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CORA

WHAT PERSONAL DATA WE COLLECT AND HOLD ABOUT YOU

  • Your name
  • Your title
  • Your address
  • Your contact telephone number(s)
  • Your contact email address(es)
  • Any personal information that you disclose to us in letters, requests for information, emails and/or telephone conversations between us.

 

PROFILE AND USAGE DATA: WE GATHER THIS DATA FROM DEVICES

  • Such as computers and mobile phones that you use to connect to our website using cookies and other internet tracking software. Please see our cookie policy for more information about this.

 

WE MAY COLLECT INFORMATION FROM YOU IN THE FOLLOWING WAYS:

Information provided by you when:

  • You use our website to request brochures or for us to contact you by telephone, post or email about our products, developments and offers.
  • When you talk to us on the phone or face to face when you visit one of our show homes and request brochures or for us to contact you by telephone, post or email about our products, developments and offers.
  • When you fill in our contact form.
  • When you contact us by email or by letter.
  • If you take part in our competitions or promotions.

 

THE INFORMATION WE COLLECT

From the following third parties that you have agreed to refer your personal information to us so that we can send you information about our products, developments and offers, or so that we can contact you by telephone, post and/or email about our products, developments and offers:

  • Any online portals such as Rightmove, Zoopla, On the market and New homes for sale
  • Estate agents and their web sites
  • Independent financial advisors
  • Government purchase assistance scheme providers, such as Homes England
  • other property companies including registered providers of social housing

 

IF YOU CHOOSE NOT TO GIVE PERSONAL INFORMATION

  • If you choose not to give us your personal information, it may mean that we cannot provide our products or services to you (or further information about them).
  • Unless we have your consent, we will only collect the personal information that we need to be able to provide a product or service to you. When we ask you for information, we will make it clear why we need it. Any data collection that is optional will be made clear at the point of collection.
  • If you provide any personal information relating to another person, normally a joint buyer or someone who is living with you, we assume that you do so with their full knowledge and consent.

 

THE REASONS WHY WE COLLECT YOUR PERSONAL INFORMATION

GDPR (General data protection regulations) says that we can use your personal information only if we have a lawful basis for doing so. This means that we can only process your personal data if we have one (or more) of these reasons:

  • To fulfil a contract, we have with you (or to take steps at your request prior to entering a contract)
  • To comply with a legal obligation
  • When it is in our legitimate interest
  • When you consent to it
  • To protect your vital interests e.g. in cases of life or death, or
  • When we are exercising a statutory function or official task in the public interest, although this will only apply in exceptional situations.

A legitimate interest is when we (or someone else) have a business or commercial reason to use your information. However, such use of your personal data must not have an unduly negative or unfair impact on your privacy or prejudice your rights and freedoms.

Here is a list of all the ways that we may use your personal information when you are a prospect, and which of the lawful reasons we rely on to do so.

Purpose Lawful basis
To provide you with information about our products and services, including purchase assistance schemes: Our legitimate interests to provide you with information about our products and services that we think you may want or need, or that may be of interest to you
To notify you about changes to our products and services: Our legitimate interests to develop and manage our brand, products and, services and to continue to provide you with information that we think you may want or need, or that may be of interest to you.
To provide you with information about new developments and house types which may meet your needs: Our legitimate interests to develop and manage our brand, products and, services and to continue to provide you with information that we think you may want or need, or that may be of interest to you.
To provide you with information about government purchase assistance schemes, like Help to Buy, and government policies that relate to home ownership: Our legitimate interests to provide you with information about products and services that we think you may want or need, or that may be of interest to you. There may also be a legal obligation for us to process the information.
To carry out an analysis about our products and services and your marketing requirements: Our legitimate interests to ensure we are sending you information we think you may want or need, or that may be of interest to you.
To inform you of promotions are running about our products and services: Our legitimate interests to provide you with information about products and services that we think you may want or need, or that may be of interest to you.
To carry out market research: Our legitimate interests to understand how we are performing so we can meet our mission statement and objectives. There may also be a legal obligation for us to process the information or to demonstrate that we are fulfilling our obligations.
To monitor telephone calls between us for authentication, security, quality and, training purposes. Our legitimate interests to help us to monitor our performance and to improve our products and services
Capture CCTV footage for security, quality, and training purposes. Our legitimate interests around health and safety and crime prevention and detection.
To process a complaint received from you: Our legitimate interests to manage our relationship with you. We may also need to fulfil our legal and contractual duties or fulfilling your requests prior to entering a contract.
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit:  Our legitimate interests in managing our business, efficiently, complying with laws or regulations that apply to us. Fulfilling our contractual duties or fulfilling your requests prior to entering a contract.

 

MARKETING

We will use your personal information to tell you about our products and services that you have expressed an interest in.

The personal information we have for you is made up of what you tell us and data we collect from third parties we work with (with your knowledge or reasonable awareness). We use this to identify and inform us of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’ (as described above).

Before sending electronic marketing communications, we will follow the law and guidance where this requires us to seek your consent. You can withdraw your consent to receive further electronic marketing at any time. Please follow the ‘unsubscribe’ instructions on our marketing communications.

We may ask you to confirm or update your choice of being contacted from time to time and if there are changes in the law, regulation, or the structure of our business.

Cora will, never sell your personal data to third party organisation.

 

WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH

This could be:

  • An estate agent that is involved with the marketing of the development
  • An independent financial advisor (IFA)
  • A Recommended solicitor
  • Any suppliers that you have requested additional items or requests for quotes to supply additional items

When sharing information, we will comply with all aspects of data protection law.

When we need to share personal data with our contractors and third-party suppliers, our relationships with them are governed by contracts which impose strict data sharing and confidentiality requirements.

Where sharing is in our legitimate business interests, we may share your information without seeking your consent first. This may be with:

  • Third parties providing services on our behalf. For example, the mailing company who distributes our marketing materials; or a research company carrying out a customer satisfaction survey on our behalf or property portals
  • We may also share information when required by law for example where ordered by the Court; where    necessary in connection with us receiving professional advice; or to protect an individual’s vital interests.

 

SENDING DATA OUTSIDE OF THE UK OR EEA

We will only send your data outside of the UK or European Economic Area (‘EEA’) to:

  • Follow your instructions,
  • Comply with a legal duty, or
  • If legally permitted to do so although if we do transfer information outside of the UK or EEA in these circumstances, we will make sure that it is protected in the same way as if it was being used in the UK or EEA. If so, we’ll use one of these safeguards:
    • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
    • Put in place a contract with the recipient that means they must protect it to the same standards as in the EEA.

 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will keep your personal information for as long as you remain an active prospect on our marketing database and/or we have products and services we believe are relevant or of interest to you.

We may keep your information for up to 12 months after the last time you contacted us or responded to contact from us for one of these reasons:

  • To respond to any questions or complaints or to resolve any follow up issues between us, or
  • To show that we treated you fairly and lawfully in compliance with data protection law.

We may keep your data for longer than 12 months if we cannot delete it for legal or regulatory reasons or need to do so to deal with future legal claims or we have a legitimate need to do so. If we do, we will make sure that your privacy is protected and only use it for those purposes.

We have a document retention schedule which sets out how long we keep different types of information for. This is based on legal requirements and good industry practice.

We will apply appropriate technical and organisational measures to ensure your personal information is secure.

 

YOUR RIGHTS

Cora is committed to upholding your data privacy rights.

 

THE RIGHT TO BE INFORMED

We will be open and transparent about how and why we use your personal information.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your personal information. This is known as a ‘subject access request’ (SAR).

We will provide a copy of your information free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in providing your information.

Where your request is manifestly unfounded or excessive, we can refuse to respond. If we refuse to respond to your request, we will let you know why.

We have one month to provide you with the information you’ve requested (although we will try to provide this to you as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your request, explaining why an extension is necessary.

We will provide you with a copy of the personal information that we hold about you. This will not generally include information about your property such as repair logs or details of contractor visits as this is unlikely to constitute your ‘personal information’.

Please be clear if you are seeking property or repairs related information, as a SAR is unlikely to fulfil your information requirements.

 

THE RIGHT TO RECTIFICATION

You can ask us to rectify your personal data if it is inaccurate or incomplete by contacting us using the contact details above. If you do, we will take reasonable steps to check its accuracy and correct it.

We will comply with your request free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in complying with your request.

Where your request is manifestly unfounded or excessive, we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

We have one month to comply with your request (although we will try to do this as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your written request, explaining why an extension is necessary.

Where we have shared the personal data in question with others, we will contact each recipient and inform them of the erasure of your personal data, unless this proves impossible or involves disproportionate effort.

Please help us to keep our records accurate by keeping us informed of any changes in your personal information.

 

THE RIGHT TO ERASURE

The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing.

This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data, for example, to comply with a legal obligation. Our response will also be guided by the provisions of our retention schedule.

We will comply with your request free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in complying with your request.

Where your request is manifestly unfounded or excessive, we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

We have one month to comply with your request (although we will try to do this as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your written request, explaining why an extension is necessary.

Where we have shared the personal data in question with others, we will contact each recipient and inform them of the erasure of your personal data, unless this proves impossible or involves disproportionate effort.

 

THE RIGHT TO RESTRICT PROCESSING

In some circumstances you can ask us to restrict the use of your personal information. This is not an absolute right and only applies if:

  • You disagree with the accuracy of your personal information
  • It has been used unlawfully but you don’t want us to delete it
  • It’s not relevant anymore, but you want us to keep it for use in legal claims
  • You have already asked us to stop using your data, but you are waiting for us to tell you if we can keep on using it
  • If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
  • We will comply with your request free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in complying with your request.

Where your request is manifestly unfounded or excessive, we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

We have one month to comply with your request (although we will try to do this as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your written request, explaining why an extension is necessary.

If we restrict the processing of your personal information, we are permitted to store the personal data, but we won’t use it.

Where we have shared the personal data in question to others, we will contact each recipient and inform them of the restriction of the personal data, unless this proves impossible or involves disproportionate effort.

 

THE RIGHT TO OBJECT

You can object to our processing of your personal data where that processing is based on legitimate interests and, in those cases, we will stop processing your personal data unless:

  • we can demonstrate a compelling legitimate grounds for continuing the processing, which override your interests, rights and, freedoms, or
  • the processing is needed for the establishment, exercise or, defence of legal claims.

If you object to our processing of your personal data for direct marketing purposes, we will immediately stop processing your personal data for that purpose although will keep your stop request on our records so as to respect your wishes.

 

RIGHTS IN RELATION TO AUTOMATED DECISION MAKING AND PROFILING

You can ask us to review any decisions that are determined by automated means, making a decision about you solely by automated means without any human involvement). You can also object to our use of your personal data for profiling (automated processing of personal data to evaluate certain things about you).

 

HOW TO COMPLAIN

If you are unhappy with why or how we have used your personal information or want to exercise your rights above, please contact our data protection lead using the contact details above.

If we cannot deal with your issue and you want to raise a complaint about our processing of your data, you can contact the Managing Director:

Mr Luke Simmons

Grovelands Business Park
West Haddon Road
East Haddon
Northamptonshire
NN6 8FB

Telephone:01604 369 200

Last update October 2022