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Privacy Policy

Your privacy is important to us, and so is being transparent about how we collect, use and share information about you. Therefore, this privacy policy is intended to help you understand and will explain how your personal information is collected, used and shared by Kinleigh Folkard & Hayward. Please read this privacy policy carefully. When using our website, this privacy policy should be read alongside, and in addition to, the website terms and conditions.

1. About us
2. Our processing of your personal information
3. Marketing activities
4. How long we keep your personal information for?
5. What is our approach to sending information overseas?
6. How do we protect your information?
7. Your rights
8. Cookies
9. Contacting us
10. Updates to this notice

 

1. About us

In this privacy policy, references to "we" or "us" or "Kinleigh Folkard & Hayward" or "KFH" are reference to Kinleigh Limited, Kinleigh Folkard & Hayward Limited and Kinleigh Financial Services Limited. 

KFH is one of London's most successful property services groups. KFH offer a diverse range of property services including residential sales and lettings, property management, new homes sales, conveyancing, chartered surveyors, financial services, commercial property services and corporate and relocation services. To enable us to provide our services we need to collect and process personal information.  This makes us a "data controller" for any personal information you provide to us for which we are responsible for complying with data protection laws.

This privacy policy therefore covers the activities of Kinleigh Limited, Kinleigh Folkard & Hayward Limited and Kinleigh Financial Services Limited. The specific company acting as a data controller of your personal information will be listed in the documentation we provide to you.

A data protection officer (“DPO”) has been appointed on behalf of all three KFH companies and, accordingly, if you have any questions about this privacy policy or if you are unsure about who the data controller of your personal information is please contact our DPO using the details set out in section 9.   

2. Our processing of your personal information

Our relationship with you and the type of services we provide will dictate the nature of personal information that we collect and use about you. It will also dictate the uses we make of your personal information, for example we will collect different personal information depending on the type of property i.e. residential or commercial and the services we provide to you.

When we provide our services, we will sometimes ask or receive "special categories of personal information”. The Information Commissioner’s Office website (which can be accessed here) provides a full list of what is considered special categories of personal information. Out of these categories, there will be limited circumstances when KFH may collect information relating to your health and criminal convictions, for example when we advise you on or recommend a mortgage product, we will collect details about your criminal convictions data for fraud prevention purposes and we will collect information about your health via a medical questionnaire in order to arrange mortgage protection insurance cover for you.

Where you provide personal information to us about other individuals (for example family members who will be living in a property we are helping you buy or personal information about your dependents if relevant to your mortgage application) we will also be data controller of their personal information. You should refer them to this privacy policy before supplying us with their information on their behalf. 

Please note that we may aggregate personal information collected about you with other individuals' personal information, device information and location information to provide general statistics so that we can improve our services and provide a better experience. In doing so, neither you nor any other individual can be identified from the information and as such, that data will not be subject to this privacy policy or data protection law.

In order to make this privacy policy as user friendly as possible, we have split it into different sections depending on the type of service you have engaged KFH for. Please click on the section below that is applicable to you and that describes the relationship you have with us. 

2.1 Individual buyer, seller, landlord or tenant of residential property

Individual buyer, seller, landlord or tenant of residential property

This section will detail what personal information we collect about you and use if you are a buyer, seller, landlord or tenant of residential property.

What personal information will we collect?

  • Your name, address and title.
  • Contact information, including telephone number, postal address and email address.
  • Financial information such as your bank details, payment details and information obtained as a result of our credit checks such as bankruptcy orders, individual voluntary arrangements or county court judgments where you are a landlord or tenant.
  • Documents provided to evidence proof of name (such as your passport, birth certificate and driving licence) and proof of address (such as utility bill, bank statement, local authority bill, NHS medical letter or GP letter of confirmation).
  • Where you are a tenant and we have introduced you to a referencing company, any information collected as part of a reference request.
  • In respect of reservation new home sales under the Help to Buy Scheme, any information provided on your reservation form including details of the property, any special conditions and financials.
  • Where you are a tenant, information about your job such as your job title, employment history and employment records (including information on your salary, benefits and earnings).
  • Additional information which is relevant to the property you are buying, selling, letting or renting for example:
    • your current home status and living circumstances; and
    • your family circumstances.
  • Information which we have gathered from publically available sources such as the HM Land Registry.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices or we visit you at your property;
  • you complete documentation including terms and conditions of business, landlord management information, application for tenancy and reference requests;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone, WhatsApp and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter or property alerts.

As well as obtaining information directly from you, we will also collect information from:

  • third parties involved in the sale/letting process such as solicitors, estate agents, third party referencing companies (where you are a tenant) and other property management companies;
  • publically available sources such as Companies House and the HM Land Registry;
  • other companies within the KFH Group; and
  • credit reference agencies where you are a tenant.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to arrange and administer the letting or sale of your property and to keep you updated on progress.
  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all properties that we have been involved with, to assist with the buying or letting process, to keep all stakeholders updated, to keep business and accounting records, manage our business operations and to develop and to improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent.

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To set you up as a client or customer and carry out anti-money laundering checks, when required
  • It is necessary to enter into your contract.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to assess your suitability as a buyer/seller).
None
 To provide services to you such as assisting you with buying or renting a property
  •  It is necessary to enter into your contract.
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties and deliver our services when you are buying/selling/letting/renting a residential property).
 None
 To introduce you to a referencing company if you are a tenant
  •  We have a legitimate business purpose (to ensure that all tenants undergo the required reference checks).
 None
Communicating with you by telephone, email and WhatsApp and when contacting you by WhatsApp, ensuring that we adhere to WhatsApp terms of use.
  •  It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose to communicate with you. 
  • We have your consent (to communicate with you by WhatsApp)
 None
Resolving any complaints that you might have.
  • It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
None
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer). 
None
Complying with our legal or regulatory obligations
  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Reviewing, assessing, tailoring, and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction)
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose (to market our services).
  • We have your consent.
None
Tracing and recovering debt
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
None
To apply for and claim on our own insurance.
  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
None

Who do we share personal information with?


We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved in the sale or letting process such as solicitors, estate agents, property developers, mortgage and financial advisers and other property management companies.
  • A referencing company and landlords where you are a tenant and we have introduced you to a particular referencing company.
  • In respect of reservation of new home sales under the Help to Buy Scheme: the Homes and Communities Agency and clients.
  • Other KFH Group companies.
  • Insurers who provide our insurance and companies who arrange such insurance.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Third parties Stitch AI Ltd and Sendbee Inc. who enable us to communicate with you by WhatsApp.
  • Debt collection agencies.
  • Credit reference agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties such as Trustpilot who we use to gather feedback about our services and client testimonials.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

2.2 Individuals to whom we provide relocation services to

This section will detail what personal information we collect about you and use if we provide relocation services directly to you.

What personal information will we collect?

  • Your name and address and title.
  • Contact information, including telephone number, postal address and email address.

If you proceed with a tenancy or sale, we will also collect the following personal information:

  • Financial information such as your bank details, payment details and information obtained as a result of our credit checks such as bankruptcy orders, individual voluntary arrangements or county court judgments.
  • At the point of a sale/entering into a tenancy agreement, documents provided to evidence proof of name (such as your passport, birth certificate and driving licence) and proof of address (such as utility bill, bank statement, local authority bill, or NHS medical letter or GP letter of confirmation)
  • Where you are a tenant and we have introduced you to a referencing company, any information collected as part of a reference request.
  • Information about your job such as your job title, employment history and employment records (including information on your salary, benefits and earnings).
  • Additional information which is relevant to the relocation services for example:
    • your current home status and living circumstances; and
    • your family circumstances.
  • Information which we have gathered from publically available sources such as the HM Land Registry.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you. 

How will we collect your personal information? 

We will collect information directly from you when:

  • you visit our offices;
  • you complete documentation; for example an application for tenancy;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter or property alerts

As well as obtaining information directly from you, we will collect information from:

  • third parties involved in the relocation process such as solicitors, previous landlords, other property management companies, third party referencing companies and your employer where you are a corporate employee being relocated;
  • publically available sources such as the HM Land Registry;
  • other companies within the KFH Group; and
  • credit reference agencies.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to provide relocation services to you.
  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all individuals to whom we provide relocation services to, to keep you updated on the relocation process, to keep business and accounting records, manage our business operations and to develop and to improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent.

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To set you up as a tenant customer and carry out anti-money laundering checks, when required
  • It is necessary to enter into your contract.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to carry out these checks before providing any services to satisfy our anti-money laundering requirements).
None

To provide our relocation services which include:

  • finding properties for you;
  • scheduling viewing appointments with our branches;
  • assisting with tenancy negotiations and contracts; and
  • supporting you through the letting process
  • It is necessary to enter into your contract.
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties and deliver high quality relocation services).
None
To introduce you to a referencing company if you are a tenant
  • We have a legitimate business purpose (to ensure that all tenants undergo the required reference checks)
None
Communicating with you and resolving any complaints that you might have.
  • It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
None
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None
Complying with our legal or regulatory obligations.
  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Reviewing, assessing, tailoring and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction)
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose (to market our services).
  • We have your consent.
None
Tracing and recovering debt. 
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
None
To apply for and claim on our own insurance.
  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
None

 

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved in the relocation process such as companies we appoint to assist with your search for a property.
  • Your employer where you are a corporate employee being relocated.
  • A referencing company and landlords where you are a tenant and we have introduced you to a particular referencing company.
  • Other KFH Group companies.
  • Insurers who provide our insurance and companies who arrange such insurance.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Credit reference agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business. 

2.3 Individuals who receive our professional services (valuation and surveys) and commercial property selling and letting and property management services

Individuals who receive our  Professional services (survey and valuations)  and commercial property selling and letting and property management services

This section will detail what personal information we collect about you and use if you are a consumer individual who has instructed us directly or who has been referred to us in relation to our professional services or commercial property selling and letting and property management services .

What personal information will we collect?

  • Your name, address and title.
  • Contact information, including telephone number, postal address and email address.
  • Financial information such as your bank details, payment details and information obtained as a result of our credit checks such as bankruptcy orders, individual voluntary arrangements or county court judgments. When engaging us for our survey services, we only collect your payment details.
  • When engaging us for commercial services, information relating to your identity such as your national insurance number, passport number and driving licence number.
  • Information about your job such as your job title and role.
  • Additional information which is relevant to the property you are arranging to have surveyed or valued for example purchase price and lease details.
  • When engaging us for commercial services, we will also collect information on occupational leases and planning permissions which may contain your personal information.
  • Information which we have gathered from publically available sources such as the HM Land Register.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices or we visit you;
  • you complete documentation including terms and conditions for instructions to sell and let and valuations related documents such as rent reviews, lease renewals and formal valuations;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter or property alerts.

As well as obtaining information directly from you, we will collect information from:

  • publically available sources such as the HM Land Register; and
  • other companies within the KFH Group.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to fulfil our contractual obligations and provide our survey professional services and commercial property and property management services.
  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all properties that we have surveyed, managed or assisted with the letting/buying process, to keep business and accounting records, manage our business operations and to develop and improve our products and services). When using your personal information for these purposes, we will always consider your rights and interests. When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent.

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information

To set you up as a customer or client and carry out fraud, credit and anti-money laundering checks, when required

  • It is necessary to enter into your contract.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to set you up as a client and carry out the appropriate checks).
None

To provide our services which include:

  • Survey - Home Buyer Reports
  • Red Book Valuations for tax/probate and matrimonial purposes.
  • Lease extensions
  • The sale and letting of freehold and leasehold properties
  • It is necessary to enter into your contract.
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties and deliver our services when you are buying/ selling/letting/renting a property).
None
Communicating with you and resolving any complaints that you might have.
  • It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
None
Providing improved quality, training and security.
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Reviewing, assessing, tailoring and improving our service offerings.
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction)
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose (to market our devices).
  • We have your consent.
None
Tracing and recovering debt.
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
None
To apply for and claim on our own insurance
  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
None

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved in the survey process such as lenders or solicitors.
  • Insurers who provide our own insurance and companies who arrange such insurance.
  • Fraud detection agencies and other third parties who operate and maintain fraud detection registers.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Credit reference agencies.
  • Other KFH group companies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

2.4 Individuals who receive our block management services

This section will detail what personal information we collect about you and use if:

  • You are a client and we are a managing agent of your block; or
  • You are a leaseholder living in a block property which we are a managing agent of; or
  • You are subletting a block property which we are a managing agent of.

What personal information will we collect? 

  • Your name, address and title.
  • Contact information, including telephone number, postal address and email address.
  • Financial information such as your bank details and payment details which we need in order to administer your payments.
  • Where you are a director of a company whom we provide block management services to: information relating to your identity such as your national insurance number, passport number, vehicle registration number or driving licence number.
  • Information which we have gathered from publically available sources such as the HM Land Register, and Companies House.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices;
  • you complete documentation including contact forms and companies house forms;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter or property alerts.

As well as obtaining information directly from you, we will collect information from:

  • previous managing agents or companies of the block property when we on-board a new block property;
  • publically available sources such as Companies House and the HM Land Register; and
  • other companies within the KFH Group.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to fulfil our contractual obligations.
  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all properties that we have been involved with, to allow us to provide high quality services, to keep all stakeholders updated, to keep business and accounting records, manage our business operations and to develop and improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent.

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To set you up as a client and carry out anti-money laundering checks
  • It is necessary to enter into your contract.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to carry out checks on clients).
None

To provide our block management services which include: for example

  • Providing reports of property visits
  • Purchasing items such as utilities, insurance and contractors
  • Negotiating, reviewing and managing maintenance contracts
  • Managing health and safety requirements
  • It is necessary to enter into your contract.
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties and deliver high quality block management services).
None
Communicating with you and resolving any complaints that you might have.
  • It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
None
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Reviewing, assessing, tailoring and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction).
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure. 
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose  (to market our devices)
  • We have your consent
None
Tracing and recovering debt.
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
None

To apply for and claim on our own insurance.

  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
None

 

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved in the block management services process such as solicitors, estate agents, house builders and developers, housing associations, local authorities, third party utilities and insurance providers, emergency service teams and repair providers.
  • Where you are a leaseholder, the owner of the block property.
  • Other KFH Group companies.
  • Insurers who provide our own insurance and companies who arrange such insurance.
  • Fraud detection agencies and other third parties who operate and maintain fraud detection registers.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Credit reference agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

 

2.5 Individuals who receive KFH mortgage, insurance and assurance services

This section will detail what personal information we collect about you and use if you are an individual receiving mortgage, insurance and/or assurance services from us.

What personal information will we collect?

  • Your name, address and title.
  • Contact information, including telephone number, postal address and email address.
  • Financial information such as your bank details, payment details and information obtained as a result of our credit checks such as bankruptcy orders, individual voluntary arrangements or county court judgments.
  • Information relating to your identity such as your national insurance number, passport number, vehicle registration number or driving licence number.
  • Information about your job such as your job title, employment history and employment records (including information on your salary, benefits and earnings.
  • Additional information which is relevant to the services we are providing for example:
    • your property ownership status and information about your property;
    • details about your existing mortgage information; and
    • information about your lifestyle.
  • Information which is related to your financial situation and is relevant to a mortgage application including:
    • your bank account, payment details and ISA account number;
    • tax residency information and tax identification number;
    • financial reviews (fact finds); and
    • information relating to your personal finances such as your financial liabilities and assets, income and outgoings.
  • Information which we have gathered from publically available sources such as internet search engines like Google, the Land Register, Companies House, Government department websites and social media sites, including Facebook and LinkedIn.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

  • Where we recommend a mortgage product to you, we will collect details about your criminal convictions and any related information for the purposes of fraud detection and prevention which are required for the mortgage application. This means we will collect any information relating to any offences or alleged offences you have committed and any caution, court sentence or criminal sentence which you are or have been subject to.
  • Where we advise on and recommend an insurance product such as mortgage protection to you, we will collect details about your physical and mental health via a medical questionnaire which are relevant to the insurance application.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices and have a face to face appointment with our advisers to discuss mortgage and insurance needs and we create a contact record of our meetings onto our client portal;
  • you complete documentation as part of the initial disclosure document and fact finding process which include expense forms, monthly spend forms, third party reference letters and express consent forms and any documents required to be completed by your insurer or mortgage lender when assisting you in the arrangement of your insurance or mortgage;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone (in particular via the central mortgage services team helping) and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter.

As well as obtaining information directly from you, we will collect information from:

  • publically available sources such as internet search engines like Google, Companies House, the Land Register and social media sites, including Facebook, YouTube and LinkedIn;
  • other companies within the KFH Group; and
  • credit reference agencies.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to fulfil our contractual obligations.
  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all services that we provide and decisions provided, to allow us to provide high quality services, to keep all stakeholders updated, to keep business and accounting records, manage our business operations and to develop and improve our products and services). When using your personal information for these purposes, we will always consider your rights and interests. When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When the information that we process is classed as “special categories of personal information", we must have an additional “legal ground" and we will rely on the following legal grounds:

  • We need to use your special categories of personal information for purposes relating to an insurance policy and there is a substantial public interest in such use. Such purposes include advising on and arrange mortgage protection insurance.
  • We need to use your special categories of personal information for the purposes of preventing and detecting unlawful acts and there is a substantial public interest in such use. Such purposes include when we need details about any criminal convictions and any related information for the mortgage application.
  • We need to use your special categories of personal information to establish, exercise or defend legal rights. This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves.
  • You have provided your consent to our use of your special categories of personal information. We will always explain why your consent is necessary.
Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information

To set you up as a client and carry out fraud, credit and anti-money laundering checks

  • It is necessary to enter into your contract.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to carry out checks on clients).
None
To provide our services which include making recommendations on mortgages and protection needs and managing the relationship with your mortgage lender and/or insurer on your behalf.
  • It is necessary to enter into your contract.
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties).
  • Such use is necessary for insurance purposes
  • It is in the substantial public interest to prevent or detect unlawful acts
  • We have your explicit consent
Communicating with you and resolving any complaints that you might have.
  • It is necessary to enter into or perform your contract.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
  • Such use is necessary for insurance purposes
  • We need to use your information in order to establish, exercise or defend legal rights.
  • We have your explicit consent
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
  • Such use is necessary for insurance purposes
  • We need to use your information in order to establish, exercise or defend legal rights.
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
  • We need to use your information in order to establish, exercise or defend legal rights.
  • We have your explicit consent
Reviewing, assessing, tailoring and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction).
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
  • We need to use your information in order to establish, exercise or defend legal rights.
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
  • You have given us your explicit consent.
To market our services.
  • We have a legitimate business purpose  (to market our devices)
  • We have your consent
None
Tracing and recovering debt.
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
  • We need to use your information in order to establish, exercise or defend legal rights.

To apply for and claim on our own insurance.

  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
  • We need to use your information in order to establish, exercise or defend legal rights.
  • Such use is necessary for insurance purposes

 

 

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

Where we engage with you relating to an insurance policy we will share your personal information with:

  • Third parties including insurers, brokers, intermediaries to arrange your insurance policy. We have chosen to partner exclusively with the insurer Legal & General.

Where we engage with you relating to mortgage advice or assurance services we will share your personal information with:

  • Mortgage lenders.
  • Financial advisers and third party brokers whom we have referred you to if you are a high net worth client.
  • Solicitors and estate agents.

In addition to the above, we will also disclose your information to the following parties:

  • Other KFH Group companies.
  • Insurers who provide our own insurance and companies who arrange such insurance.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Credit reference agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

 

2.6 Individuals who engage KFH for conveyancing services

Consumers who are buying and selling property

This section will detail what personal information we collect about you and use if you are an individual buying or selling property and we provide you with conveyancing services.

What personal information will we collect?

  • Your name address and title.
  • Contact information including telephone number, postal address and email address.
  • Financial information such as details of the mortgage you have or will require.
  • Information which is relevant to the property you are buying or selling for example:
    • your current home status; and
    • details of your current property sale or purchase.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices or have a consultation with us;
  • you use our website;
  • you contact us to make a complaint;
  • you contact us by email, telephone and through other written and verbal communications; and
  • you request information about our services or subscribe to a newsletter.

As well as obtaining information directly from you, we will collect information from other companies within the KFH Group.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to keep a record of individuals we have introduced to our conveyancing panel, to allow us to provide high quality services, to keep you updated, to keep business and accounting records, manage our business operations and to develop and to improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To set you up as a client or prospective client and provide you with a quote.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to assess your suitability to receive these services).
None

Where you have agreed to our quote, to provide access to our conveyancing services provided by our panel of solicitors.

  • We have a legitimate business purpose (to use your information to fulfil our contractual duties and deliver high quality conveyancing services).
None
Communicating with you and resolving any complaints that you might have.
  • We have a legitimate business purpose (to send you communications, record and investigate complaints and ensure that future complaints are handled appropriately).
None
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Reviewing, assessing, tailoring and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction).
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose (to market our services).
  • We have your consent.
None

To apply for and claim on our own insurance.

  • We have a legitimate business purpose (to ensure that we have appropriate insurance in place).
None


Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved in the conveyancing process such as our panel of solicitors and search providers.
  • Other KFH Group companies.
  • Insurers who provide our insurance and companies who arrange such insurance.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

 

2.7 Third party suppliers and business partners

If you are one of the following third parties who do business with us or another business partner with whom we work with or a contact at one of the following, this section will detail what personal information we collect about you and use:

  • Solicitors;
  • A relocation agent with whom we engage to assist with the provision of our relocation services;
  • A contact at a panel organisation or search provider;
  • Mortgage and protection advisers;
  • Maintenance and repair suppliers;
  • Marketing agents;
  • Property Management companies;
  • Property developers;
  • Photographers; or
  • Block management service providers (consultancy, contractor, utilities).

What personal information will we collect? 

  • Your name and contact information, including previous contact information, such as your telephone numbers, email addresses and post addresses.
  • Information about your job such as job title.
  • Information which we obtain as part of checking sanctions lists if necessary.
  • Information which we have gathered from publically available sources such as internet search engines like Google, Companies House, Land Registry, Government department websites and social media sites, including Facebook and LinkedIn.

What special categories of personal information will we collect?

We do not collect any of your special categories of personal information.

How will we collect your personal information?

We will collect information directly from you when:

  • you visit our offices or have a consultation with us;
  • you complete documentation such as terms of business; or
  • you contact us by email, telephone and through other written and verbal communications.

As well as obtaining information directly from you, we will collect information from:

  • other third parties in the property industry who refer your services to us;
  • publically available sources such as internet search engines like Google, Companies House, the Land Register and social media sites, including Facebook and LinkedIn; and
  • other companies within the KFH Group.

What will we use your personal information for? 

We use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal information":

  • We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to engage your services.
  • We have a legal or regulatory obligation to use such personal information. For example we may be required to carry out certain background checks and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business reason (e.g. to keep business and accounting records and to manage our business operations). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent.
Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To provide our services
  • We have a legitimate business reason (to effectively provide  our services we rely on the expertise of other third parties to assist)
None
To build and maintain our business relationships
  • It is necessary to enter into or perform our contract with you.
  • We have a legitimate business reason (to build strong business relationships and manage such relationships).
None
To provide a third party referral process
  • We have your consent.
  • We have a legitimate business reason (to refer customers, clients and third parties to you which would be useful for you).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, internal audit requirements, receiving professional advice (e.g. tax or legal advice).
  • It is necessary to enter into or perform our contract with you.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business reason (to effectively manage our business operations).
None
Communicating with you to manage and handle your queries.
  • We have a legitimate business reason (to send you communications to effectively manage our business and respond to your queries).
  • It is necessary to enter into or perform our contract with you.
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business reason (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business reason (to manage our business and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
Tracing and recovering debt
  • We have a legitimate business purpose (to trace and recover debt that is owed to us).
None

Who will we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other third parties involved such as solicitors, estate agents, landlords and mortgage brokers.
  • Any of our clients and customers.
  • Other KFH Group companies.
  • Insurers who provide our own insurance and companies who arrange such insurance.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Credit reference agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

 

2.8 Contact at a corporate entity to whom we provide services to or who refers work to KFH

This section will detail what personal information we collect about you and use if you are one of the following:

  • a contact at a corporate client to whom we provide residential sales and lettings services;
  • a contact at a corporate client to whom we provide professional services (survey, commercial and block management);
  • a contact a corporate business to whom we are handling relocations for their employees; or
  • a contact at a mortgage lender or broker, corporate client or an organisation who refers work to KFH.

What personal information will we collect?

  • Your name and contact information, including telephone number, postal address and email address.
  • Information about your job such as your job title.
  • Information which we have gathered from publically available sources such as internet search engines like Google and social media sites such as LinkedIn.
  • Information obtained through our use of cookies. You can find out more information about this in section 8.

What special categories of personal information will we collect?

We do not collect any special categories of personal information about you.

How will we collect your personal information? 

We will collect information directly from you when:

  • you visit our offices;
  • you complete documentation such as terms of business;
  • you use our website;
  • you request information about our services; and
  • you contact us by email, telephone and through other written and verbal communications.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":

  • We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
  • We need to use your personal information for a legitimate business purpose (e.g. to provide our services to a corporate client, to keep our corporate client updated, to keep business and accounting records, manage our business operations and to develop and to improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To communicate with you regarding the provision of services to the corporate client you work for and to resolve any complaints
  • We have a legitimate business purpose (to use your information to fulfil our contractual duties to our corporate client, to provide regular updates and to record and investigate complaints and ensure that future complaints are handled appropriately).
None
To discuss work referrals
  • We have a legitimate business purpose (to consider all work referrals and to liaise with you to gather more information)
None
Providing improved quality, training and security
  • We have a legitimate business purpose (to develop and improve the products and services we offer).
None

Complying with our legal or regulatory obligations.

  • We have a relevant legal or regulatory obligation.
None
Managing our business operations such as maintaining accounting records, analysis of financial results, statistical analysis, internal audit requirements, receiving professional advice (e.g. tax or legal advice) and facilitating payment of our services.
  • We have a relevant legal or regulatory obligation.
  • We have a legitimate business purpose (to effectively manage our business operations).
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None
Transferring or selling part of our business or re-organising our company structure.
  • We have a legitimate business purpose (to manage our business portfolio and re-organise our company).
  • We have a relevant legal or regulatory obligation.
None
To market our services.
  • We have a legitimate business purpose (to market our services).
  • We have your consent.
None

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other key contacts or individuals at your organisation.
  • Other third parties involved in the provision of our services such as landlords, tenants and leaseholders.
  • Other KFH Group companies.
  • Insurers who provide our insurance and companies who arrange such insurance.
  • Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  • Debt collection agencies.
  • Our third party service providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
  • Third parties who undertake analysis for the purposes of product improvement.
  • Selected third parties in connection with any sale, transfer or disposal of our business.

 

2.9 Users of the KFH websites

If you are a user of the website, this section will detail what personal information we collect about you and our uses of your personal information.

What personal information will we collect?

  • General information submitted via the website (including your requests to contact you by WhatsApp and your mobile number) and information relating to a complaint, for example where you request a service or leave a review at the ‘Tell us what you think’ section at https://www.kfh.co.uk/contact-us/tell-us-what-you-think.
  • Information obtained through our use of cookies. You can find more information about this in section 8.
  • Information submitted on the MyKFH portal to create property alerts and which may include your name, email address, customer type and any information submitted as part of the online chat.

What special categories of personal information will we collect?

We do not collect any of your special categories of personal information.

How will we collect your personal information?

We will collect your information directly from our website or from you when you submit a request on our website.

What will we use your personal information for?

We may use your personal information for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal ground” when we process your "personal information":

  • We need to use your personal information for a legitimate business purpose (e.g. to monitor the number of visitors and usage of our website, to follow up on enquiries and to provide marketing information to you). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
  • We have your consent

 

Purpose for processing Legal grounds for using your personal information Legal grounds for using your special categories of personal information
To market and promote our services
  • We have  a legitimate business interest (to promote  our services and good feedback)
None
To respond to requests for services.
  • We have a legitimate business interest (to follow up on enquiries and to provide information about our service offerings
None
Communicating with you on the online chat
  • We have a legitimate business purpose (to communicate with you on our online chat about our services).  
None
To respond to your request to contact you on WhatsApp and when contacting you, ensuring that we adhere to WhatsApp terms of use
  • We have your consent
None
Resolving any complaints that you might have
  • We have a legitimate business purpose (to contact you in order to investigate complaints and ensure that future complaints are handled appropriately).
None
To monitor the number of visitors and usage of our website.
  • We have a legitimate business reason (to monitor usage of our website).
None
Reviewing, assessing, tailoring and improving our service offerings
  • We have a legitimate business purpose (to develop and improve our services to ensure we provide high customer satisfaction).
None
Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems.
  • We have a legitimate business purpose (to ensure the integrity and security of our systems).
None

 

Who do we share your personal information with?

We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:

  • Other KFH Group companies.
  • Our third party service providers such as IT suppliers and website providers.
  • Third parties Stitch AI Ltd and Sendbee Inc. who enables us to communicate with you by WhatsApp.

 

3. Marketing activities

We will use your personal information to provide you with newsletters, property alerts and emails about the different services KFH can offer where it is part of the services we offer to you or where you have provided your consent for us to do so.

We will send out marketing communications via email post or other electronic means.

If you wish to opt out of marketing, you may do so by clicking on the “update your requirements” link on any marketing email communication or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us using the details set out in section 9 to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.

 

4. How long do we keep personal information for?

We will keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 2 above and to comply with our legal and regulatory obligations.

We have a detailed retention policy in place which governs how long we will hold different types of information for. The exact time period will depend on your relationship with us and the type of personal information we hold and the length of time between transactions in the industry has been taken into account when determining how long data is retained for, for example:

  • Where you are an individual to whom we provide our mortgage or assurance services, we will keep your personal information for 15 years from the end of our contractual relationship with you.
  • Where you are a non-financial services individual, for example a buyer or seller, landlord or tenant of a residential property with whom we assisted with the buying, selling or letting process, we will keep your personal information for a maximum of 15 years from the date of completion or the end date of the tenancy.

If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 9.

 

5. What is our approach to sending your personal information overseas?

Other than when we contact you by WhatsApp (and your personal information is shared with third party supplier Sendbee Inc. in the United States to facilitate such communications), we do not transfer or disclose your personal information to countries or third parties located outside of the European Economic Area ("EEA").

The personal information we collect about you will be stored and processed in the United Kingdom.  Should we need to transfer your personal information to any other country, we will take all reasonable measures to safeguard the transfer of your personal information in a manner that complies with data protection laws.

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 9. 

 

6. How do we protect your information?

KFH values your privacy and data security. We use third party services to help maintain the security and performance of our systems and sites. Email monitoring software and network traffic firewalls are also used. You can be assured that any personal information we gather about you through our sites, email, social media, telephone or other means will not be passed on to any third party or organisation except in the instances outlined above in section 2. Please also note that when we contact you by WhatsApp (as you have requested), all communications will be end to end encrypted.

We will never change our bank details during the course of a transaction. Always query emails supposedly from us where the sender’s email address does not match our domain kfh.co.uk, or where the format, style or content is not usual. We will always check when we receive an instruction to amend our record of a customer’s details.

If you receive something suspicious, please report it to our data protection officer using the details set out in section 9.

 

7. Your rights

Under data protection laws you have a number of rights in relation to the personal information that we hold about you which we set out below. These rights might not apply in every circumstance. You can exercise your rights by contacting us at any time using the details set out in section 9. We will not usually charge you in relation to a request.

Please note that although we take your rights seriously, there may be some circumstances where we cannot comply with your request such as where complying with it would mean that we couldn't comply with our own legal or regulatory requirements. In these instances we will let you know why we cannot comply with your request.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

Where you would like to do so, you can submit requests by email to clientliaison@kfh.co.uk or by contacting us using the details set out in section 9.

The right to rectification

We always take care to ensure that the information we hold about you is accurate and where necessary up to date. If you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, you can contact us and ask us to update or amend it.

The right to restriction of processing

In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information. 

The right to withdraw your consent

Where we rely on your consent in order to process your personal information, you have the right to withdraw such consent to further use of your personal information.

The right to erasure

This is sometimes known as the 'right to be forgotten'. It entitles you, in certain circumstances, to request deletion of your personal information. For example, where we no longer need your personal information for the original purpose we collected it for or where you have exercised your right to withdrawn consent.

Whilst we will assess every request, there are other factors that will need to be taken into consideration. For example we may be unable to erase your information as you have requested because we have a regulatory obligation to keep it.

The right to object to direct marketing

You have control over the extent to which we market to you and you have the right to request that we stop sending you marketing messages at any time.  You can do this either by clicking on the "unsubscribe" button or “update your requirements” link in any email that we send to you or by contacting us using the details set out in section 9.

Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service related communications where necessary.

The right to object to processing

In certain cases you have the right to object to our processing, This arises in relation to where we process your personal information based on our legitimate business interests. Where we do so, you can object to such processing, unless our purpose outweighs any prejudice to your privacy rights.

The right to data portability

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

Rights related to automated decision-making

We do not carry out any automated decision making. If this changes in the future, we will provide you with an updated notice setting out our decision making process.

The right to make a complaint with the Regulator

You have a right to complain to the Information Commissioner's Office (ICO) or any other local Data Protection Regulator if you believe that we have breached data protection laws when using your personal information.

You can visit the ICO's website at https://ico.org.uk/ for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.

 

8. Cookies

Technologies such as: cookies, beacons, tags and scripts are used by KFH and our partners, affiliates, analytics or service providers. These technologies are used in analysing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Cookies are very small text files that are stored on your computer when you visit some websites. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use cookies to help identify your computer so we can tailor your user experience.

You can disable any cookies already stored on your computer, but these may stop our website from functioning properly. Please visit www.allaboutcookies.org if you would like more information, including how to see what cookies have been stored in your web browser and how to manage and delete them.

Should you wish to opt out of Google Analytic tracking across all websites please visit http://tools.google.com/dlpage/gaoptout.

Calls made to phone numbers on our website and marketing materials may be recorded for training purposes.

This website occasionally uses third party tools such as HotJar to understand what users interact with using surveys, screen recording and by visually representing clicks, taps and scrolling behaviour. These tools are constructed in a way to protect you and your information, but if you do wish to opt out by visiting this website: https://www.hotjar.com/legal/compliance/opt-out.

Log File Information: Log file information is automatically reported by your browser each time you access a web page on our Service. When you access the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. We do not link this automatically-collected data to personally identifiable information.

The table below details the cookies we use across our website:

Purpose Cookie lifetime Cookie name
Remembers a user session ID and holds details of last search criteria/paging/context Until browser is closed ASP.NET_SessionId
Acceptance of cookies 12 months Kfh-cookie-accept
Authentication cookie for MyKFH. Persists user’s logged in state once logged into MyKFH 12 months MyKfh
Stores the My KFH username for personalisation 12 months MyKfhName
Monetate cookies run A/B testing in order to develop and improve the website for future visitors. This cookie stores a visitor's unique Monetate identifier using a combination of a timestamp and random number. See Monetate website for more information: https://monetate.com/platform-privacy-policy/ 60 months m.tv
Google Analytics cookies anonymously collect information about how visitors use our site. We use this information to develop and improve the website for future visitors. No personal information is collected or stored. 24 months _utma
Google Analytics cookie as above 30 minutes _utmb
Google Analytics cookie as above Until browser is closed _utmc
Google Analytics cookie as above 6 months _utmz
Google Analytics cookie as above 30 minutes _utmv

 

9. Contacting us

If you would like further information about any of the matters in this notice or if have any other questions about how we collect, store or use your personal information, you may contact our Data Protection Officer by emailing clientliaison@kfh.co.uk, telephoning us at 020 8739 2000  or writing to:

Data Protection Officer

Kinleigh Folkard & Hayward

KFH House

5 Compton Road

London

SW19 7QA

 

10. Updates to this notice

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice and you can check our website here periodically to view it.

This notice was last updated July 2020.

 

 

 

 

 

 

 

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