Privacy Policy
Effective date: January 16, 2019
Coastal Management Ltd, here-in referred to as (“us”, “we”, or “our”), based at 99 Western Road, Hove, BN3 1FA, are registered with the ICO (Information Commissioner’s Office) under the registration reference: Z1659523.
This page explains how and when we collect and use your personal data throughvisiting our website https://www.coastalletting.com or using our services.
We use your data to provide and improve our service. By using our website or service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.coastalletting.com
Definitions
Service – Service is the management of properties, tenancies, enquiries and our website all operated by Coastal Management Ltd.
Personal Data – Personal Data means data about an individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data – Usage Data is data collected automatically either generated by the use of our website or from the website infrastructure itself (for example, the duration of a page visit, click through from third party websites).
Cookies – Cookies are small files stored on your device (computer or mobile device).Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our website.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes
Data Controller – Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers) – Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User) – Data Subject is any living individual who is using our service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our service to you.
Who The Information Is Processed About
Coastal Management Ltd process personal information about:
- Customers
- Tenants
- Professional advisers and consultants
- Complainants, enquirers
- Suppliers
- Landlords
- Employees
Types of Personal Data We Collect
While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Name, title, date of birth, marital status, gender,nationality
- Contact number, email address, home address (including previous addresses)
- Employment and education, salary information, other types of income such as benefits, length of employment or education, National Insurance Number
- Next of kin, guarantor, friends providing a reference
- Login information i.e. username and password, internet protocol address (e.g. IP address), browser type and version, browser plug-in types and versions, operating system, location data, the time and date of your visit,cookies, usage data, unique device identifiers and other diagnostic datareceived from devices to communicate with websites and applications using the internet which may identify an individual
- Financial details such as bank account and payment details, loans, adverse credit history
- All information required for referencing
- Marketing and communication preferences.
How We Collect Personal Data
There are a number of ways we collect personal information, depending on how you contact us. Ways in which we may collect this data would be through:
- Creating an account on our website
- Enquiring through our website
- Direct face-to-face contact in our office
- Verbal contact over the telephone
- Provide feedback
- Subscribe to marketing from us
- Applying for a property or our service
- Contact via a third-party website such as Rightmove, Zoopla, Gum Tree
- Contact via an external agent
- Transaction data from providers of payment services
How We Use Your Data
Coastal Management Ltd uses the collected data for various purposes. We are able to use this information under the following basis:
Contract – In order for us to for us to adhere to our contract in place with you such as our tenancy agreement.
Legitimate – So that we can recover debts, develop and improve our service, train our staff in order to keep up to standards, keep our records up to date, resolve disputes, prevent illegal activity, run our business and services, monitor and study how our service is being used.
Consent – To provide marketing and advertising information or goods and services which may be of interest to you.
Legal – To update you on changes to our service, identify a person living in a property let by us and verify your identity, prevent and detect fraud, comply with requirements imposed by law such as logging of a deposit, court orders.
Ways We May Use Your Data
- To provide and maintain our service – Contract and Legitimate
- To carry out property maintenance services – Contract
- To carry out referencing – Legal, Legitimate and Contract
- To notify you about changes to our service – Legal and Legitimate
- To promote and advertise our services – Consent
- To allow you to participate in interactive features of our service when you choose to do so – Consent
- To provide customer support – Contract and Legitimate
- To maintain our own accounts and records – Legitimate
- To gather analysis or valuable information so that we can improve our service to you – Legitimate
- To monitor the usage of our service – Legitimate
- To detect, prevent and address technical issues or fraud – Legal and Legitimate
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information– Consent
Data for Marketing
We may use your Personal Data to contact you with newsletters, marketing or promotional
materials and other information that may be of interest to you.
You may opt out of receiving any, orall, of these communications from us by contacting us by email at info@cmlet.com.
Please note, if you have requested further information regarding a property or our services but haven’t opted in to receive marketing information from us, we will still use your Personal Data to contact you to address your questions and queries.
Retention of Data
Coastal Management Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, for up to 7 years for accounting, legal and regulatory purposes.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Coastal Management Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Coastal Management Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Coastal Management Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Coastal Management Ltd
- To prevent or investigate possible wrongdoing in connection with the service
- To protect the personal safety of users of the service or the public
- To protect against legal liability
Service Providers (third parties)
We may employ third party companies and individuals to facilitate our service (“Service Providers”), provide the service on our behalf, perform service-related services or assist us in analysing how our service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Such third parties include:
- External agents: Other letting or estate agents who advertise properties on our behalf, arrange viewings for said property, recommend potential applicants, carry out our service on our behalf when it is not possible for us to do so due to location or emergencies.
- Referencing agents: To carry out background checks and other referencing requirements on our behalf such as credit checks, affordability checks.
- T. and technical support companies: To assist with any operational issues using a computer or other technical device, improve our service including that of our systems and website.
- Deposit protection service: To log and protect the deposit paid by the tenant in the interest of the Landlord and Tenant but also for legal reasons.
- Contractors: Who will carry out repair or improvement works to a property and to contact you to arrange an appointment.
- Insurance companies: To make a claim due to loss of rent, damage to a property.
- Debt collecting agencies or Bailiff: In order to locate an individual to recover debts.
- Utility companies: To advise of new, existing or previous tenants in order for them to update their billing records and recover debts.
- If we enter into a joint venture or merge with another business
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Links to Other Sites
Our website may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Security of Data
During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner.
Coastal Management LTD take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We are responsible for ensuring that the data handling policy is followed by the members of the establishment and respect the GDPR. Our staff are responsible for their safe handling of the offices available, and potentially sensitive data. Staff need to adhere to the GDPR. As with staff members of Coastal Management Ltd, directors will need to adhere to the same rules as other members of staff when, as part of their role, they have access to data. We ensure all members of staff comply with GDPR by undertaking staff training.
If we detect a data breach, we will inform the ICO within 72 hours.
Children’s Privacy
Our service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Coastal Management Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at info@cmlet.com.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Coastal Management Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
England:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Scotland:
The Information Commissioner’s Office
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk
Wales
Information Commissioner’s Office
2nd floor, Churchill House
Churchill way, Cardiff, CF10 2HH
Telephone: 029 2067 8400
Email: wales@ico.org.uk
Northern Ireland:
Information Commissioner’s Office
3rd Floor, 14 Cromac Place
Belfast, BT7 2JB
Telephone: 028 9027 8757
Email: ni@ico.org.uk
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details.
Our data protection officer is: Alex Beattie
If you have any questions about this Privacy Policy, please contact them:
- By email: info@cmlet.com
