Privacy Policy

At Cookes Property Management we take the management of your personal data very seriously and are committed to ensuring that your data and privacy are protected.

We have appointed a DPO (Data Protection Officer), and any queries or concerns that you may have should be sent to info@cookesproperty.co.uk and marked for the attention of the DPO, or in writing to: the Data Protection Officer, Cookes Property Management Ltd, Unit 9 Wharf Road Industrial Estate, Wharf Road, Woodston, Peterborough. PE2 9PS.

This Privacy Policy was last amended in June 2018 and supersedes any previous versions.

Third Party Links

Our website may include links to third part websites, plug-ins or applications which may allow third parties to collect or share your personal data.  We are not responsible for their use of your personal data and cannot control it.

1. What information may we collect and how we use it?

 As a Lettings business we collect, use, store and transfer different types of personal data depending on the services that we supply, that you would like to use.  When renting or letting a property from Cookes Property Management Ltd, we collect and use your personal data which may include:

  • Identity Data (such as: title, name, marital status, date of birth, photo ID, proof of residency  and gender)
  • Contact Data (such as: email address, telephone numbers and residential address history)
  • Financial Data (such as: bank account details and statements)
  • Marketing and Communications Data (your marketing preferences from us and our third parties and your communication preferences)

It is important that the personal data that we hold about you is accurate and up to date.  Please keep us informed if your personal data changes during your relationship with us.  Please contact us to update or rectify your personal data at any time by emailing info@cookesproperty.co.uk and marking your email for the attention of the DPO, or in writing to: the Data Protection Officer, Cookes Property Management Ltd, Unit 9 Wharf Road Industrial Estate, Wharf Road, Woodston, Peterborough. PE2 9PS.

2. How do we collect your personal data?

Direct Interactions

 Your Identity, Identity, Contact and Financial Data can be collected when you:

  • Apply for our services
  • Walk-in or email or telephone our branch
  • Request marketing to be sent to you
  • Leave us some feedback
  • Contact us through social media

Third Parties or Publicly Available Sources

 We may receive personal data about you from various third parties and public sources as listed below:

Identity and Contact Data from data brokers or aggregators such as:

  • HomeLet based inside the EU
  • Lets Let Online based inside the EU
  • Rightmove based inside the EU
  • Zoopla Property Group based inside the EU
  • Facebook based outside the EU

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How do we use your Personal Data?

In the following table we will summarise the ways and for what purposes that we plan to use your personal data. Please Note: We will only use your personal data for the purpose that we have collected it unless it is necessary for us to comply with our legal obligations.

 

Purpose / Activity Type of Data Lawful Basis for Processing Including Basis of Legitimate Interest
To contact you Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of a contract with you

 

 

Necessary for our legitimate interests (for operating our business, to recover debts due to us, to keep our records updated and to study how customers use our products / services)

To carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products and services that you request from us  

Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of a contract with you

 

 

Necessary for our legitimate interests (for operating our business, to recover debts due to us)

To permit selected third parties:

 

·         To provide you with information about goods or services which we feel may be of interest to you

·         To assist us in the improvement and optimisation of advertising, marketing material and content, our services and our website

Identity

Contact

Technical

Usage

Consent (in relation to SMS and email marketing communications)

 

Necessary for our legitimate interests (to develop and improve our service offering)

To notify you about changes to our services Identity

Contact

Performance of a contract with you

 

Necessary to comply with our legal obligations

 

Necessary for our legitimate interests (to keep our records updated)

To ensure that content from our website is presented in the most effective manner for you and your computer Identity

Contact

Financial

Transaction

Necessary for our legitimate interests (to develop our products / services and grow our business and provision administration and IT services)
To verify your identity Identity

Contact

Financial

Transaction

Necessary to comply with our legal obligations

 

Necessary for our legitimate interests (for running our business and to prevent fraud and money laundering)

As part of our efforts to keep our site safe and secure and to prevent or detect fraud Identity

Contact

Financial

Transaction

Necessary to comply with our legal obligations

 

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud

To provide customer support Identity

Contact

Performance of a contract with you

 

To facilitate and to enable you to partake in a property viewing Identity

Contact

Performance of a contract with you

 

To comply with requirements imposed by law or any court order Identity

Contact

Technical

Usage

Necessary to comply with our legal obligations

 

Marketing

You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time.  You also have the right to withdraw consent for us to pass your information to third parties for marketing purposes.  If you do withdraw your consent, this will result in us ceasing to market goods and services to you.

You can ask us to stop sending you marketing messages at any time by emailing info@cookesproperty.co.uk or by calling 01733 312338

If you do withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations.

If you no longer wish to be contacted by third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies about how to unsubscribe.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the Cookes Property Management Group of companies for marketing purposes.

Cookies

The Cookes Property Management website and applications may automatically collect data about how you use our services in order to help us improve future functionality.  We use Google Analytics, which is a web analysis service provided by Google.

The cookies on the Cookes property Management website do not track, collect or upload data such as your name, email address or billing information, but it may collect data about your equipment and browsing activities.  We may collect and report on the adoption and usage of specific features, crashes and exceptions and other useful, anonymous metrics.

Certain devices can detect your approximate location, via latitude and longitude. The accuracy of this data is not in the control of Cookes Property Management.  lf this feature is requested, Cookes Property Management will prompt you to provide your permission to access your location data for the purposes of providing you with results or directions based on your current location.  You can disable location settings within your browser or app.

4. Disclosures of Your Personal Data

 We may have to share your personal data with the parties set out below for the purposes set out in the “Purposes

for which we will use your personal data” table above. We have agreements in place with our third parties that restrict their use of your personal data.  We only allow third parties to use your personal data for specified purposes and in accordance with our instructions.

 

 

Category Explanation

 

Related Third Parties Lets Let Online (referencing)
External Third Parties Service providers acting as processors based in the United Kingdom who provide lT and system administration services, anti-money laundering service providers, tenancy deposit administrators (such as MyDeposits) and services to enable us to perform our contract with you.

 

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accountancy services.

 

HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

 

If you are a tenant and we are helping you with the administration in moving, we will refer your personal information to HomeLet which acts on our behalf to provide these services.  HomeLet may contact you about the services that they provide if you consent for them to do so.

 

Other Third Parties Sometimes there may be third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. lf a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Anti-Money Laundering

 Cookes Property Management are committed to operating its business in a transparent and open manner consistent with our legal and regulatory obligations.  We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity.  We always seek to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to the National Crime Agency.

As part of this commitment, we adopt a strict compliance of all Anti-Money Laundering rules, with specific emphasis on the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010 and the Terrorism Act 2000.

Cookes Property Management policy commitment is applicable to all of our customers, including landlords and tenants.  As a result, we obtain and hold for a period of at least five years evidence pertaining to our customers’ identity and, where appropriate, we obtain proof of ownership of property.  We will be unable to proceed with any work on behalf of our customers if we are unable to obtain this information.  Customers’ identity will be subject to an electronic identity check, which may also include a credit check.

Cookes Property Management are registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017.

5. Data Security

Once we have received your personal data we will use reasonable and necessary procedures and security features to try and prevent unauthorised access.  For example, we limit who can access your personal data to those individuals and third parties who need to know it and who are subject to a duty of confidentiality.  lf we become aware of a data breach we will notify the lnformation Commissioner’s Office.  lf we believe that the data breach is serious, we may notify you in accordance with our legal requirements.

 6.Data Retention

 We hold on to your personal data whilst you use our services (or whilst we provide services connected to you) and for at least five years thereafter, for legal, regulatory and accounting purposes.  lf we need to hold on to your personal data for longer, we take into consideration the potential risks in continuing to store your data against why we might need to keep it.  ln some circumstances we might anonymise your personal data so it is not associated with you, and we may then use this information indefinitely.

7. Your Legal Rights

 Under data protection laws you have the right to protect and look after your personal data. You have the right to:

  • ask us for the personal data that we hold and process about you (this is commonly known as a data subject access request). You have rights to the following information:
  • the purpose(s) for which we are processing your information;
  • the categories of personal information we hold about you;
  • the recipients or categories of recipient to whom the personal data has been or will be disclosed;
  • the period for which we will store your information, or the criteria used to determine that period;

prevent the use of your personal data for marketing purposes by;

  • informing a Cookes Property Management telephone operator; or
  • by ticking the relevant boxes on the data collection forms; or
  • by emailing info@cookesproperty.co.uk

Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you, or to tell you about changes to our terms and conditions.;

  • ask that any inaccurate information we hold about you is corrected;
  • ask that we delete the personal data we hold about you in certain situations;
  • ask that we stop using your personal data for certain purposes;
  • ask that we do not make decisions about you using completely automated means; and/or
  • ask that personal data we hold about you is given to you, or where technically feasible a third party chosen by you, in a commonly used, machine-readable format.

The rights listed above may apply in certain circumstances, and so we may not always be able to comply with your request to exercise these rights.  We will usually respond to a request from you to exercise your rights within 1 month of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests.  Please be aware that we may need to process your personal data and/or request specific information from you to help us comply with your request.  You will not usually have to pay a fee to exercise these rights, but we reserve the right to if your request is clearly unfounded, repetitive or excessive, alternatively we may refuse to comply with your request.

Complaints and Feedback

If you would like to speak to us about how we handle your personal data, please contact our Data Protection Officer in the first instance at info@cookesproperty.co.uk.  You can also complain to the lnformation Commissioner’s Office who is the UK supervisory authority for data protection issues.

How to contact Cookes Property Management

We welcome your views about our website and our Privacy Policy. lf you would like to contact us with any queries or comments please send an e-mail to info@cookesproperty.co.uk

Indemnity

You acknowledge that you are solely responsible for the use to which you put this website and all the results and information you obtain from it and that all warranties, conditions, undertakings, representations and terms whether expressed or implied, statutory or otherwise are hereby excluded to the fullest extent permitted by law.

Save in respect of liability for death or personal injury arising out of negligence or for fraudulent misrepresentation, we and all contributors to this website hereby disclaim to the fullest extent permitted by law all liability for any loss or damage including any consequential or indirect loss or damage incurred by you, whether arising in tort, contract or otherwise, and arising out of or in relation to or in connection with your access to or use of or inability to use this website.

Whilst we take every care to ensure that the standard of this website remains high and to maintain the continuity of it, we do not accept any ongoing obligation or responsibility to operate this website (or any particular part of it).

If any part of our terms and conditions is deemed to be unenforceable (including any provision in which we exclude our liability to you) the enforcability of any other part of these conditions will not be affected.

These terms and conditions and your use of this website are governed exclusively by English law.

This does not affect your statutory rights as a consumer.

Cookes Property management Limited is registered in England and Wales (registered number 7017965). Our registered office is at Unit 9 Wharf Road Industrial Estate, Wharf Road, Woodston, Peterborough. PE2 9PS