Privacy notice

This privacy notice sets out how Keepmoat Homes uses and protects any personal information shared with us via any channel of communication, including but not limited to this website, or other channels such as: email, telephone, in person at our developments, direct mail, social media, SMS, newsletters/blogs, competitions, refer a friend, webchat or other Keepmoat Homes’ websites.

We are committed to protecting and respecting privacy and ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and how to contact us and supervisory authorities in the event of a complaint.

When, in this notice, we refer to personal information we mean any information that could potentially identify a specific individual.

Index

1. Who we are
2. What Information we collect about you
3. What we do with the personal information that we collect
4. Who we share your personal information with
5. How long we will keep your personal data for
6. Keeping your personal information secure
7. The legal basis we rely on for processing your personal data
8. Where in the world we will hold your personal information
9. Your rights in relation to your personal information
10. Complaints

Who we are

When, in this notice, we refer to Keepmoat Homes we mean Keepmoat Homes Limited whose registered address is at The Waterfront, Lakeside Boulevard, Doncaster, DN4 5PL and which is registered under company number 02207338. Keepmoat is the data controller in respect of your personal information and is responsible for ensuring that the personal information we collect is processed in accordance with the General Data Protection Regulation.

If you have any questions or are unsure about anything contained in this privacy notice, please let us know by contacting our Data Protection Governance Group at:

Keepmoat Homes Limited

The Waterfront

Lakeside Boulevard

Doncaster

DN4 5PL

Or email [email protected]

What information we collect about you

In the course of our interactions with you we may collect some (but not necessarily all) of the following information either directly or indirectly, this includes but is not limited to personal information you provide to us.

Personal information collected by us, whether obtained from you directly or indirectly, during initial enquiries:

• Your name
• Your contact details such as your e-mail address, telephone number, and residential address including postcode
• Demographic information including age bracket, occupation, household and employment type

If personal information is collected by us indirectly, the categories of third parties from whom we collect that personal information are:

• Marketing Platforms (including where you provide details about our properties to Rightmove, Zoopla, New Homes for Sale)
• Advertising Platforms (including Google, Yahoo, Zapp, Bing however these platforms will direct you to our website)
• Social Media Platforms (including Facebook, Twitter)
• Marketing list data providers (including Experian)
• Contractors Health & Safety Assessment Scheme (Contractors only)
• your solicitor, estate agent and Independent Financial Adviser where you have agreed that they can share personal information with us

Personal information we collect automatically:

• Information about how you navigate and use our website such as the search terms you use, the pages you visit, the amount of time you spend on the website
• Information about the device you use to access the website such as device type, screen resolution and location
• Call recordings
• Static or moving images from CCTV and
• Unmanned Aerial Systems ("UAS")(drones)

Other information we may collect from you throughout your journey with Keepmoat Homes includes (but is not limited to):

• Contact preferences such as preferred contact method and time
• Property search preferences such as number of bedrooms, location and price range
• Development sites and properties you have indicated an interest in
• Information about your circumstances, such as whether you are a first or second-time buyer, the reason for your move, your income bracket and means of financing your new home
• Property reservation details
• Proof of identification
• Details of your solicitor, estate agent and Independent Financial Adviser;
• Details of your current home e.g. sales status and further information about the property  if you are using Easy Move;
• Details of your mortgage (if you require one)
• Details of extras you require and choices you have made in relation to your property
• Bank and credit/debit card details
• Proof of the source of your funds and wealth (including but limited to bank statements)
• House purchase completion date
• Information you share with our customer care teams such as details of your property
• Information you provide when completing surveys which we may ask you to complete to help improve our customer experience and as part of business reporting, such as whether you would recommend Keepmoat to a friend and where you heard about us
• VAT Registration, proof of insurance and professional certification (Contractors only)
• Details of any reported on-site incident
• Insurance details

What we do with the personal information we collect

We will use the personal information we collect about you in the following ways:

• Providing products and services to you, including but not limited to:
  • engagement with you as a potential customer of Keepmoat Homes;
  • for the fulfilment of our contractual obligations to you during the sales process; and
  • providing care, support and information to you both during and after the sales process
• Responding to your enquiries
• Improving the customer support we provide
• Personalising our interactions with you
• Processing payments made by you to Keepmoat Homes or vice versa
• With your consent or if we have a legitimate interest in doing so, contacting you for marketing and promotional purposes
• Complying with our legal obligations to you and third parties
• Complying with our legal obligations regarding anti-money laundering
• Facilitating our internal record keeping and auditing
• Conducting reports and analytics
• Facilitating any buying or selling of Keepmoat’s business asset
• To promote Keepmoat's developments by the use of moving images
• For surveying and mapping Keepmoat's developments through the construction stage

Who we share your personal information with

We will not pass your personal information to anyone outside our group, except to carefully selected third parties, for example where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose.  Where necessary, your personal information may be shared with third parties in order to comply with our anti-money laundering obligations. For example, your identification may be shared with third parties for verification. Who we share your personal information with is set out in the table at Figure 6.0, below.

We will not disclose your personal information to any other third party without your consent unless we are satisfied that they are legally entitled to access your personal information.

How long we will keep your personal information for

We will keep your personal information for as long as we need it to provide the services and products you request from us. We may also keep it to comply with our legal obligations, to resolve complaints and to enforce our rights.  As a result, the length of time that we keep your information for will vary depending on the purposes for which we have it. In any event, we will review what information we need on an ongoing basis and will only retain it for the minimum amount of time that we need it for.

In the event that you provide us with personal information to allow us to fulfil any anti-money laundering obligations, we will retain such information for five years. This is to fulfil our legal obligations.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We are working towards being accredited as meeting the UK Government’s Cyber Essentials Plus standard.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data breach where we are legally required to do so.

The legal basis we rely on to process your personal information

Data protection law sets out a number of conditions which organisations can rely on in order to lawfully handle personal information.

The reasons for processing that we rely on are as follows: -

i. Legitimate interests

The law permits us to handle your personal information where necessary in our legitimate interests provided that this isn’t outweighed by your interests. We will ensure that when relying on legitimate interest as the legal basis for processing there will be a minimal impact on your privacy rights. Many of the purposes for handling your personal information, described above, fall into this category as they are essential activities which enable us to run our business efficiently and effectively for example, enabling us to use third party service providers, to monitor, review and improve the services we provide to you and your experience when you visit our Website and to help us ensure that we communicate with you about the things that are most likely to be of interest to you. We may, if necessary, also use your information to defend our legal rights or to obtain legal advice and to manage any complaint that you might have. We ensure that your rights and interests are protected when we do this.

ii. Performance of a contract

Where you transact with us to buy a new home, we will use your personal information so that we can fulfil our part of the contract e.g. to deliver the product to you, to take payment and to manage this process and perform our obligations under your home buyer warranty.

iii. Performance of legal obligations

We will, if required by law, disclose your personal information for example in response to a court order or to comply with anti-money laundering obligations. We will disclose your personal information if requested by a law enforcement agency or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, money laundering, situations involving potential threats to the physical safety of any person, non-compliance with of our terms and conditions, or as otherwise permitted or required by law and consistent with legal requirements.

Figure 6.0

We may share the following personal data with the following categories of third parties under the legal basis condition and for the reasons identified:

Category of 3rd Party - Legal Basis and Reason for sharing data	Name	Address	Contact details	Bank details	Other data we may share
Marketing Agencies and Providers Legitimate Interest - For marketing and reporting purposes, as well as to provide products, services and information to our customers and prospective customers	Yes	Yes	Yes	No	Contact preferences Reservation information e.g. plot number, price agreed. Moving images (obtained from UAS (drones))
Survey Tool Providers Legitimate Interest - For maintaining and enhancing the company's products and services	Yes	Yes	Yes	No	Contact preferences
Information Services Providers, such as Experian Legitimate Interest and Performance of legal obligations - For data enrichment and cleansing and complying with our legal obligations	Yes	Yes	Yes	No	No
Keepmoat’s supply chain including tradespeople & sub-contractors Performance of a Contract & Legitimate Interests - For providing products & services to our customers, and to confirm with obligations under the NHBC warranty	Yes	Yes	Yes	No	Information shared with Customer Care teams regarding property Contact Preferences Moving images (obtained from UAS (drones))
National Housebuilding Council, Home Builders Federation and the Local Authority Building Control Legitimate Interest, Performance of Legal Obligations & Performance of a Contract - For providing products & services to our customers and complying with our legal obligations	Yes	Yes	Yes	No	Sale Status House Purchase Completion Date
Independent Financial Advisors Performance of a Contract, Legitimate Interest & Performance of Legal Obligations - For providing products & services to our customers and potential customers and conducting legitimate credit reference checks	Yes	Yes	Yes	No	Property reservation details Personal & Purchase circumstances
Solicitors, other legal advisors and experts Legitimate Interests, Performance of a Contract & Performance of Legal Obligation - For providing products & services to our customers and potential customers and legal obligation for prevention of fraud	Yes	Yes	Yes	No	Property reservation details Proof of identification (when acting as a Sales Agent only) Incident details Information shared with Customer Care teams regarding property
Third party verifiers Legitimate Interests, Performance of a Contract & Performance of Legal Obligation - For providing products & services to our customers and potential customers and legal obligation for the verification of identification	Yes	Yes	Yes	No	Name, address, date of birth, passport number, drivers licence number
Managing Agents & Companies Performance of a Contract & Legitimate Interests - For providing products & services to our customers and to enable managing agents to correctly identify customers for the purpose of providing products and services	Yes	Yes	Yes	No	No
Shared Ownership Providers Performance of a Contract - For providing products & services to our customers and to enable partners to correctly identify customers for the purpose of providing services	Yes	Yes	Yes	No	House Purchase details
Partners including joint venture partners, housing associations & authorities Performance of a Contract - For providing products & services	Yes	Yes	Yes	No	House Purchase details
Estate Agents, Easy Move and Help to Buy Scheme Providers Legitimate Interest & Performance of a Contract - For providing products & services and complying with legal obligations. For providing products & services to our customers and to enable third parties to correctly identify customers for the purpose of providing services and to monitor the performance of the agents	Yes	Yes	Yes	No	Property reservation details
Utility Companies Legitimate interests - To enable utilities companies to correctly identify customers for providing products and services	Yes	Yes	Yes	No	House Purchase Completion Date Meter Readings
Local Authorities Legitimate interests - To enable the local authority to correctly identify customers for council tax purposes	Yes	Yes	Yes	No	House Purchase Completion Date
Council of Mortgage Lenders Legitimate Interest, Legal Obligation & Performance of a Contract - For providing products & services and complying with legal obligations in the sale of homes	Yes	Yes	Yes	No	Property reservation details
External third parties requesting personal data in the course of a contract or in the legitimate course of business, such as sales documentation relating to historic sales, or historic shared equity loan book Performance of a Contract & Legal Obligation - For providing products & services and complying with legal obligations	Yes	Yes	Yes	No	Any non-financial information legitimately required by the data request
Auditors Legal Obligation - For legally required annual financial audit	Yes	Yes	Yes	Yes	Related collected data
Financial Institutions Performance of a Contract - For business account management	Yes	Yes	No	Yes	Payment details
Purchasers and potential purchasers of any freehold reversionary interest in a development that is owned by Keepmoat Homes Limited Performance of a Contract - In performance of a contract, or fulfilment of our future obligation under a contract	Yes	Yes	Yes	No	No
Data Archive Service Providers Legitimate Interest - For the secure storage of personal information	Yes	Yes	Yes	Yes	Related collected data
Company’s Insurers & 3rd Party Insurers Legitimate Interest & Legal Obligations - For claim management and auditing purposes	Yes	Yes	Yes	Yes	Incident details Insurance details
National Officials including HMRC, Health & Safety Executive, Law Enforcement Agencies & the Environment Agency (and other regulatory bodies) Legitimate Interest & Legal Obligations - For compliance with legal obligations and the provision of safe & secure premises	Yes	Yes	Yes	No	Incident details CCTV/UAS (drone) footage Electronic security records
Keepmoat Ltd, its subsidiaries & holdings Legitimate Interest & Performance of Contract - For provision and completion of essential business services	Yes	Yes	Yes	No	Any non-financial information legitimately required
Contact centre providers Legitimate Interest - For providing services and call recording	Yes	Yes	Yes	No	No

 

Where in the world we will hold your personal information

We will not transfer your personal data outside the EEA unless such transfer is compliant with data protection legislation, however, your personal information may occasionally be processed and held by third parties outside the European Economic Area (EEA).

Whereas in the EU, we implement a high standard of data protection law, some parts of the world do not implement such stringent laws. As a result, if we do send personal information

outside of the EEA we will endeavour to ensure that appropriate safeguards are in place so that it is protected in accordance with the GDPR European data protection law. Such safeguards may include: -

• Sending personal information only to countries that European Authorities have indicated have adequate data protection laws in place; and
• Putting in place contracts with the recipient containing terms which the European Authorities have approved as providing adequate protection; organisations which are members of a scheme which has been approved by European Authorities as achieving adequate protection e.g. Privacy Shield.

Cookies on our Website

Cookies are small text files stored on your computer (or mobile device) by web pages as you visit them. Cookies are not programs and cannot harm your computer.

The Keepmoat website(s) use Cookies to enhance your experience of our website(s) and to help us analyse data about how visitors are using our website(s). We may also use Cookies to display relevant adverts to you when you visit other selected websites. 

Please refer to our separate Cookie Policy.

Email Tracking

We use email tracking as part of our marketing activity to determine whether or not the email has been opened and if it was responded to.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst viewing such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information
• access to your personal information and to certain other supplementary information that this privacy notice is already designed to address
• require us to correct any mistakes in your information which we hold
• you require us to anonymise your personal information so that you can no longer be identified from that personal information
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

We will keep the personal data we store about you accurate and up to date so far as our technologies and processes permit.

If you would like to exercise any of our rights listed above you can do so at any time using the following methods:

• Writing to us at any time, at: c/o Data Protection Governance Group, Keepmoat Homes Limited, The Waterfront, Lakeside Boulevard, Doncaster DN4 5PL
• Clicking on the unsubscribe link at the bottom of promotional e-mails
• Phoning the telephone number included on any postal correspondence
• Using the opt out code on any promotional SMS communication

For further information on each of those rights, including the circumstances in which they apply, see the guidance issued by the Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

Complaints

If you have any questions or concerns about how Keepmoat Homes Limited handles your personal information, you can write to us at:

c/o Data Protection Governance Group

Keepmoat Homes Limited The Waterfront Lakeside Boulevard Doncaster DN4 5PL

You also have the right to raise any complaint you may have with the ICO. You can do this by contacting them: -

• By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow Cheshire, SK9 5AF
• By phone: 0303 123 1113
• By email: [email protected]

Your statutory rights are not affected by anything in this notice.

Keepmoat Homes reserves the right to change this notice from time to time. You should check our privacy notice from time to time to ensure that you are happy with any changes. If we propose a significant change we will endeavour to notify you by email and will otherwise post a notification that our notice has changed on our Website.