Privacy Policy

EPROPERTYS A&P LTD - PRIVACY NOTICE 

1 ABOUT THIS NOTICE 

1.1 ePropertys A&P Ltd is committed to protecting the privacy and security of your personal information.  This privacy notice describes how we collect and use personal information about you in accordance with data protection law.  Please read it carefully. 

1.2 Data protection law says that the personal information we hold about you must be: 

Used lawfully, fairly and in a transparent way. 

Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 

Relevant to the purposes we have told you about and limited only to those purposes. 

Accurate and kept up to date. 

Kept only as long as necessary for the purposes we have told you about. 

Kept securely 

1.3 If you have any questions about this notice or how we collect and use personal information about you please contact us info@epropertys.com. 

2 INFORMATION ABOUT US 

2.1 We are ePropertys A&P Ltd.  Our registered office is at 292-294 Hale Lane, Edgware, London, HA8 8NP and our registered company number is 12797419. 

2.2 If you have any questions, our contact details are: 

2.2.1 info@epropertys.com 

2.2.2 0330 1333 718 

2.2.3 292-294 Hale Lane, Edgware, London, HA8 8NP 

3 DATA WE COLLECT ABOUT YOU 

3.1 We will collect personal information about you in the performance of our business operations. The type of the personal information collected will depend on the nature of our relationship with you.  

Landlord - a landlord appointing us to market the letting of their property and/or manage the property; 

Tenant - a prospective or actual tenant of one of the properties we are appointed to let or manage for a landlord. 

Contractors – a contractor who has an entry on our website platform to allow landlords to contact them regarding carrying out potential maintenance and repairs on the landlord’s property. 

Other Parties - about other parties, for example a tenant’s guarantor. 

3.2 The table below sets out the types of personal information we will collect. 

  Data  Description 
(a)  Personal Details  includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender. This would apply in particular to Tenants and Landlords 
(b)  Contact Information  includes billing address, delivery address, email address and telephone numbers. This would apply in particular to Tenants, Landlords and Contractors. 
(c)  Identification Documents  Identification documents required by money laundering regulations, including passport details, driving licence details and utility bills. This would only apply to Tenants and Landlords. 
(d)  Financial Information  includes bank account and payment card details. This would apply in particular to Tenants and Landlords. 
(e)  Transaction Information   includes details about payments to and from you and other details of products and services you have purchased from us. This would apply in particular to Tenants and Landlords. 
(f)  Website Data   includes information on use of our website and details of internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. This would apply to all users of our website. 
(g)  Profile Information  includes your username and password, feedback and survey responses. This would only apply to registered users of the ePropertys platform available at https://epropertys.com/. 
(h)  Marketing  includes preferences in receiving marketing from us and our third parties and your communication preferences. This would apply in particular to Tenants and Landlords. 
(i)  Enquiry Information  where you engage in communication information, which may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation. For example, communications by email, telephone, post, SMS or via our website) between you and us, will include personal information (such as names and contact details) in that communication. 
(j)  Social Media  if we engage with you on social media, we may use information you share with us (including your social media handle or profile) or which is available from your account to inform our correspondence with you. 
(h)  Contracts  where you sign a contract related to the services we provide. This will include landlord’s terms of business with us, tenant’s assured shorthold tenancy agreements and guarantor’s tenant guarantees. 

4 HOW WE USE YOUR PERSONAL DATA 

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

Where we need to perform the contract we are about to enter into or have entered into with you. 

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

Where we need to comply with a legal obligation. 

4.2 Please see our “Glossary” [INSERT LINK] to find out more about the types of lawful basis that we will rely on to process your personal data. 

4.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. Please see “Marketing” section. 

4.4 We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

5 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

5.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

5.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity  Type of data  Lawful basis for processing 
Registration - register you as a new Landlord or Tenant 

(a) Personal Details 

(b) Contact Information 

(i) Enquiry Information 

Contract Performance 
Selection and References – selection of Tenant and obtaining references, undertaking credit reference checks and criminal convictions check before tenancy is confirmed 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(i) Enquiry Information 

See section on “Special Categories” of data below. 

Consent 

Legitimate Interests - to fulfil our obligations to Landlord and to protect our commercial interests. 

Identification - undertaking tenancy or landlord identification checks  (c) Identification Documents  Legal Obligation 
Contracts – entering into contracts with Landlords and obtaining Tenant’s tenancy agreements and guarantor’s tenant guarantee agreements. 

(a) Personal Details 

(b) Contact Information 

(h) Contracts 

Contract Performance 
Rent Collection  collecting rent, fees and charges from Tenant 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(e) Transaction Information 

Contract Performance 

Legitimate Interests - to recover sums due to Landlord 

Repayments - to Tenants, including deposit and rent overpayments 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(e) Transaction Information 

Contract Performance 

Legitimate Interests - to recover sums due to Landlord 

Fees - collection of fees and charges due from Landlord  

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(e) Transaction Information 

Contract Performance 

Legitimate Interests - to recover sums due to us 

Rent Distribution - payment of rent to Landlord  

(d) Financial Information 

(e) Transaction Information 

Contract Performance 

 

Tenancy Management - contacting Tenant to manage tenancy, for example organising maintenance, gas safety checks and tenancy renewals 

(a) Personal Details 

(b) Contact Information 

(g) Profile Information 

Contract Performance 

Legitimate Interests - to protect assets managed by us 

Legal Obligation 

Tenancy Management - contacting Landlord to manage tenancy, for example organising maintenance, gas safety checks and tenancy renewals 

(a) Personal Details 

(b) Contact Information 

(g) Profile Information 

Contract Performance 

Legal Obligation 

Tenancy Management – contacting guarantors to arrange Tenant guarantees for a property. 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(h) Contracts 

Contract Performance 

Legitimate Interests - to protect assets managed by us 

Contractors – providing your contact information on our platform so Landlords interested in having maintenance work and repairs undertaken on their property. 

(a) Personal Details 

(b) Contact Information 

Contract Performance 

Consent 

Complaints – handle any complaints regarding our services or Tenants/Landlords 

(a) Personal Details 

(b) Contact Information 

(i) Enquiry Information 

Contract Performance 

Legal Obligation 

Legitimate Interests - to protect assets managed by us 

Arrears / Notices – pursue or serve notices in relation to outstanding rent or fees. 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

(e) Transaction Information 

Legitimate Interests - to fulfil our obligations to Landlord and to protect our commercial interests. 
Surveys – asking you to leave a review or take a survey 

(a) Personal Details 

(b) Contact Information 

(g) Profile 

(l) Marketing 

Contract performance 

Legitimate interests - to study how customers use our products/services 

Prize Draws - enable you to partake in a prize draw or competitions 

(a) Personal Details 

(b) Contact Information 

(g) Profile 

(l) Marketing 

Legitimate interests - to develop them and grow our business 
Website Maintenance - to administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Personal Details 

(b) Contact Information 

(f) Website Data 

(g) Profile 

Legitimate Interests - for running our business, provision of administration and IT services, network security, to prevent fraud 

Legal Obligation 

Data Analytics - to use data analytics to improve our website, products/services, marketing, customer relationships and experiences 

(f) Website Data 

(g) Profile 

Legitimate Interests - to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 

6 MARKETING 

6.1 We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in. 

6.2 You always have the right to "opt out" of receiving our marketing.  You can exercise the right at any time by contacting us info@epropertys.com.  If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails.  If you "opt-out" of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing.  We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don't include direct marketing. 

6.3 For individuals. We may use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential Tenants and Landlords (including, in particular, if we collected them as part of a letting in relation to you or a negotiation with you about a letting). Otherwise (in particular if you are not a Tenant or Landlord and we haven’t discussed a sale with you) we will only send you marketing emails or texts with your consent. 

6.4 For businesses. If you are a company or LLP (or are acting in a professional capacity as part of one) we use your contact details as necessary for our legitimate interests in marketing to you (by various channels) and maintaining a list of potential customers. 

6.5 Third-party marketing. We never share your name or contact details with third parties for marketing purposes unless we have your "opt-in" consent to share your details with a specific third party for them to send you marketing. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. 

6.6 We retain your details on our marketing list until you "opt-out" at which point we add you to our suppression list.  We keep that suppression list indefinitely to comply with our legal obligations to ensure we don't accidentally send you any more marketing. 

7 WEBSITE INFORMATION 

7.1 We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools.  This may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access a website.  We use this as necessary for our legitimate interests in administering and improving our website and its content, to ensure it operates effectively and securely, and to develop our business and inform our marketing strategy.  We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors) which is not personal information about you. 

7.2 Sharing or Like buttons. If you click a “share” or “like” or equivalent social media button on our website, the relevant social media platform may be a joint controller with us in relation to information that is sent to them about you regarding your clicking of that button (which may include the types of information which we collect about you as part of your visit to our website described above). Any information sent to a social media platform is used by them according to their privacy policies, and they will be solely responsible for that use and primarily responsible for providing you with information about any joint processing and enabling you to exercise your rights under data protection law. For more information on the responsibilities of social media platforms and us in relation to social media buttons on our website, please see the privacy notice of the relevant social media platforms. 

7.3 For detailed information on the cookies on our site and the purposes which they are used for see our Cookie Notice https://epropertys.com/cookies_policy. 

7.4 We keep this website information about you for up to six months from when it is collected or the relevant cookie expires. 

7.5 Third party websites. Our website may, from time to time, contain links to third party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy notice of every website you visit. 

8 PHOTOS, CONTENT AND PROMOTIONAL MATERIAL 

8.1 This is information about you which you provide to us (whether through our website or otherwise), or images or recordings of you which you allow us (or someone on our behalf) to take (including at our premises or events), for publication or display.  This may include reviews, comments, testimonials, photographs (including stock photos and advertising material) and videos. 

8.2 We may display and publish this content (and, if relevant, attribute it to you) on our platforms as necessary for our legitimate interests in providing content and for promotional purposes (or, in some circumstances, because you have specifically consented to us doing this).  This information is kept and published or displayed by us for as long as we consider it relevant for those purposes.  You can ask us to remove or delete your content at any time (subject to any agreements about our right to use it) by contacting us.  If we are displaying or publishing the information based on your consent, you have the right to withdraw that consent at any time. 

9 PROFESSIONAL INFORMATION 

9.1 If you work for one of our Landlords or Tenants, the information we collect about you may include your contact information, details of your employment and our relationship with you.  This information may be collected directly from you, or provided by your organisation.  Your organisation should have informed you that your information would be provided to us, and directed you to this policy.  We use this as necessary for our legitimate interests in managing our relationship with your organisation.  If we have a business relationship with you or your organisation, we may receive information about you from your organisation. 

10 INFORMATION COLLECTED AT OUR PREMISES 

We are a purely digital estate agency and do not have physical premises so no information will be collected this way. 

11 EMPLOYMENT (APPLICATIONS, REFEREES AND EMERGENCY CONTACTS) 

11.1 We will collect and hold information on job applicants (including applications for work experience or internships), including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.  We may also collect information about your professional history which you make available on LinkedIn, or which are on your employer's website. 

11.2 We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.  Where you voluntarily provide us with special categories of data, such as information about your race, health or sexuality, we will store this as part of your application on the basis that you have decided to make it public to us for this purpose, and to ensure that our record of your application is accurate so we can comply with (and demonstrate our compliance with) our obligations under employment law. 

11.3 If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice.  If you currently work for us, or used to work for us, you can request a copy of this from us.  If you are not successful in your application, your information will be held for up to six months after the relevant round of recruitment has finished. We will, however, not contact you about future opportunities during or after this period unless you have provided us with consent to do so during the recruitment process. 

11.4 You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully.  If you have not provided all of this information, we may contact you to ask for it.  If you do not wish to provide this information, we may not be able to properly consider your application. 

11.5 If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant.  We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights.  Your information will be kept alongside the applicant's information. 

11.6 If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that member of staff.  We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that member of staff, and for our legitimate interests in administering our relationship with that worker.  Your information will be kept until it is updated by that member of staff, or we no longer need to contact them after they have stopped working for us. 

12 LEGAL CLAIMS 

Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers.  How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim. 

13 SPECIAL CATEGORIES OF DATA 

13.1 Other than as set out in this notice, we do not collect any "special categories" of more sensitive personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, as well as information about criminal convictions and offences). 

13.2 We may collect and use "special categories" about criminal convictions and offences in relation to Tenants when undertaking client identification and reference checks as part of our reference checks in the tenancy set-up process. We will obtain your consent for this; 

13.2 Where we collect "special categories" of particularly sensitive personal information this information requires higher levels of protection and by law we need to have further justification for collecting, storing and using this type of personal information.  We may process special categories of personal information in the following circumstances: 

13.3.1 In limited circumstances, with your explicit written consent. 

13.3.2 Where it is needed in the public interest. 

13.3.3 Where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent. 

13.3.4 Where you have already clearly made the information public. 

14 AUTOMATED DECISION MAKING 

14.1 We do not undertake any automated decision making (i.e. without human involvement). This includes not making automated decisions regarding the Tenants selected for properties we manage, Landlords we will accept or potential employees we may interview. 

14.2 We do not undertake automated decision making but will use tools to inform our human decisions. For example, undertaking credit checks and references on potential Tenants. 

15 INFORMATION WE RECEIVE FROM THIRD PARTIES 

15.1 We may also receive information about you from the following sources: 

15.1.1 Our service providers.  We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out in this privacy notice. 

15.1.2 Businesses we have bought.  If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice.  If we are reviewing whether to acquire a business, or substantially all of its assets, which holds your personal data (whether you are a customer or employee of that business or otherwise) we may receive limited personal data about you from that business or professional advisors involved in the transaction, as necessary for our legitimate interests in making decisions about that acquisition.  If we do not acquire that business, any information we receive about you will be deleted as soon as practicable following the decision not to acquire. 

15.1.3 Publicly available sources.  If relevant as part of our relationship with you, we may obtain information from publicly available sources such as Companies House or LinkedIn. 

15.1.4 Credit information.  We may also collect credit information on you from third party reference agencies. We will obtain your consent before undertaking such credit reference checks. 

16 SHARING YOUR INFORMATION 

16.1 We never sell your data to third parties. But we may need to share your information with third parties, including third-party service providers and other entities in our group.  Third parties are required to respect the security of your personal information and to treat it in accordance with the law.   

16.2 Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our Tenants and Landlords, or others or where we have another legitimate interest in doing so.  This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

16.3 Which third-party service providers process your personal information? We may need to share your personal information with third-party service providers (including contractors and designated agents) so that they can carry out their services. We may use third-party service providers in relation to the following types of activity: ID checks, anti-money laundering checks, deposit protection bodies, inventory providers, payment processing. A table of the relevant third-party service providers is set out below: 

WHOSE DATA   THIRD PARTY  REASON   DATA SHARED 
Tenant/Landlord  Other party to your transaction  Allow the transaction to proceed. 

(b) Contact Information. 

(h) Contracts 

Tenant  Reference providers  Obtain a reference for you as a potential tenant. 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

Tenant  ID Check providers  Check your right to rent in the UK 

(a) Personal Details 

(b) Contact Information 

(c) Identification Documents 

Landlord  Anti-Money Laundering checking providers  Enable us to perform Anti-Money Laundering checks 

(a) Personal Details 

(b) Contact Information 

(c) Identification Documents 

Landlord  HM Land Registry  Verify ownership of your property  (b) Contact Information 
Landlord  Energy Helpline/Water Suppliers/Local Authorities  Switch your energy supply and register you for water supply and council tax if you opt for this service 

(a) Personal Details 

(b) Contact Information 

(d) Financial Information 

Landlord/Tenant  Inventory providers  Carry out inventory checks and report on the condition of property  (b) Contact Information 
Landlord/Tenant  Maintenance Contractors and Out of Hours service providers  Arrange and carry out essential maintenance and emergency repairs to property when necessary  (b) Contact Information 
Landlord/Tenant  Deposit Protection Service  Keep deposit money safe 

(b) Contact Information 

(d) Financial Information 

Landlord/Tenant  Guarantor  Obtaining a Tenant guarantee in relation to a tenancy. 

(a) Personal Details 

(b) Contact Information 

(c) Contracts 

Guarantor  Landlord/Tenant  Obtaining a Tenant guarantee in relation to a tenancy. 

(a) Personal Details 

(b) Contact Information 

(c) Contracts 

Landlord/Tenant  Go Cardless  Arranging payment of (a) Tenant’s rent to Landlord (b) payment of our fees by Landlord  

(a) Personal Details 

(b) Contact Information 

Landlord/Tenant 

/Guarantor  

Docusign  Arranging signature of tenancy and guarantee documentation. 

(a) Personal Details 

(b) Contact Information 

(c) Contracts 

16.4 How secure is your information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.  Where third parties process your personal information on our behalf as "data processors" they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure. 

16.5 What about other third parties? We may share your personal information with other third parties, for example with potential buyers and professional advisers in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for.  We may also need to share your personal information with a regulator or to otherwise comply with the law. 

17 WHERE WE STORE YOUR INFORMATION 

17.1 We are based in London and our main data centre is located in the UK.  However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU.  It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers. 

17.2 We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice. 

17.3 Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an "adequacy decision" in place, meaning the EU considers them to have an adequate data protection regime in place.  These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

17.4 If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required.  To obtain more details of these safeguards, please contact us. 

18 DATA SECURITY 

18.1 As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

18.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary. 

19 HOW LONG WILL WE KEEP YOUR INFORMATION FOR? 

19.1 We have set out below indications of how long we generally keep your information.  In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

19.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

19.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. 

20 YOUR RIGHTS 

20.1 Data protection law gives you a number of rights when it comes to personal information we hold about you.  The key rights are set out below.  More information about your rights can be obtained from the Information Commissioner's Office (ICO) at https://ico.org.uk/.  

20.2 Under certain circumstances, by law you have the right to: 

20.2.1 Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights.  This is why we are providing you with the information in this notice.  If you require any further information about how we use your personal information, please let us know. 

20.2.2 Request access to your personal information (commonly known as a "data subject access request").  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

20.2.3 Request correction of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected. 

20.2.4 Request erasure of your personal information.  This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations).  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

20.2.5 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim).  You also have the right to object where we are processing your personal information for direct marketing purposes. 

20.2.6 Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

20.2.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means. 

20.2.8 Withdraw consent.  In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so. 

20.2.9 Lodge a complaint.  If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO). 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us at info@epropertys.com. 

20.3 No fee usually required.  You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.  Alternatively, we may refuse to comply with the request in such circumstances. 

20.4 What we may need from you.  We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights).  This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified. 

20.5 Timescale.  Please consider your request responsibly before submitting it.  We will respond to your request as soon as we can.  Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know. 

21 GLOSSARY 

21.1 When we use the term lawful basis we mean one of the following reasons: 

“Legitimate Interest”  the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 
“Contract Performance”  processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 
“Legal Obligation”  processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 

22 CHANGES TO THIS PRIVACY NOTICE 

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise.  Please check back frequently to see any updates or changes to our privacy notice. 

Version: March 2021 

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