Information about you, such as your name, your business name, telephone number and email address;
•Additional information that is provided by you filling in forms on our websites or at exhibitions/events, say. This includes information provided at the time of registering to use our site, subscribing to our services, posting material, or requesting further services or information;
•If you contact us, we may keep a record of that correspondence;
•We may also ask you to complete surveys from time to time that we use for research purposes, although you do not have to respond to them;
•Details of transactions you carry out through our site and of the fulfilment of your orders;
•Details of your visits to our websites and emails received including, but not limited to, traffic data, location data, web logs and other communication data, whether this is required for our own billing purposes or otherwise.
•We may receive information about you from you or third parties when we are acting for a client and we are required to obtain information about you, for example if you are applying for a property owned by the client and you are providing information for referencing purposes. The information we receive may include your contact details, identification information, financial information, employment information and details included in any correspondence and information about you in connection with any matter on which we are engaged to advise our client (including biographical and personal/circumstantial details). Where we receive information about you, we will only use that information for the purposes of the legal transaction.
•You give us information about yourself when you make an enquiry to Key-Lets, or engage us to provide letting agency services to you, or when entering information via our website, opt-in/consent forms, apps or by communicating with us by phone, post, e-mail, live chat, social media or otherwise. It includes additional information that you provide to us during the course of any legal/contractual matter.
In addition, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to prevent fraudulent access to our password-only areas.
Information that you give to us
The information you give to us mainly includes your contact details, identification information, financial or billing information, employment information and details included in any correspondence and information about you in connection with any matter on which we are engaged with you.
Information we receive from other sources
We may receive information about you from third parties. For example from:
In transactional matters
Law firms, accountants, letting agents and other professional advisors acting for you where our client is a party to or otherwise concerned in the course of, for example; a commercial or domestic property transaction, a family, trust or probate matter, and due diligence.
In dispute resolution
Law firms, counsel, experts, tracing agents and other professional advisors acting for you or for us on your behalf, or from third parties, where our client is a party to or otherwise concerned in the course of, for example: an action for rent arrears, eviction or other housing matter dealt with by the Scottish Courts and/or First-tier Tribunal for Scotland (Housing and Property Chamber).
Any complaint resolution in other areas between our client and tenant and or Guarantor, for example a tenancy deposit claim.
Customers of financial institutions
Banks, building societies, bankruptcy practitioners and finance companies, where you are their customer/debtor, who are clients of ours or from whom we are given or request information.
In a representative capacity
Personal representatives, attorneys, trustees, deputies and others who may provide us with information in connection with a matter including litigation which we are conducting for a client in, for example a First-tier Tribunal for Scotland (Housing and Property Chamber) complaint.
In Relation to Employment
Recruitment consultants who may provide information about you to us in relation to a potential job at Key-Lets and employers who may provide a reference on you to us.
We may supplement the personal data collected from you with information from publicly available sources, such as information to validate your identity or address, or to perform a credit check. The information that we receive about you from others mainly includes contact details, biographical, behavioural, fraud, billing and legal information.
Information we collect about you
Please note that your provision of documents for identity verification purposes is necessary for us to comply with our legal and statutory obligations to represent our clients and to verify tenants and guarantors for our client's properties. Failure to provide these documents will result in our being unable to undertake identity verification as required by the Money Laundering Regulations 2017 and, subsequently, we will not be able to act for you or accept a tenancy application.
TYPE OF PERSONAL DATA WE PROCESS ABOUT YOU
As a letting agency dealing with property marketing and management we may process a range of personal data about you. To make it easier to understand the information that we use about you, we have divided this information into categories and provide a short explanation of the type of information each category covers (please note that not all categories may be applicable to you):
Your name and contact details
Why we use it: Information which can be used to address, send or otherwise communicate a message to you.
How we use it: We send you emails, text, phone calls, online messaging, letters for keeping you updated on offers and new or altered services. Fraud prevention and detection, finding out your favourites, what you like and what you can do without to better engage with you as a client or customer of Key-Lets.
Your banking, card, billing information
Why we use it: To accept payments from and make payment to clients, customers and other associated property management parties. Fraud prevention and detection,
How we use it: To make payment to landlords, trade services, other parties for the management of our client's property. To accept rental payment and other payments for services etc from tenants or representatives.
Your legal and insurance information
Why we use it: To facilitate legal and due diligence requirements.
How we use it: To provide legal and insurance services to our clients and customers.
Your geo-location and device information
Why we use it: To facilitate information and improve marketing services.
How we use it: Collecting information which contains or reveals the location of your electronic device and other unique information improves our service provision to you and other clients and customers.
Employment, Biographical and Behavioural information
Why we use it: To assess potential and current employees as part of our employment processes.
How we use it: Employment application, interviews, employment training and reviews.
Why we use it: To keep a record of events or conversations.
How we use it: We may record phone calls and retain transcripts of dialogue i.e. live chat conversations, either for our records or for training purposes. If you visit our office your image may be recorded on CCTV for security purposes
HOW AND WHY WE USE YOUR PERSONAL DATA
Under the applicable data protection laws (GDPR) we need a lawful basis to collect and use your personal data. The law allows for six lawful bases to process people’s personal data.
We have assessed our business interests in carrying out communication, contractual and marketing activities and we have carefully considered the impact the collection and use of personal data could potentially have on individuals’ rights.
The following are our lawful bases to process people’s personal data:
1. Where it is necessary for us to perform a CONTRACT with you
We may use and process your personal data where we have supplied you (or continue to supply you) with any legal services, For example a lease or management agreement where we have arranged for the supply of another firm's services to you, or where you are in discussions with us about a particular matter on which you are considering taking advice.
We will use your information in connection with the contract for the provision of services when it is needed to carry out that contract or for you to enter into it.
We may also use and process your personal data in connection with our recruitment activities, if you apply for a position with us (whether directly or through a third party) or send your details to us on a speculative basis.
2. Where we have a LEGITIMATE INTEREST
We process personal information for certain legitimate business purposes, which include some or all of the following:
•To educate you and/or to share with you, techniques, strategies and insights that are designed to help you improve your property business and service provision
•To update our records and generally maintain accurate communication with you
•To carry out our obligations arising from any contracts entered into between you and us;
•To allow you to participate in interactive features of our service, when you choose to do so;
•To notify you about any changes to our service.
•To identify and prevent fraud;
•To enhance the security of our network and information systems;
•To better understand how people, interact with our websites;
•To communicate with you about offers, products, services and other information that we believe may be helpful to you and your property interests;
•To determine the effectiveness of our promotional campaigns and marketing.
•To enhance, modify, personalise or otherwise improve our services and communications for the benefit of you and our customers;
•To create a profile of you based on any preferences you have indicated to us to enable us to decide what products and services to offer to you for marketing purposes
•To undertake analysis to inform our business and marketing strategy
•To manage and deliver internal projects for business improvement
•For network and information security purposes to enable us to take steps to protect your personal data against loss or damage, theft or unauthorised access
•To comply with a request from you in connection with the exercise of your rights (for example, where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)
•To assist in the management of queries, complaints or claims
•To notify you or your business of changes in the law that might affect you or your property interests and
•For the establishment, exercise or defence of our legal rights.
Where you have provided CONSENT
Where you have given us your consent we will use and process your personal data to send you communications about events, products and news updates and relevant news and announcement. Such communications may include content on relevant lettings updates, seminar and event invitations and other news/announcements.
Please note that your information may be used to send you details of our products or services that we have identified as likely to be of interest to you, based on the preferences you have indicated to us.
We will seek separate and specific consent from you in circumstances where we wish to feature your identity in a published case study, press release, advertisement or testimonial or wish to include your image in a photograph or video in connection with public relations or promotional activities.
You have the right to withdraw your consent at any time.
Where required by LAW
Where you engage us to provide letting management or other contractual / legal services to you, we will need to process your personal data and the personal data of third parties in order to comply with our legal obligations under the Letting Agents Code of Practice.
It is also a legal requirement for you to provide us with information to verify your identity in connection with anti-money laundering and criminal financing legislation as well as anti-social behaviour legislation. We may also use and process your personal data in order to comply with other legal obligations to which we are subject.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. Key-Lets will never ask for personal or sensitive information through social media platforms and we encourage users wishing to discuss sensitive details to contact us through our primary communication channels i.e. telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Our suppliers and service providers
Our work for you may require us to provide information to third parties who will use your information for the purposes of providing services to us or directly to you on our behalf. Such third parties may for example include insurers or tradesmen.
When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their services and we have an agreement in place that requires them to keep your data secure and not to use it other than in accordance with our specific instructions.
Others involved in your property management.
Our property management work may require us to provide information to third parties such as councils, tenant representatives, law firms, accountants, counsel, expert witnesses, medical professionals and other professional advisers, who will use your information in connection with a tenancy issue.
Any third party to whom we disclose information about you will be under an obligation to keep your information secure and not to use it for any purpose other than that for which it was disclosed unless you agree with them otherwise.
Credit/debit card payment processors
All payment information is handled using encrypted technology and we are compliant with the Payment Card Industry Data Security Standards (PCI-DSS). Where you make a payment to us by credit or debit card, we will use the payment card information only for the purpose of processing that specific transaction.
No credit or debit card details are stored once your payment has been processed and the transaction is completed.
When you pay for any services such as rent over the telephone/internet, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
Other ways in which we may share your personal data
We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal data if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to protect your vital interests, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and clients. However, we will always take steps to ensure that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us for our use is stored on our secure servers which are located within the UK and the European Economic Area (EEA).
The third parties may be located outside of the EEA or they may transfer your data outside of the EEA. Those countries may not have the same standards of data protection and privacy laws as in the UK, which means additional safeguards must be put in place. Whenever we transfer your data outside of the EEA, we impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UK. We may also require the recipient to subscribe to 'international frameworks' intended to enable secure data sharing. Any third parties transferring your data outside of the EEA must also have in place appropriate safeguards as required under data protection law.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR
How long we will retain your personal data is determined by a number of factors including the type of data, the purpose for which we use that data and our regulatory and legal obligations attached to this use. We do not retain personal data in an identifiable format for longer than is necessary.
The only exceptions to this are where:
•the law requires us to hold your personal data for a longer period, or delete it sooner;
•you exercise your right to have the data erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law
•the law permits us to keep your personal data indefinitely provided we have certain protections in place.
You have a number of rights in relation to your personal data under data protection legislation. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal data
You have the right to ask for a copy of the data that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal data if it concerns other individuals or we have another lawful reason to withhold that data.
Correcting and updating your personal data
The accuracy of your data is important to us and we are working on ways to make it easier for you to review and correct the data that we hold about you.
However if you change your name or address/email address, or you discover that any of the other data we hold is inaccurate or out of date, please let us know by contacting us on 01292 289289 or firstname.lastname@example.org.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time by email@example.com (please use "Withdrawal of consent" as the subject heading of your email).
You also have the right to:
1.Request to see the personal data we hold about you. This includes the right to obtain confirmation as to whether or not we process any of your personal data. There may be a charge to provide this as set out under applicable law;
2.Request that we correct any inaccuracies in the personal data that we hold on you;
3.If you wish you can request to have your personally identifiable data deleted from our database and/or to stop receiving communications from us;
4.Request that we do not process your personal data for marketing purposes;
5.Object to our processing of your personal data if we are relying on legitimate interest as the lawful ground for processing;
6.withdraw your consent to receiving any email communications to which you previously opted-in, you can do so using our Unsubscribe tool at the footer of the email
If you withdraw your consent, our use of your personal data before you withdraw your consent is still lawful.
If you wish to talk to us about any of the above, please drop us an email at firstname.lastname@example.org
If you have any concerns or complaints about our activities, you can contact us on email@example.com or you can call 01292 289289 during normal office hours.
If you withdraw your consent, our use of your personal data before you withdraw your consent is still lawful.
Under no circumstance do we sell your information or personal data to third parties.
Erasing your personal data or restricting its processing
In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at 12 Parkhouse Street, Ayr KA7 2HH. Provided we do not have any continuing lawful reason to continue processing or holding your personal data, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal data where you believe our processing is unlawful, you contest its accuracy, you have objected to its use and our investigation is pending, or you require us to keep it in connection with legal proceedings. We may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal obligations or proceedings.
Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner's Office (ICO) if you are concerned about the way we have processed your personal data. Please visit the ICO's website for further details.
SECURITY AND LINKS TO OTHER SITES
Security measures we put in place to protect your personal data
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your personal data, we have in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access any of our online or electronic resources, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Links to other websites
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites, so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites even if you access them using links that we provide, and their security cannot be guaranteed.
If you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
Use of 'cookies'
The main purposes of the cookies we use are:
•Session – to allow the user to navigate our sites more easily; for example, you don’t have to login in as a new user every time.
•Analytics – to improve the user experience of the site by providing statistics on how the site is used.
•Authentication – this enables us to identify you and therefore where appropriate, personalise information for you.
How to refuse and delete cookies
You can refuse to accept all or some cookies by modifying your settings within your browser – for help on how to do this visit www.aboutcookies.org.uk
You may also delete all cookies on your browser – click help on your browser or visit www.aboutcookies.org.uk
Please remember that if you block the session cookies you may be unable to access certain parts of our websites.
Have a question? You can get in touch with us by sending an email to firstname.lastname@example.org or you can call +44 (0)1292 289289.
Key-Lets, 12 Parkhouse Street, Ayr, Scotland KA7 2HH