Date of last review: Jan 2021
Regal Portfolio Management Limited is wholly owned by Regal Asset Managers Ltd
Regal Portfolio Management identifies itself as a data controller and is committed to respecting and protecting your privacy. We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for personal data under registration reference ZA879007.
You have the right to contact us in order to remove consent, to correct, amend or to erase your personal data at any time. Where your information is required for statutory record keeping purposes, we reserve the right under UK Data Protection law not to comply with your request.
About Regal portfolio management and Our Office
Regal Portfolio Management Limited whose registered company number is 09060825 and registered office is 505 Pinner Road, Harrow, Middlesex, HA2 6EH. Our trading address is Regal Portfolio Management Limited, 383 High Road, Willesden, London, NW10 2JR.
How do we collect personal information about you?
We obtain personal information about you that you provide to us through our website, emails, phone conversations or documents that you provide to us and when you visit our office Regal Portfolio Management Limited 383 High Road, Willesden, London, NW10 2JR or if we meet you at another address such as for a property appraisal or valuation.
Here are some other examples of how we would collect personal information about you:
When you call our office
When you enquire about a specific property we have for rent or for sale
When you ask us to appraise or value your property for rent or for sale
When you register for our newsletter
When you interact with us via our website, email or one of our social media sites such as Facebook, Instagram Twitter, and LinkedIn
When you use our online valuation tool on our website supported by ValPal
When you provide copies of passports, photographic ID, Utility Bills, proof of address, payslips, bank statements or other information for the purpose of becoming a client
When you request specific information regarding one of our services
When we need to carry out money laundering or other checks relating to our legal obligation or for the purpose of business transaction
What type of personal information is collected about you?
The information that we collect from you might include but is not limited to, your name, your email address, phone number, date of birth, other information pertaining to your property search or suitability to continue using our services such as relevant financial details, relevant address and related address details and any information that you choose to provide to us.
Regal Estates uses various applications to administer your personal data. We do not use these tools to perform profiling or any kind of automated decision-making about you.
Regal Estates holds your personal data in electronic database form including the use of cloud-based applications. We ensure to select cloud providers that provide suitable guarantees over the privacy and rights associated with your personal data.
The information that we collect through our website using automated technical means includes: the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, identification number, online identifier and location data. We also collect information about your website visit including which website pages are accessed, page response times and length of visits to pages.
How long do we keep your personal information?
We are legally required to hold some types of information for certain prescribed periods of time to fulfil our statutory legal obligations. Outside of these specific statutory obligations, we will hold your personal data on our systems for as long as necessary for the relevant purposes for which we use it and in accordance with any retention periods set out in any relevant contract you hold with us.
If ‘consent’ is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. We review the status of your consent every twelve (12) months and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
If we process your data on the basis of ‘legitimate interests’, we will retain your data for so long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims.
We will frequently keep our data storage up to date and remove information you request us to do so in line with current guidelines.
It is not possible for us to specify how long for which we will retain your personal information. In such cases, we will determine the period of retention based on the following criteria:
If the information was needed for HMRC purposes
To fulfil our statutory legal obligations
To provide you with information relating to your business transactions, fulfil contracts and if there is a legitimate business interest to do so
To provide you with up to date and relevant information, when requested by you
How do we use your personal information?
We may use the information that you directly provide to us in the following ways:
We may use your name, address and contact details for the purpose of carrying out our obligations arising from any contracts entered into by you and “The Companies” such as providing you with products and services you have requested, visiting and arranging viewings of your property. Our legal basis for this use is that it is necessary for the performance of a contract to which you are party and is a legitimate interest to do so.
We may use your name, email address and postal address to provide you with information, you have requested from us, respond to enquiries or requests from you, communicate with you in relation to those enquiries or requests and arranging visits to your property by our staff. Our legal basis for this use is our legitimate interests, namely the fact that you provided us with your details freely at the time of registering us and have registered information in response to our customer enquiries or requests.
We may use your name, email address and postal address to provide you with information regarding similar goods and services to those you have already enquired about or purchased. Our legal basis for this use is our legitimate interests, namely the ongoing marketing of our goods and services to individuals with whom we have an existing relationship in connection with our goods and services and/or who have expressed an interest in those goods and services.
Where you have entered into a contract with us or we have provided you with services we may use your name, email address, postal address or phone number to ask for your feedback about the services we have provided to you. Our legal basis for this use is our legitimate interests, namely evaluating and where necessary improving the quality of our service provision with a view to promoting the success of our business and positive customer relationships.
Where you are a party to an existing contract with us or regularly enter into contracts with us for our goods and services, we may use your name, email address, postal address or phone number to notify you of changes to the terms and conditions of our services. Our legal basis for this use is our legitimate interests, namely the administration and management of our business contracts and relationships
We may use your name, email address and postal address to send you marketing communications, if you have chosen to receive these. These may include information about properties For Sale, For Rent and Shared Ownership, the current property market, property alerts, promotions or offers. Our legal basis for this use is consent.
We may use your personal information to verify your identity if needed during the transaction period with us. Our legal basis for this use is compliance with a legal obligation to which we are subject with our legitimate interests being namely ensuring the security of our systems, network and information and those of third parties.
We may use the information that we automatically collect using technical means through our website to:
Administer our site and for troubleshooting, testing, research and statistical purposes. We use Google Analytics, a third-party website monitoring tool. Our legal basis for this is our legitimate interests, namely monitoring the use of our software and IT systems, improving our website
Measure or understand the effectiveness of our own advertising activity. Our legal basis for this use is our legitimate interests, namely improving the relevancy of our advertising
Measure or understand the effectiveness of our marketing emails – sending e-newsletters, property details, SMS texts or URL links to our website. Our legal basis for this use is consent
We may analyse the personal information we collect directly from you and obtain using automated technical means to create a profile of your interests and preferences so that we can contact you with information relevant to you (only if you have chosen to receive marketing communications from us).
We may also use any of your personal information that we collect from you directly and additional information about you from external sources where necessary to detect and reduce fraud and credit risk. These sources include Land Registry and Companies House. Our legal basis for this use of your personal information is our legitimate interests in preventing our business being subject to fraud or credit risk.
Who has access to information?
We will not in any circumstances sell or rent your information to third parties.
We may pass your information to third party service providers if there is a legitimate business interest to do so and if related to any part of your transaction with us and relevant to our business relationship or if any legal authorities request information or have the proper authorisation such as a search warrant or court order.
These third party providers or data processors are including but not limited to our business partners, suppliers, sub-contractors working on our behalf and for the purpose of completing tasks and providing services to you, these will include:
Named parties to a contract such as your landlord or tenant
Third parties who provide services to the property for maintenance and repairs including plumbers/electricians/builders/carpenters/damp proofing specialists/pest control/furniture suppliers
Utility companies including utility provider intermediaries where we are required to do so and to adhere to a tenancy agreement or contract
Referencing companies to obtain references relating to the letting of a property and referencing of tenants
Block managers, where a let property is a leasehold property
Inventory clerks who may be employees of our company or external inventory providers to conduct check in and check outs
Insurance or warranty companies where you have decided to buy a product or service through us
Telephone or software providers including cloud based applications utilised in order for us to conduct business transactions and fulfil contracts
Other parties that may have a direct link to fulfil any contract between a landlord and tenant, landlord and us or tenant and us
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and otherwise use your information in accordance with applicable data protection law.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy)
In addition to the specific disclosures set out in this section, we may disclose your personal information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure.
In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, applying only in certain circumstances and subject to certain exceptions, and in the interests of keeping this policy concise, not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
You have the right:
To object to us processing your personal information for marketing purposes. If you object, we will stop processing your personal information for this purpose. When we collect your data, you can choose whether you wish to receive marketing communications from us. If you wish to stop receiving marketing communications, you can opt out at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails or contacting us directly so we can stop doing so.
To access the information we hold about you and certain information about our processing of it and your rights in relation to it.
In certain circumstances, to obtain erasure of the personal information we hold about you, subject to certain exceptions.
To rectification of the information we hold about you.
In certain circumstances, to restrict our processing of your personal information or object to us processing it. If you object, we will stop processing your personal information unless certain exceptions apply.
Where our legal basis for processing your personal information is your consent or the performance of a contract and we process it by automated means, to be provided with the personal information we hold about you in structured, commonly used and machine-readable format and to transmit the information to another controller.
To not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly affecting you, subject to certain exceptions.
Where our processing of your personal information is based on your consent, to withdraw that consent at any time. If you withdraw your consent, we will stop the relevant processing, but it will not affect the lawfulness of our processing before the withdrawal.
To exercise any of these rights, email us at email@example.com or write to us at Regal Estates, 383 High Road, Willesden, London, NW10 2JR In addition, you can exercise your right to object to direct marketing at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails or informing us you wish to be removed from marketing materials.
If you consider that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint to a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. More information about lodging a complaint with the Information Commissioner’s Office (the relevant UK supervisory authority) can be found at https://ico.org.uk/concerns/.
Calling Our Office
When you call our office and you provide us information over the phone when requested this information may be used to share relevant information to you for what you are calling about. For example if you call to register your interest in a property or arrange a viewing we may ask you information such as for your name, telephone number and email address in order to send you the address by SMS message or email, likewise we may share other properties you are interested in renting or buying if you request this. We may also ask for other details such as information about your financial circumstance, job circumstance and affordability as this is directly related to information we require so we can be of service to you. Where we take payments over the phone our call recording software will be paused so financial card details are not taken or stored.
When you call our office, we may collect Calling Line Identification (CLI) information. We use this information to help improve the efficiency and effectiveness of our help line.
We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, to ascertain and demonstrate that standards are being met, for crime prevention, to establish facts and evidence for business transactions and to improve the quality of our customer service as per the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000. All recorded telephone calls will be stored securely, only retained for an appropriate time.
Security precautions in place to protect your information
We take appropriate technical and organisational precautions to secure your personal information and prevent its loss, misuse or alteration. All information you provide to us is stored on our secure servers. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
The transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and for this reason we cannot guarantee the security of data sent between us over the internet.
Cookies allow us to provide important site functionality so you don’t have to re-enter lots of information. They also allow us to remember what links and pages you have been or viewed during a session. This helps us deliver a better, more personalised service to you.
It is possible to switch off cookies by setting your browser preferences. For more information on the Cookies we use, see below for our detailed cookies policy below.
Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.
2. to allow essential parts of our web site to operate for you.
3. to operate our content management system.
4. to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.
5. to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
6. to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
7. to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.
8. to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.
9. to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.
10. to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube’s privacy-enhanced mode.
Links to other websites
Our website may contain links to other websites run by other organisations. We are not responsible for any of the privacy practices of those organisations or the content of their websites. You should read the privacy policies available of these said organisations before providing them with any personal information.
Transferring your information outside of European Economic Area (“EEA”)
We do not use our services outside the EEA.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint and we will make you aware of this. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Below is our complaints procedure:
All written complaints must be sent in writing to firstname.lastname@example.org or Regal Estates, 383 High Road, Willesden, London, NW10 2JR, we will acknowledge your complaint within 3 working days and a proper investigation will be promptly undertaken, we will send you a formal written outcome of our investigation within 14 working days, a senior member of staff will deal with the complaint. If you feel dissatisfied you will be told how to further pursue the complaint internally, this should provide you with an opportunity for a separate and detached review of the complaint by a member of staff not directly involved with the transaction, such a review will be sent to you within 14 working days.
Data Protection Complaints
You may lodge a complaint with the ICO in the event of Regal Estates non-compliance with the UK data protection law.
Review of this Policy
We keep this Policy under regular review. This Policy was last updated on 18th May 2018.
You can obtain further information about data protection laws by visiting the Information Commissioner’s Office website at www.ico.org.uk.