Privacy Policy

Protecting your privacy rights is very important to us. This privacy policy sets out how we process your personal data when you engage with us. Please read this policy carefully to understand why and how your personal data will be used, how it will be shared, and the rights you have in respect of your personal data.

In this policy, when we talk about “personal data“, we mean information relating to an individual who can be identified – directly or indirectly – by reference to that information. For example, their name, address, phone number, or email address. When we talk about “processing“, we mean any action taken in relation to personal data, including collecting, using, storing, or deleting it.

Caudwell Ltd (registered at Coach House Broughton Hall, Broughton, Eccleshall, Stafford, England, ST21 6NS) (referred to in this policy as Caudwell, we, or us) is the data controller in respect of the personal data processing described in this policy. When we say Caudwell is the “data controller“, this means we exercise overall control and responsibility over how your personal data is processed.

When we process your personal data, we will do so in compliance with applicable data protection laws, including UK GDPR, and applicable local data protection laws.

If you have any questions about this policy, or would like to exercise any of the rights described in it, you can contact us using the following details:

• By email: reception@caudwell.com
• By post: Caudwell Ltd, The Company is the data controller of your personal data processed by us, and can be contacted here: 38 Park Street, London, W1K 2JF

Whenever we process your personal data, we strive to do so according to the following principles:

• We will process personal data lawfully, fairly, and transparently.
• We will only collect personal data for a specific and legitimate business purpose, and will only use it in a manner that is consistent with that purpose.
• We will only collect personal data that is , relevant and that is limited to what is adequate and necessary for the relevant purpose; we will not collect excessive personal data.
• We will keep personal data accurate and up to date.
• We will not keep personal data for longer than we need it, and will delete it securely once it is no longer needed.
• We will keep the personal data we process safe and secure.

When you engage with us, we collect the following information about you:

• First name;
• Last name;
• Address;
• Email address;
• Telephone number;
• Nationality;
• Information about properties you may be interested in, and
• Information about your use of our website and online resources, such as when you last accessed them, which pages you have looked at, and the IP address you used to log in. If you access certain online resources we offer, such as digital presentation models, we will also generate user credentials that allow you to log in.

We will process this personal data for the purposes described below.

To be clear, we do not collect sensitive personal data about you, such as information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, or information concerning your health, sex life, or sexual orientation.

We will process your personal data for the following purposes:

• In order to manage our relationship with you, for example by communicating with you about your property requirements and prospective property purchases, and / or completing those transactions.
• In order to send you our newsletter or offers we think you might be interested in.
• In order to understand your use of our website and online resources, including your interest in particular properties (and aspects of the property).
• Where necessary, in connection with legal proceedings (or prospective legal proceedings), in order to establish, exercise, or defend our legal rights.
• Where necessary, in order to fulfil or comply with legal obligations, including complying with requests from competent administrative or judicial authorities, or in any circumstance where such processing is required by law.
• In connection with an actual or proposed sale, transfer or re-organisation of all or part of our business and the acquisition of the business (which may involve the disclosure or transfer of your personal data to an acquiring entity).

We will not use your personal data for decisions based solely on automated processing if the decision produces legal effects concerning you or significantly affects you, unless you gave your explicit consent for this processing.

We will only process your personal data where we have valid legal grounds to do so in accordance with applicable data protection law. We rely on the following legal grounds when processing your personal data:

• Consent, i.e., where you have given us your consent to the processing (for example, if you consent to receive direct marketing from us).
• Performance of a contract, i.e., where it is necessary for the performance of a contract with you, or in order to take steps prior to entering into that contract (for example, if you complete a property purchase with us).
• Legal or regulatory obligation, i.e., where we need to process your personal data in order to comply with a legal or regulatory obligation (for example, if we need to carry out anti-money laundering checks).
• Legitimate interests, i.e., where the processing is necessary for our legitimate interests (or those of a third party). Please see the section below titled “Our legitimate interests” for more information.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We use your personal data where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal data is necessary to:

• Ensuring we provide an efficient and profession service to you and providing you with a good experience when you engage with us regarding potential property purchases or investements;
• Ensure effective administration and management of our website and online resources and ensuring network and information security;
• Maintaining an up-to-date client database and managing our client contacts;
• Administer our operations and business, including our relationships with clients, in an efficient and effective way, including understanding and responding to queries, complaints and feedback and seeking to improve and develop our services;
• Ensure the security of our or another’s premises or property, and
• Enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice.

We may obtain information about your use of our website and online resources through “cookies“. Cookies are small text files that may be placed on your device by us or certain third parties that we allow to do so. Some of these cookies are strictly necessary for the operation of the website, such as information about your computer, IP address, operating system, and browser type. You also have the choice to allow us to place other cookies on your device that help us remember your preferences and understand how you interact with our website and online resources and to show you online advertising that you might be interested in. A more detailed breakdown of the cookies we use is set out below. You can update your cookie preferences at any time via the cookie banner on our website.

Access to your the personal data is restricted to only those who need it for a legitimate business purpose, on a “need to know” basis. There are certain circumstances where we will transfer your personal data to third parties. These include:

• Caudwell entities and affiliates to administer and manage our relationship with you and so we can provide the best service across our group. We also share your personal data within our group for management forecasting and financial planning purposes.
• Service providers, who may process your personal data on our instructions. These include IT suppliers (including website, software, and app developers and providers), cloud hosting providers such as Salesforce (our CRM provider), professional advisors, marketing agencies, database providers, backup and disaster recovery specialists and email providers.
• Advertising partners, who may process your personal data in order to show you digital advertising that you might be interested in. If you do not want us to share this information, you can disable personalised advertising cookies via the cookie banner on our website.

Our suppliers and service providers will be required to meet appropriate standards on processing information and security when processing your personal data.  The information we provide them, including your information, will only be processed in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy policy.

Your personal data may be transferred to other third-party organisations in certain scenarios, such as:

• If we’re discussing selling or transferring part or all of our business, the information may be transferred to prospective purchasers under suitable terms as to confidentiality.
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you.
• If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority. For example, the police, e.g., in order to assist fraud protection and minimise credit risk; or
• If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

We may transfer your personal data to locations outside of the UK and European Economic Area (EEA). However, to ensure your personal data is protected in accordance with UK and EU data protection law, we will only transfer data outside the UK and EEA where appropriate safeguards as required by applicable data protection law are in place. This includes where a jurisdiction has been deemed adequate by the UK Government or EU Commission or, where there is no adequacy decision, by putting in place standard contractual clauses.

Please contact us at reception@caudwell.com if you would like further information on the specific safeguards used by us when transferring your personal data.

We are committed to keeping your personal data secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical and organisational measures to safeguard and secure the personal data we process. We employ a suite of IT security tools in order to safeguard personal data, we restrict access to data, and we have physical and organisational security measures in place to prevent unauthorised or unlawful access to personal data, as well as accidental loss, destruction, or damage to personal data. We also maintain an inventory of personal data and evaluate the protections that we have in place for that data to ensure that our security measures are tailored to the sensitivity of the data.

In addition, as described above, we have limited access to your personal data to only those individuals who need access to it in order to fulfil their roles, and only to the extent that they need such access. Employees are not authorised to share personal data with other employees or third parties unless that sharing is authorised and complies with this privacy policy.

If, despite all our efforts, a data breach does occur, we shall do everything in our power to limit the damage. In case of a data breach which is likely to result in a high risk to you, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. Where required, we always inform the relevant supervisory authority or authorities without undue delay.

We will only store your personal for as long as necessary for the purpose for which we have collected it and will dispose of it securely once that purpose has been fulfilled. Your personal contact data will be retained for 3 years from the date of last contact with you.

In certain circumstances, we may have to retain your personal data for a longer period to comply with a legal obligation or a request from a public authority. In these events, we will delete or anonymise your personal data as soon as we have complied with that legal obligation or request.

The retention periods are established considering legitimate business purposes, according to applicable laws.

You have a number of rights in relation to our handling of your personal data. These rights are not applicable in all circumstances and exemptions may apply. Your rights may include the following:

• Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy.
• Transfer: you may request the transfer of certain of your personal data to another party in some circumstances.
• Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground. However, we may be entitled to continue processing your information based on our legitimate interests.
• Withdraw consent: where you have provided your consent to the collection and processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

You also have a right to lodge a complaint with a supervisory authority. In the UK, you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

If you do not want to receive marketing communications from us, you can opt-out to these processing operations in contacting us at reception@caudwell.com.

Any other requests, including those regarding the exercise of such rights, and questions can be directed to reception@caudwell.com.

This privacy policy may change from time to time and is available on our website. You can tell when this privacy policy was last updated by looking at the date at the top of the policy. If we make changes to this privacy policy, we will post the updated version on our website.

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email.

Any changes to this privacy policy will become effective upon posting. We encourage you to review this website from time to time for the latest information.