At Devine Homes Plc ("Devine Homes", "we", "us", "our") we recognise that it is important for you to understand how we use your personal data. Therefore, please read the following information carefully as it contains important information regarding the Devine Homes website (this/our “Site”) and the way in which we use your personal data.
We will only use personal data in ways that are described in this policy and only ways that are consistent with our obligations and your rights under applicable data protection laws.
2. Who we are
For the purpose of applicable data protection laws, the data controller (in other words, the organisation that determines how and for what purposes your personal data is used) will be Devine Homes Plc.
3. Personal data we may collect from you and how we collect it
Personal data you provide to us directly.
Ways in which you might provide the data to us.
This is personal data about you that you give us, which can happen in a wide variety of ways, including by asking us to provide you with products and services and your use of those products or services, signing up to our newsletter, corresponding with us by e-mail, telephone or SMS or if you mention or interact with us on social media (for example by mentioning/tagging us or by contacting us directly). It also includes personal data you provide when you provide us with feedback, report a problem with our Site, enter into a contract with us or otherwise provide us with any personal data.
What type of data might be included?
The personal data you give us may include but is not limited to: your name, postal address, e-mail address and phone number (including mobile number), gender (and preferred salutation), date of birth, social media handle and personal data on your social media account, financial and credit card personal data, thoughts about our products (including complaints and reviews). If you are one of our contractors or suppliers, we will process your business contact details and your job role.
We will only ever ask you to give us personal data which we need in order to provide you with the products or services that you have requested from us.
If you apply for a role with us, we will collect a range of information directly from you either by email, over the phone or via an online job application process/system which may include but is not limited to: your name, address and phone number (including mobile number), email address, gender (and preferred salutation) date of birth, your health information (if relevant to your application), the contents of your CV (including details of previous roles, any relevant qualifications you have obtained), evidence that you are legally permitted to work in the country you are applying for a role in, your current and desired annual salary, your current notice period, websites, whether you have previously been employed by us, how you heard about the role you are applying for and any other information that we reasonably require as part of the recruitment process.
If you are a job applicant and want more detail about how we process your personal data as part of our recruitment process, you can contact our HR department by email at email@example.com.
Visiting one of our sites
If you visit one of our sales centres or show homes (or book to do so), or if you visit one of our construction sites or offices, we will process your personal data. This personal data may include: your name, postal address, e-mail address and phone number (including mobile number).
We may also process your personal data in the form of video or audio recordings via our CCTV. We use CCTV on various sites, primarily construction sites and offices, for the safety of and prevention of any crimes committed against our staff, our customers, our equipment and our properties, not for other monitoring purposes.
We provide staff with the option to wear enhanced safety items whilst on our sites which monitor them to increase their safety and to prevent crime, not for other monitoring purposes.
In the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities.
Personal data we collect or generate about you.
When you visit our Site or get in touch with us, we may collect, generate, store and use certain personal data about you.
This personal data may include: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if accessing an account with us), browser type and version, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform and any phone number used to call our customer service number.
It may also include information about your visit to our Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse our Site.
This information is used by us to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and for the control of illegal acts. We reserve the right to check these log files and data retroactively if there is reasonable suspicion of an illegal act due to concrete indications. We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable.
Personal data we receive from other sources.
We may occasionally receive personal data about you from other sources, for example if you use any of the other websites we operate or the other services we provide as part of our corporate group.
4. Why and how do we use your personal information and what is our "lawful basis" for doing so?
We will only use your personal information when the law allows us to. Whenever we process your personal data, we are required to identify and maintain a valid "lawful basis" (i.e. a legally compliant justification) for the processing. To help you to understand what we do with data and why, we have described the various relevant lawful bases that we rely on in the table below. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
How we use your personal data
To provide you with the information and services that you request from us (i.e. to complete certain tasks, processes, and to communicate with you regarding those services that you request from us and respond to your questions and comments).
To measure how satisfied our Site visitors and our customers are and provide customer service (including troubleshooting in connection with your requests for services or when you ask us questions by email, on the phone or on social media).
To prevent or detect crime, fraud or abuses of our products and services or our Site and to enable third parties to carry out related technical, logistical, research or other functions on our behalf related to these purposes.
To send you newsletters, updates, information about new products or services that we think might interest you.
To measure or understand the effectiveness of advertising we serve to you and.
To carry out market research or similar surveys.
To find out more about the visitors to our Site and our customer base as a whole (and not to find out more about you as an individual) to ensure that the products and services that we offer are most likely to interest our Site visitors and customers.
To notify you about changes to our services and terms and conditions.
For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our website.
If you are a job applicant, we will use your personal data to assess your suitability for the role and to make recruitment decisions. Unless you ask us not to, we will continue to process the application data (including CVs and any interview notes) of unsuccessful applicants for a period of 6 months.
We use CCTV on various sites, primarily construction sites and offices, for the safety of and prevention of any crimes committed against our staff, our customers, our equipment and our properties, not for other monitoring purposes.
We provide staff with the option to wear enhanced safety items whilst on our sites which monitor them to increase their safety and to prevent crime, not for other monitoring purposes.
What is our legal justification for processing your personal data
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for products and services.
Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues).
In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, if we receive a legitimate request from a law enforcement agency).
In other cases (such as the detection of theft, fraud or ensuring security of our website) we will rely on our legitimate interests in keeping our employees and our Site secure and to prevent theft and fraud.
Unless we are contacting you in a business to business capacity, we will only use your personal data to send you electronic marketing messages if we have consent from you to do so (or if you are an existing customer and have not opted out of receiving marketing materials).
In some cases, we will rely on our legitimate interests to send these types of communication (our legitimate interest in marketing and advertising our products).
We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you.
We rely on our contractual arrangements with you as the lawful basis for this processing. In some cases, we rely on our legitimate interests as a business to send you these updates.
We have a legitimate interest to respond to your contact for the purposes of administering our business.
We have a legitimate interest in recruiting talent into our business and assessing candidates to ensure that we are making fair and appropriate recruitment decisions.
We may process some of your data on the basis of a legal obligation that applies to us as an employer (e.g. in some territories, this may require us to process data relating to race, religion, gender or disability/health).
We have a legitimate interest to ensure the safety of and prevention of any crimes committed against our staff, our customers, our equipment and our properties.
In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, in the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities.).
5. What if you fail to provide personal information?
Please make sure you provide us with certain information when requested as if you don't we may not be able to perform the contract we have entered into with you (such as, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6. Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy notice to you.
7. How we share your personal information and where it may be processed
Third party suppliers and service providers which process your personal information
Like most businesses, we may provide your personal information to third parties for processing as part of the services that those third parties carry out on our behalf as part of the day to day operations of our business. These trusted suppliers will process your personal information on our behalf and provide us with services such as the provision of certain HR-related functions, the provision of IT services, third party software providers, the hosting of your personal information and our accountants and professional advisers.
We will share your personal information with suppliers of services in respect of any property you reserve from us or the sale of the property from us to you. These third parties may include: estate and managing agents; financial and legal advisors; any relevant mortgage provider; the National House Building Council and similar organisations; utility and service providers; and local authorities.
We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal information and that they will only ever be allowed to use your personal information in order to provide us with services (and not for their own purposes). We require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.
Other scenarios in which we might share your personal information
We may also share your personal information:
with government authorities or professional bodies, such as HM Revenue & Customs in the United Kingdom (for tax purposes);
with our professional advisors including tax, legal or other corporate advisors who provide professional services to us;
with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;
in the event that we consider selling or buying any business or assets we will disclose your personal information to any prospective sellers or buyers of such business or assets;
in the event of any insolvency situation (e.g. administration or liquidation);
if we, or substantially all of our assets, are acquired by a third party, in which case your personal information will be one of the transferred assets;
to protect the rights, property or safety of our employees, workers, contractors, clients, or others. This includes exchanging your personal information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of our employee, worker, contractor and client safety, crime prevention, fraud protection and credit risk reduction; or
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
8. How do we protect your personal information?
In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
9. How long does we keep your personal information?
We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, tax, health and safety, reporting or accounting requirements. This means your personal data will be erased from our systems when we no longer need it.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you. In this case, we may retain such information for a longer period without further notice to you.
10. Your rights in connection with your personal information
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes so that our records can be updated. We cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.
Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights, below:
Right to be informed about how your personal information will be processed. This enables you to receive information about how we use your personal information. We have set this information out in this notice.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information (commonly known as the "right to be forgotten"). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.
11. Processing your personal information in other territories
Given the international location of some of our clients and suppliers, your personal information may be transferred in and out of the UK and the European Economic Area ("EEA") where local laws may not provide legal protection for personal data in the same way as is applicable in the UK or the EEA. Where your personal information is processed outside of the UK and EEA, we will ensure that we take the necessary steps to protect your personal information as required by data protection laws.
13. Third-party websites
Our Site may, from time to time, contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
14. Changes to this privacy notice
We reserve the right to update or amend this privacy notice at any time, including where we intend to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue you with a new privacy notice as soon as practicable when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways from time to time.
We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your data (our details are in the section immediately below). We will try to put things right.
However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to the UK's Information Commissioner's Office ("ICO"). You can contact the ICO at: First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or https://ico.org.uk/.
If you have any questions about this privacy notice or how we handle your personal information, please contact Louise Whitney – Sales & Marketing Manager as follows:
St Michael’s House
111 Bell Street
P: 01737 274828