Who we are
Welcome to SAY’s privacy policy.
SAY Property Consulting LLP (referred to as “SAY”, “we“, “us” or “our“), is a company registered in England and Wales under company number OC343485 is a Data Controller and in some instances a Data Processor, in respect of personal data provided by our clients.
We are registered on the Information Commissioner’s Register, number ZB076842. We have an appointed data privacy manager who is responsible for overseeing your concerns in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your data subject rights, please contact the data privacy manager using the details set out at the end of this document.
Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document we explain how we collect, use and protect your personal data. We also explain what rights you have with regards your personal data and how to exercise those rights. It is important that you read this privacy notice, together with any other privacy, policy or fair processing notice that we may provide on specific occasions when we collect or process personal data about you.
This privacy notice is based on the terms used in the United Kingdom, general data protection regulation UK GDPR and for ease of understanding the following definitions apply:
Consent: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Controller: the natural or legal person, public authority, agency, company, organisation or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the Information Commissioners Office.
Data subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Personal data: any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processor: a natural or legal person, public authority, agency, company, organisation or other body which processes personal data on behalf of the controller.
Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Recipient: a natural or legal person, public authority, agency, company, organisation or another body, to which the personal data are disclosed, whether a third party or not.
Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future.
Third Party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
How we collect and how we use it
We process your personal information to meet our legal, statutory and contractual obligations and provide you with our products and services. You may give us information about you by corresponding with us by post, phone, email, social media or otherwise by submitting an enquiry via our website, by opting in to receive a newsletter, or when you take part in a prize, draw, competition or survey. We may also collect personal data from publicly available sources such as Companies House. We will never collect any unnecessary personal data from you, and do not process your information in any way other than specified in this notice.
The personal data we may collect from you is:
- name
- personal email
- business email
- business telephone number
- mobile telephone number
- IP address, browser and version
- Website tracking and analytics
- Photographs and other digital media
In special circumstances, primarily around employment, we may process Special Category Personal Data about you (this may include 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) and we will of course obtain express permission. Where necessary we may process information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Most commonly, we will use your personal data in the following circumstances:
- where are you have consented for us to contact you
- for performance of contract
- where we need to comply with a legal or regulatory obligation
- vital interests
- where legitimate interests, all those of third party, and your interests and fundamental rights do not override those
We will only use of 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. In those circumstances, the privacy notice will always be updated and we will notify you of the changes. Please note that we may process your personal data without your consent in compliance with the above rules where this is required or permitted by GDPR.
Cookies
Cookies are small text files that are placed on your computer when you access the website these allow websites to do several important things including remembering which pages you visited.
If you visit our website and when your browser is set to accept cookies, we will interpret this as an indication that you consent to use our cookies or other similar technologies. If you change your mind in the future, you can modify the settings in your browser to reject cookies or disable cookies completely. If you do this, please be aware that you may lose some of the functionality of our website and continuing to use our website you have consented to information being collected from your device by cookies and other technologies for the purposes is described in this privacy notice.
How long we retain your personal data for
We only retain your personal data for as long as we need it, and for the purposes for which it was collected, and whilst taking into consideration our legal, accounting or reporting obligations. We will on an ongoing basis to review the length of time to retain your personal data. We will securely delete your personal data if it is no longer needed for such purposes or update or archive or securely delete your personal data if it goes out of date. 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. For further information on how long we retain your personal data, please contact our data privacy manager.
Data Sharing & Third parties
We use third parties to provide various systems to support company activities and additionally, some data may be shared with third parties in the following instances:
- Who are directly involved in dealing with any requests or enquiry made by you
- For internal business functions such as finance, CRM and HR
- For marketing purposes, where you may opt out or withdraw any time
- For promotional offers
- Where such disclosures are required by law
- With third parties who are providing us with professional advice
- Where the disclosure is in connection with any criminal investigation, legal proceedings or in respective legal proceedings where permitted by law
- Where the disclosure is in order to establish or exercise or defend our legal rights, including providing information to for prevention or reducing credit risk
- Where required to enforce our T&Cs.
- Where we have stated or informed you otherwise e.g. there is privacy notice or website
- Unless we have your consent , we will not pass on information to a third-party for purposes of their marketing
- We may also disclose your personal data to third parties in the event that we sell, merge or buy any businesses or assets, or parts thereof (in which case we may disclose your personal data to the prospective seller or the buyer of such businesses or assets)
- Or if all of our assets are required by third-party, in which case, personal data held by us about our clients, and subscribers will be one of the transferred assets
We request 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.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Right to be Informed: you shall have the right to obtain clear and transparent information about the data controllers data processing activities. This is provided in this privacy notice.
Right of Access: 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.
Right of Rectification: 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.
Right to 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.
Right to 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.
Right of 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.
Right to Data Portability: 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.
Right to 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.
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.
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.
Security Measures
We take your privacy seriously and take every possible reasonable measure and precaution to protect and secure your personal data. We work hard to protect this data and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know
- we have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office of a breach where we are legally required to do so.
- restricted access to areas used to store data via firewalls encryption and the latest widely accepted security protocols.
- Cybersecurity and Bring Your Own Device policies implemented
- Data breach and incident response plans
- organisational and technical measures
The Internet is global and no data transmitted via the Internet can be guaranteed to us to be completely secure during transmission. We cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security, unless it’s due tried making agents or wilful default.
Our website is hosted in the EU and all personal data provided to us is stored within our server located in the EU. The European Union, EU, has formally recognised the U.K.’s high data protection standards and this allows the continued seamless flow of personal data from the EU to the UK.
Transfers outside of the UK ,(if applicable), not currently applicable
Personal data in the United Kingdom is protected by the UK general data protection regulation, UK GDPR and the Data Protection Act 2018, DPA 2018 but some other countries may not necessarily have the same high standards of protection for your personal data.
We may utilise some products or services (or parts of them) that may be hosted or stored outside of the UK, for our business functions, such as HR, banking or other, which means that we may transfer any information which is submitted by you.
Consequences of not providing your data
You are not obliged to provide your personal information to us however, as this information is required for us to provide you with our services and or deliver our products, we will not be able to offer some or all of our services without it.
Contacting us and lodging a complaint
We only process your personal information in compliance with his privacy notice, and in accordance with the relevant data protection laws. If however, you wish to raise a complaint regarding the processing of your personal data or are unhappy with how we’ve handled your information you have the right to lodge a complaint with the ICO, however, in the first instance, we would always prefer to help you directly and resolve any concerns you may have.
Our Full Details Are:
Full name of legal entity: SAY Property Consulting LLP (company number OC343485)
Name or title of data privacy manager: Shilpa Wymer
Email address: shilpa@sayproperty.co.uk
Postal address: 211 – 213 Regent Street, London, W1B 4NF
Registered Address: 24 Old Bond Street, London W1S 4AP
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk