Privacy Policy
The Company is committed to ensuring that both your privacy is protected and that we remain compliant with all relevant data protection legislation, including the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 as applicable in the UK (UK GDPR). The Company is the controller for the purpose of the legislation.
Any personal data we collect will be used by us in accordance with current data protection legislation and this Privacy Policy.
We may change this Privacy Policy from time to time by updating this page. You should check this page intermittently to ensure that you are happy with any changes. This Privacy Policy was last updated in January 2024.
It is also important that the personal data which we hold about you is kept up to date and is accurate so please keep us updated if your personal data changes during the course of your relationship with us.
This Privacy Policy sets out how Pimlico Homes (the Company) uses, stores and protects any information that you give us whether through this website, over the phone, by email, in person or otherwise.
The Company is committed to ensuring that both your privacy is protected and that we remain compliant with all relevant data protection legislation, including the General Data Protection Regulation (EU) 2016/679.
For more information please visit our dedicated Privacy Policy page.
We routinely collect and process personal information relating to our customers, potential customers and enquirers, suppliers, sub-contractors and other third parties. This collection of data takes place when we contact you, you contact us and also, if you are a visitor to our offices, showrooms or sites. We also collect information from third parties who provide data to us such as our service providers.
We may collect, use, store and transfer different kinds of personal data. That personal data is categorised into the following groups:
Identity Data includes first name, last name, former names, username or similar identifier and title.
Contact Data – Includes address information, email address and telephone numbers.
Financial Data – Includes bank account and payment details, spending budget, credit checks and other financial information.
Transaction Data – Includes personal data which is relevant to the transaction or proposed transaction for the sale and purchase of a property. This may include information as to current buying position, funding arrangements, information relevant to the sale of a current home, part exchange information and other matters relevant to home purchasing and ownership. It also includes data about the choices you make for your new home.
Technical Data – Includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data – Includes information about your interest including potential interest, in a property or site (including data about your home ownership, purchase status and show home visits), preferences and any feedback you might provide to us as well as information about how you use our website, products and services. This also includes information which is generated by the technology-based marketing tools we use.
Marketing and Communications Data – Includes your preferences in receiving marketing from us, any third parties we may work with from time to time and your communication preferences.
Employment Data – Usually includes data about qualifications, employment history and status including details of salary and benefits as well as other information normally included on a CV. Employment Data is relevant when you apply for a role with us.
Safety Data – Specific to our role as a construction site operator. This information usually only applies to data about our contractors, suppliers, workers and other site visitors and includes data needed to ensure site health and safety. It includes some medical data and medication information, next of kin details, signatures, CPCS/ CSCS card numbers, your highest qualifications, trades and car registrations. Safety data also includes any data collected via use of CCTV systems on some of our sites.
From time to time, we may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be collated from personal data but is not itself, personal data. An example of Aggregated Data use would be where we establish where visitors to our website, are based.
For some purposes, we may use Special Categories of Personal Data. Special category data includes data about race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and health information as well as biometric data. Where we use this data, it is usually for the purpose of site safety or may be relevant to an employment role application, for example any health information you may provide to us so that we can make relevant arrangements for you to attend an interview. A similar position might apply to show home visits for example, where you or a member of your group has a disability. In most cases, where we do hold any such information, we will rely on the fact that you have provided it to us and so have consented to use of that data for the purposes for which you disclosed it to us.
We collect personal data in a number of different ways, including:
Through direct interactions via post, phone, text or email. This includes when you make an enquiry, become a purchaser, give us feedback or contact us for any other reason.
Through automated technologies including where you interact with our website when we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please also see our Cookies Policy for further details. We also operate a CCTV system on some of our construction sites for the purposes of site safety and security.
From third parties which includes where we receive data from service providers such as analytics providers, advertising providers (such as Rightmove), professionals and from providers of technical, payment and credit reference service providers. The type of data we receive from these parties will vary according to the particular relationship we have with you.
In some cases, you might volunteer information about another person or may be asked to provide details about another person. An example of this might be a member of subcontractor personnel providing emergency contact details. Whenever you provide information about another person, you should ensure that you have relevant permission before supplying such details to us and should bring this Privacy Policy to the attention of anyone whose details you provide to us.
The personal data we hold, is most commonly used for:
- marketing, promoting and selling homes to our customers.
- entering into and fulfilling contracts with our customers.
- ensuring that our company practices are safe, secure and compliant with all relevant legislation.
- tendering, negotiating and fulfilling orders and purchases for the supply and purchase of goods and services with sub-contractors and suppliers.
| Purpose & Categories of personal data | Basis for processing personal data and how we use it |
|---|---|
| Customer registration of interest
Identity Data, Contact Data, Profile Data, Marketing and Communications Data and Technical Data |
We hold this information in order to market our developments to interested parties and this is in our legitimate interests to do so for the generation of sales within our business. |
| Customer property reservations and property sales transactions
Identity Data, Contact Data, Profile Data, Financial Data and Transaction Data |
We hold this information in order to reserve properties for customers and to proceed with and complete, the sales process. It is in our legitimate interests to do this in order to sell the properties which we build. Where the data is used within the sales process, we use the data for entering into and performing our contract with you. |
| Customer aftercare services
Identity Data, Contact Data, Profile Data, Financial Data and Transaction Data |
We use this data to provide aftercare services such as dealing with follow up enquiries or any problems. In some cases, this may be necessary for the performance of our contract with you. In other cases, we may provide an aftercare service where it is in our legitimate interests to do so for the purpose of customer service quality and reputation management. This may also involve the disclosure of data to our contractors and other third parties. Data use for this purpose also includes dealing with our complaints process and feedback. |
| Marketing activities
Identity Data, Contact Data, Profile Data, Marketing and Communications Data and Technical Data |
We use these types of personal data for the promotion of our business and sending details about us and our properties and related services. We do this as it is in our legitimate interests for the marketing and promotion of our business, for developing our profile, understanding our customer base and informing our business strategy. |
| Website Administration and Data Analysis
Technical Data and Profile Data |
This covers the use of personal data for the administration of our website including troubleshooting, testing and maintenance. It is also to ensure our website content is presented in the most appropriate way and to tailor sales and customer service information for you. This also covers analysing both traffic to our website to enhance the site and content we provide and our customer base. See also our Cookies Policy about the use of cookies on our website. These uses are in our legitimate interests to ensure our website functions properly and in some cases, for website and network security. Data analysis is also in our legitimate interests as it allows us to understand our audience, provide tailored information and promote our business. |
| Management of subcontractors and suppliers
This is usually limited to Identity Data and Contact Data. In some circumstances, it may also include Financial Data and Transaction Data. |
We hold this information to negotiate, tender and fulfil subcontracts and supplier contracts relating to the building of Duchy Homes properties. Use of data for this purpose also includes dealing with other third-party service providers such as IT providers, market research organisations and professional advisors and consultants. We use data for these purposes as it is in our legitimate business interests for the proper appointment, management and administration of supplier and contractor relationships who assist us and from whom we source goods and services. |
| Performing on site inductions/on site health and safety requirements including site safety induction through our online portal
Contact Data, Identity Data, Safety Data |
Data held for this purpose relates to representatives of sub-contractors and suppliers. We hold this information to ensure that only suitably qualified, inducted and trained persons are permitted onto sites and that our sites are suitable workspace environments for staff and other site visitors. It is also used for emergency or incident purposes. This ensures that we are compliant with relevant legislation, including the Health and Safety at Work etc Act 1974 and the Equality Act 2010. We process this data therefore, to comply with legal obligations to which we are subject and where we process special category data for this purpose, with consent of the relevant person. |
| Job applications – dealing with prospective employees and candidates
Identity Data, Contact Data and Employment Data |
We hold this information for handling job applications. It is in our legitimate interests to use data for this purpose in order to: (1) recruit new employees; and (2) contact unsuccessful candidates and invite them to apply for future vacancies. This is part of our role as a potential employer. Where you apply for a role with us, we may also collect information from referees or previous employers but will only do so with your consent. We do not routinely request any special categories of personal data for this purpose but we will process that kind of information if you decide to disclose it to us, in which case we will do so on the basis that you have consented. |
When we refer to our legitimate interests above in relation to any of the purposes, we refer to the interest we have in conducting and managing our business. We consider and balance any potential impacts on relevant individuals in assessing our legitimate interests.
We use Identity Data, Contact Data, Profile Data, Marketing and Communications Data and Technical Data to form a view on what we think may be of interest including where you have requested information or expressed an interest in any of our sites. We will continue to send marketing communications in accordance with the timelines referred to below, unless you opt out by clicking to ‘unsubscribe’ from our emails or by contacting us.
We will not share your personal data with any third party for marketing purposes.
We hold personal data in a variety of forms, which include paper records, electronically on cloud- based systems, electronically on local servers and on company hardware.
We will hold the data for as long as we continue to have a legitimate interest to do so. This varies according to the different categories of personal data we hold and the purposes for which we hold it.
Personal data that we hold for prospective customers will be retained throughout the phase of construction and for a 6 month period following the sale of the last home on that site. After that date, all personal data will be suppressed on our database.
Personal data of representatives of subcontractors and suppliers will be retained for a period of up to 13 years to reflect the 12 year contractual liability period and a further 1 year buffer.
Personal data that we hold of unsuccessful candidates in recruitment drives will be retained for no longer than 12 months from the date of last contact with that person.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
These timescales will be kept under review and may be amended from time to time.
We will use your personal data for the initial purposes unless we reasonably consider that we need to use it for a different reason. We may also process and disclose your personal data in compliance with relevant rules where required or permitted by law.
Using your data for the purposes outlined in this policy may involve sharing your personal data with third parties such as IT service providers, administrative service providers, credit reference and financial service providers, installers and contractors and any consultants who we may use. We may also transfer personal data to our professional advisors such as insurers, bankers, accountants, conveyancers and where relevant, to regulators and other authorities such as the National House Building Council. We require those third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to use your data for specified purposes in accordance with our instructions. In some circumstances, we may request your specific consent to a data disclosure.
We do not transfer your personal data outside the UK. If on rare occasions we do so, we ensure a similar degree of protection by putting in place contract provisions which give personal data a comparable level of protection as it has in the UK.
From time to time, we may include links to third-party websites and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control such third-party websites and are not responsible for their privacy policies or how they use personal data.
You have a number of rights in relation to the personal data that we hold. These include:
- The right to be informed;
- The right of access (also known as a Subject Access Request);
- The right to rectification;
- The right to erasure
- The right to restrict processing;
- The right to data portability;
- The right to object; and
- Rights in relation to automated decision making and profiling.
Further information on these rights can be found on the website of the Information Commissioner’s Office at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. If you wish to exercise any of these rights, you can contact using the below details.
If you are concerned that any of the personal information we hold on you is incorrect, if you wish to object to the use we have made of your personal data or otherwise if you have any questions about this policy, please email to: [email protected].
Finally, you also have the right to make a complaint at any time to the Information Commissioner’s Office but we would always appreciate the chance to deal with any concerns you may have in the first instance.
