Privacy Policy | SEM Management Team

Privacy Notice

This is the privacy notice of Sterling Estates Management Limited
(registration number: 05424444) whose registered office is at
1st Floor Compton House, 23-33 Church Road, Stanmore, Middlesex,
England, HA7 4AR.

This privacy notice sets out how we collect and process your personal
data. This privacy notice also provides certain information that is
legally required and lists your rights in relation to your personal data.

This privacy notice relates to personal information that identifies you
as a natural person (whether you are an actual or potential customer, an
individual who browses our website or an individual outside our
organisation with whom we interact). We refer to this information
throughout this privacy notice and policy as personal data or personal
information and further detail of what this includes are set out in this
privacy notice below.

The privacy and security of your personal information is very important
to us so we want to assure you that your information will be properly
managed and protected by us at all times. Please read this privacy notice
carefully as it explains how we may collect and use your personal data.

Changes to the Privacy Notice and Your Duty to Inform Us of Changes

This privacy notice may vary from time to time so please check it
regularly. This version was last updated on 23 March 2023.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during
your relationship with us. For example, if you change your email address,
name or payment details, please let us know the correct details by sending
a letter to us at our registered address above.

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.

Links to Other Websites

Our website may contain links to other websites of interest. However,
once you have used these links to leave our site, you should note that we
do not have any control over that other website. Therefore, we cannot be
responsible for the protection and privacy of any information which you
provide whilst visiting such sites and such sites are not governed by
this privacy notice.

You should exercise caution and look at the privacy statement applicable
to the website in question.

How to Contact Us

For the purposes of relevant data protection legislation, we are a
controller of your personal data. As a controller we use (or process)
the personal data we hold about you in accordance with this privacy
notice.

If you need to contact us in connection with the use or processing of
your personal data, then you can do so using our contact details on our
website or correspondence you may have received from us.

What Information We Hold About You

The personal data that we collect about you may include the following
information:

• Identity Data includes full name, username or similar
  identifier, age, nationality, marital status, title, date of birth,
  photographic identification and gender.
• Contact Data includes billing and correspondence
  addresses, email address and telephone numbers.
• Financial Data includes bank account and payment
  card details.
• Transaction Data includes details about payments
  to and from you.
• Property Data includes details about property
  occupancy, building and car parking security data, energy usage and
  relevant surveys.
• Information about your use of our website, including personal data
  gathered using cookies.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including:

• Direct interactions. You may give us your
  Identity, Contact, Financial and Property Data by filling in
  forms or by corresponding with us by post, phone, email or
  otherwise.

  This includes personal data you provide when you:

  • Apply for our products or services;
  • Complete a survey; or
  • Give us some feedback.
• Use of our website, including personal data gathered using cookies.

• Third parties or publicly available sources.
  We may receive personal data about you from various third parties
  as set out below:

  • Personal data from the landlord;
  • Personal data from the management company appointing us as a
    managing agent;
  • Personal data from solicitors or other legal professionals,
    including when you purchase or rent within a property we
    manage;
  • Personal data from other managing agents as part of a
    management handover to us; and
  • Identity, Contact and Property Data from publicly available
    sources such as Companies House, Land Registry and the
    Electoral Register based inside the EU.

We also collect information from publicly available sources and
third-party databases made available to the relevant industry for the
purposes of reducing fraud and financial crime, as well as any other
third-party databases where your personal data may be held, provided
such third parties have lawful bases on which to share such personal
data with us.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or
  have entered into with you, the named manager or the landlord that
  appointed us.
• Where it is necessary for our legitimate interests (or those of a
  third party) and your interests and fundamental rights do not
  override those interests.
• Where we need to comply with a legal or regulatory obligation.

Given the above, generally we do not rely on consent as a legal basis
for processing your personal data.

How We Use Your Personal Data and the Lawful Basis for Doing So

We may rely on one or more of the following legal bases when processing
your personal data for the following purposes:

In the interests of security and to improve our service, telephone calls
you make to us or calls we make may be monitored and/or recorded. The
processing is necessary to pursue our legitimate interest in the
management and operation of our business.

Cookies

A cookie is a small file which asks permission to be placed on your
computer’s hard drive. Once you agree, the file is added and the cookie
helps analyse web traffic or lets you know when you visit a particular
site.

Cookies allow web applications to respond to you as an individual. The
web application can tailor its operations to your needs, likes and
dislikes by gathering and remembering information about your preferences.

We may use traffic log cookies to identify which pages are being used.
This may help us analyse data about web page traffic and improve our
website in order to tailor it to customer needs. We only use this
information for statistical analysis purposes and then the data is
removed from the system.

Overall, cookies help us provide you with a better website by enabling
us to monitor which pages you find useful and which you do not. A cookie
in no way gives us access to your computer or any information about you,
other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers
automatically accept cookies, but you can usually modify your browser
setting to decline cookies if you prefer. This may prevent you from
taking full advantage of the website.

Who We Pass Your Personal Data To

We may have to share your personal data with the parties set out below
for the purposes set out in the table above.

• Service providers acting as processors who provide IT and system
  administration services, including Trace Property Solutions.
• Property-related services such as contractors, tradespersons or
  service providers acting as processors in providing maintenance
  and management services.
• Professional advisers acting as processors or joint controllers,
  including lawyers, auditors, debt collection agencies and insurers
  who provide consultancy, banking, legal, insurance and accounting
  services.
• HM Revenue & Customs, regulators and other authorities acting as
  processors or joint controllers based in the United Kingdom who
  require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal
data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.

How Is Your Data Secured?

We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who will only process your
personal data on our instructions and they are subject to a duty of
confidentiality.

We have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.

How Long Will We Use Your Personal Data For?

We will only store your data for as long as is necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying
any legal, accounting or reporting requirements.

Your Rights

You have a number of rights concerning the personal information we use,
which you may ask us to observe. In some cases, even when you make a
request concerning your personal information, we may not be required or
be able to carry out your request, as this may result in us not being
able to fulfil our legal and regulatory obligations under the lawful
processing conditions under which we hold your data, or because there
is a minimum statutory period of time for which we have to keep your
information.