As part of everyday business activities that we carry out, we need to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This privacy notice sets out how we will process personal data we collect from or about you, or which you provide to us. Please read this notice carefully to understand why data is being collected and what we do with that data. We may also update the privacy notice from time to time by amending this page.
Our website and services may contain links to independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies.
For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Kinden Limited (We), a company registered in England & Wales under company number 12587609. Our registered address is 1 Walcot Gate, Bath, Avon, United Kingdom, BA1 5UG, and We are registered with the Information Commissioner's Office (ICO) as follows:
Organisation name: Kinden Limited
ICO Registration Reference: ZA250244
What type of information will we collect from you?
The personal information we collect from our clients or potential clients will typically include the following:
Full name and contact details (this includes your contact number, email and postal address)
Information relating to your identity where we are required by law to collect this to comply with the Money Laundering Regulations 2017 and the Immigration Act
Information on your close connections where we are required to conduct conflicts of interests under regulatory obligations
Your banking details where required if you engage us to carry out property management activities and we help you to let out a property or, where if you are renting,so we can set up an approved tenancy deposit account for you and arrange for rental payments
Details about your areas of interest and requirements of desired property if you engage us in sourcing or finding a property for you
Your communications with us, including a record of the email or telephone correspondence, created when you contact us as part of a product or service query
Where we need to collect personal data by law (for example to meet our obligations to prevent fraud and money laundering) or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case.
On what basis can we process your information?
The legal grounds under data protection legislation for processing your personal data are as follows:
It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, for us to provide you with our products and services
You have given us explicit consent to the processing of your personal data for one or more specific purposes, namely 1) where you have given us consent to receive electronic marketing by us and/or 2) to process your Special Category Personal Data described above. You do not need to provide us with marketing consent in order to receive our services
It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests include processing necessary data to improve and to promote our services and products and to better understand our customers’ interests and knowledge of the property market and to administer the technical aspects of our service and products.
Where we need to comply with a legal obligation; or in rare circumstances
Where we need to protect your interests (or someone else's interests); and/or
Where it is needed in the public interest or for official purposes
What do we do with your information?
We will hold and use personal information about you in the following ways:
To fulfil our obligations to you when providing you with our property related services
To share your information with others where necessary to fulfil our property services for you or where acting as agent for a third party on your behalf
To comply with our statutory and regulatory obligations, including verifying your identity, prevention of fraud and money laundering and to assess your credit worthiness
Communicate with you during the course of providing our services, for example with your enquiries and requests
Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future
To provide you, or to enable third parties to provide you, with information about goods or services we feel may interest you, where you have provided permission for us to do so or, if you are an existing customer only, where we choose to contact you by electronic means (including e-mail or SMS) with information about our own goods and services similar to those which you have already obtained from us or negotiated to obtain from us . For those marketing messages you can unsubscribe at any time
To notify you about changes to our service
To ensure that content from our site is presented in the most effective manner for you and for your computer
How long we keep your data for
We will retain your personal data for different periods depending on the service you have chosen to use us for. Data may be retained electronically or physically
Individuals’ data is retained for all:
Vendors – clients for whom we have sourced or attempt to source property for, or clients that we manage renovations for.
Tenant Applicants - people who have registered their details to become tenants.
Landlords – clients for whom we carry out property management which may include also the letting of property or attempted to let a property
Period data is retained:
Until You change their preferences and decide not to receive any further emails (they are to be archived). They will be subsequently deleted unless we have a contractual or legal obligation to retain their data;
If we have a contractual or legal obligation to retain data, that data will be retained until the legal obligation no longer applies (generally after six years). Data that is archived, is no longer current and not required to be retained for contractual or legal obligations shall be permanently deleted.
Physical files are created and retained for sales or lets that are current or have already completed. Files for deals that were completed more than six years previously are to be permanently deleted/shredded.
Who do we share your information with
We will pass your details to the following organisations who carry out certain activities on our behalf as part of us providing our services.
Name of Third Party
Purposes for Carrying out Processing
Lettings advertising and online property management tool.
ICO registration number: ZA280842
Project Management Tool
Website host and online webchat provider
Newsletter subscription management
Bunk App Ltd
We will also pass your details where necessary to your property solicitors and those of the other party to your transaction. We will also disclose your personal information to third parties:
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.
If our company or substantially 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.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will not share your information with third parties for marketing purposes without first obtaining your prior consent.
Security of your data
Your data will be held on secure servers within the European Economic Area ("EEA") with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.
If we have given you a username and password which enables you to access certain parts of your matter on our systems, you are responsible for keeping it confidential. Please do not share it with anyone.
How you can access and update your information
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. These requests are free of charge and can be sent to firstname.lastname@example.org
If you signed up to receive contents from us or our newsletter via our website, you have the right to unsubscribe any time or update your information via the links included in every email communication.
How you can request erasure of your data
You can 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 you have withdrawn consent for us to process it (as explained 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.
How you can withdraw your consent
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. You can contact us at email@example.com
How you can restrict or object to us using your data
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used please contact us at firstname.lastname@example.org
Complaints about the use of your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us at email@example.com
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.