- visitors to our website or people who enquire about our business and properties we list
- people who do business with us
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Horton and Garton Ltd|
|Our data protection officer||John Horton, 172 King Street, London, W6 0QU.|
|Personal information||Any information relating to an identified or identifiable individual|
1. The information we collect about you
When you do business with us, we collect the following personal information from you:
- your name
- your contact details, including: email address, telephone number, and postal address(es) associated with your account;
- details of the services received or to be received from us;
We will also collect some or all of the following information, as relevant to the provision of the services
that you receive from us:
- payment information, including: bank account details, credit card number and expiry date, proof of funds;
- information relating to the ownership of the property;
- information relating to the layout of your property (floor plans and photos);
- information about the appliances and devices in your property and their warranties;
- information about the access to the property (keys, codes etc.);
- records of your discussions with our employees, whether oral or written (including through our social media platforms), including: comments and opinions that you may share about the provision of the services, complaints you may make or questions you may ask. Telephone conversations may be recorded for training purposes, and to allow us to improve our services.
You are not obliged to provide to us any of the above personal information; however, we may not be able to provide you with all our services if the necessary information is not received.
2. How and why we will use the information about you
In addition to collecting information directly from you (such as when you create your account, use any of our products or services, or otherwise contact us, and from cookies on our website), we may also collect 1information from third party products and apps (LetMC, Tenant Shop, FixFlo etc.) when you use them in connection with our services.
3. Key Terms
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as
this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What We Use Your Personal Information For||Our Reasons|
|To prevent and detect fraud against||For the performance of our contract with you or to|
take steps at your request before entering into a
|To prevent and detect fraud against||For our legitimate interests or those of a third|
party, i.e to minimise fraud that could be damaging
for us and for you
|Conducting checks to identify our customers and|
verify their identity
Screening for financial and other sanctions or
Other processing necessary to comply with
professional, legal and regulatory obligations that
apply to our business, eg under health and safety
regulation or rules issued by our professional
|To comply with our legal and regulatory|
|Ensuring business policies are adhered to, eg|
policies covering security and internet use
|For our legitimate interests or those of a third|
party, i.e to make sure we are following our own
internal procedures so we can deliver the best
service to you
|Operational reasons, such as improving efficiency,|
training and quality control
|For our legitimate interests or those of a third|
party, i.e to be as efficient as we can so we can
deliver the best service for you at the best price
We gather this information to allow us to process your registration, process any requests you may make (including to take payment), provide the services requested, and maintain your account. The relevant information is then used by us, our agents and sub-contractors to provide you with statements of your account, and to communicate with you on any matter relating to the conduct of your account and the provision of the services.
We will also use your information to respond to your questions and complaints, and to investigate and respond to any misuse or abuse of your account (including fraud).
If you agree, we may also contact you about other products and services we think may be of interest to you,
based on our review of your information.
From time to time we may use information about how you use our products and services, and/or provide it to our customer service agencies, for research and analysis purposes so that we can monitor and improve the services that we provide. We or our agents and sub-contractors may contact you by post, email or telephone to ask you for your feedback and comments on the services you receive or used to receive from us.
We may also use aggregate information and statistics for the purposes of monitoring the use of our services and our website usage, in order to help us understand how they are used and to develop and improve them, and we may provide such aggregate information to third parties. These statistics will not include information that can be used to identify you.
4. Who We Share Your Personal Information With
In addition to those mentioned above, we may share personal information with the following:
- other companies in our franchise group trading as Horton and Garton, in order to provide the services to you;
- third party installers, engineers and delivery companies, to enable them to provide their services to you in respect of our products;
- other providers of services to us, including companies that: provide IT support, process payments; analyse data; provide financial or legal advice; send communications to customers; engage in market research;
- regulators, local government councils, other government bodies, or law enforcement, where we are required to do so;
- tenancy deposit administrators (such as the Tenancy Deposit Scheme);
- our present and future contact details to utility suppliers, local authorities and credit or reference providers, including for the purposes of debt recovery.
Horton and Garton may also wish to provide you with information (via email, text, push notification, mail or telephone) about any other service or products we think may be of interest to you. We have a legitimate interest in processing your personal information for promotional purposes. If you would rather not receive this information, please send an email message to email@example.com or contact our team. However, where consent is needed, we will ask for this consent separately and clearly. You have the right to opt out of receiving promotional communications at any time by contacting us.
However, in a few cases some of our website features may not function if you remove cookies from your browser.
7. How We Protect Your Information
Information may be held at our offices and those of our franchisees, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
We have put in place the following security procedures and technical and organisational measures to safeguard your personal information: Data is stored on the Cloud Platform servers located in EU, protected by passwords and a firewall preventing access by any protocol apart from HTTPS and SSH. SSH access is only allowed using authorised RSA keys.
We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
8. Overseas Transfers
The information you provide may be transferred to countries outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy, including the United States of America. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
9. Access to Your Information and Updating and Correcting Your Information
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send a request to firstname.lastname@example.org and book an appointment with us to visit our office and collect the copies in person. We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to Horton and Garton changes (for example if you change your email address, name or payment details), or if you wish to cancel your registration, please let us know the correct details by sending an email to email@example.com. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
10. Your Rights Regarding Your Information
Including as stated above, you have the following rights with regard to your personal information:
- the right to access your personal information that we hold;
- the right to be informed how your personal information is used;
- the right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data;
- the right to request corrections to inaccuracies in your personal information that we hold;
- the right to request that we cease to hold certain of your personal information, understanding that this may cause the functionality of our products may be reduced, or to not be usable at all;
- the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you;
- the right to opt out of receiving direct marketing messages.
To exercise any of the above rights, please contact us at firstname.lastname@example.org. You also have the right to contact the UK Information Commissioner’s Office you are unhappy with how we are using your personal information, though we encourage you to contact us first, where we will do our best to address your concerns. The Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
11. How Long We Keep Your Personal Information
We will retain your personal information for the duration of your account with us. After you close your account, we will retain your personal information for a reasonable period, in order to fulfil our contractual and legal obligations to you, and to maintain our records.
13 How to Contact Horton and Garton
|Our Contact Details|
|Horton and Garton Ltd|
172 King Street
Tel: 020 8819 0510
14. Service Notifications
Some of our apps may send service notifications directly to your electronic device (through the relevant app, by email and/or by text, in accordance with your preferences) when we have something important or of interest to share with you, or where you have asked to be notified of events relating to the operation of the system at your property. At any time you can turn off service notifications through the relevant app, through your online account or via the system settings of your electronic device.
15. Links to Other Websites
16. Sale of Business
If Horton and Garton’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.