1. Who we are

This Privacy Policy applies to the use and processing of personal data collected by Hadleywoods, a trading name of Turabi Ltd. The ICO Registration number of Turabi Ltd is ZB166247

The phrases “us”, “we” or “our” will mean Turabi Ltd – on behalf of and in respect of whom this Privacy Policy is made.

For information concerning the collection, use and processing of personal information by any of our third-party business partners or suppliers, please email us at [email protected] or call our Head Office on 0800 099 6072 Monday-Friday 8:30am to 5:30pm). 

2. Information covered by this Privacy Policy

(i) Personal data – This is information, or any combination of separate pieces of information, that could be used to identify you;

(ii) Special categories of personal data – This is information classified as sensitive (such as details regarding your health or more detailed financial information).

If you have any questions about this notice or our use of your personal data, please contact the Hadleywoods Data Protection Officer by email to [email protected] or in writing to Turabi Ltd, 15A Wellington Road Enfield London EN1 2PD

3. Where we get personal information from

When you enquire or register for products and services provided by Hadleywoods, we may collect personal information from a variety of sources, including:

• Information we collect directly from you, either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet;
• Information we collect when you visit or create an account on our websites;
• Information provided to us by third parties;
• Information from publicly available sources, for example, Land Registry.

4. What information we collect

4.1 Information we collect directly from you

Depending on the type of service or product we are discussing, the following are examples of information we may collect directly from you:

• Name;
• Date of birth;
• Email address;
• Current residence address;
• Past residency address(es);
• Right to live in the UK;
• Telephone number;
• Information about the reason for selling your property;
• Information about your family;
• Information about your health;
• Credit history;
• Financial information, such as earnings and outgoings;
• Payment information, such as a credit card and bank account details;
• Your communication and marketing preferences.

We may, as part of your relationship/ongoing communication with us, request additional information from you which is relevant to the provision of specific services.

Any telephone calls either to or from our customer service teams may be recorded for training, monitoring, compliance and security.

4.2 Information we collect when you visit our websites

We use cookies and other technologies to collect information when you visit our websites, including when you make use of our online chat service. Details of how we use cookies are provided in Section 13 ‘Our Use of Cookies’.

4.3 Information we obtain from third parties 

Where required by law, or for business needs, we will obtain information about you from third parties, but only after we have your agreement to do so.

Third parties we may need to contact may include (but are not limited to) credit reference agencies, financial advisors, banks, employers, accountants and solicitors.  Our objective for doing so will typically be to obtain references, undertake identity / basic criminal record verification, validate your income, check other financial history and our own database management.

We may also receive information from the following third-parties:

• Social Media Companies including Facebook, Twitter, Google+ when you interact with our brand through these platforms;
• Live chat suppliers partnered with us through the applications hosted on our website;
• Enquiries through licensed property portals when you request further information on a property or request information;
• Other agents/companies as and when required for purposes which will be disclosed.

5. Who we share your information with

We may share your information both within Hadleywoods and also relevant third-party business partners.

Where we engage third party service providers to provide products or other business services and operations, we provide them with only the personal information they need to perform the service we request.  Relevant service providers may include:

• Mortgage brokers we are partnered with for mortgage services and advice;
• Independent financial advisors for advice relating to your property and the services we offer;
• Solicitors and conveyancing agents for legal advice relating to your property and the services we offer;
• Surveying companies for services required for the sale / purchase of your property;
• House and contents / family protection insurances
• Other insurance and warranty companies where you have decided to buy a product or service through us.

We will only pass personal information to a third party with your full and explicit authorisation. We contractually require them to securely protect information, and not to use it for any other purpose.

6. How we use your information

We will process the information you provide us to provide the best possible service and answer any questions you may have.  With your explicit permission, we may obtain relevant information from other sources to provide you with products and services.

The following are examples of how we use the information we collect:

• To process your registration and confirm your identity;
• To provide a full range of estate agency services for the sale and purchase of property;
• To arrange surveys and/or valuations;
• To arrange mortgages;
• To arrange protection insurances;
• To provide conveyancing services;
• To provide will writing and associated legal services;
• To provide property auction services;
• To create and manage your online account;
• To process payment for our services;
• To protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent or franchise quality, integrity, compliance and security of business processes;
• To arrange for the transfers of funds by or to third parties
• To provide, administer and communicate with you about Hadleywoods services, services, offers, programs and promotions, their issuers, acquirers, retailers and partners;
• To compile business directories, including business contact information;
• To help us monitor, improve and protect our products, content, services and websites, both online and offline, including as set out in our Cookie policy (see Section 13);
• To personalise our website, products or services for you, including as set out in our Cookie (see Section 13)
• If you provide a credit or debit card as payment, we and our Franchisee also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud
• To investigate any complaints received from you or from others, about our services or the properties which we deal with;
• To investigate legal claims, compliance and regulatory issues (including disclosure of such information in connection with legal process or litigation);
• To invite current and previous clients to take part in market research and contribute reviews regarding our service.

6.1 Customer surveys

From time to time we may provide your information to our customer service agencies for research, survey and analysis purposes so that we can monitor and improve the services we provide.

We or our agents and sub-contractors may occasionally contact you including by post, email or telephone to ask you for your feedback and comments on our services.

6.2 Information about our products and services

With your explicit permission, we may also use your personal data to contact you by post, email, telephone or other electronic means to provide you with information about products and services from Hadleywoods and carefully selected third parties which we feel may be of interest or relevant to your needs.

Please see Section 12 for information about how you can exercise your rights.

6.3 Credit scoring

Some of the services provided by third parties may involve an automated decision and/or credit scoring to determine whether we are able to provide a service or product.

Using third parties to undertake searches and collate information on our behalf helps make fair and responsible decisions. When coming to these decisions we and third parties will consider:

• The information provided on the application form;
• Information about previous account conduct, including any payment arrears and;
• Official public records information such as fraud record information and insolvency records.

Any credit scoring methods used by third parties are regularly tested to ensure they remain fair, effective and unbiased.

For further information about automated decisions or credit scoring, please contact the Hadleywoods Data Protection Officer by email at [email protected]

7. Lawful basis of processing

Hadleywoods processes your information under any of the following lawful conditions:

(i) Performance of a contract – This is where the collection and processing of your data is necessary for the performance of a contract with you, or to take steps at your request prior to entering into a contract;

(ii) Legal obligation – This is where the collection and processing of your data is necessary for compliance with a legal obligation, for example, verification of identity and fraud prevention;

(iii) Consent – Where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example, to receive marketing information from Hadleywoods;

(iv) Legitimate interests – Some information is processed by Hadleywoods as part of its legitimate interests which include network and information security, opting out of communications, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided;

(v) Law enforcement – We will provide information in response to requests by government or law enforcement authorities, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

8. Other situations

We may transfer or otherwise process your personal information:

• As part of the sale of a Hadleywoods to another company;
• When we have received your instruction to pass the sale of your property to another agent;
• To enforce our terms and conditions;
• When required by law and/or government authorities;
• When requested by The Property Ombudsman scheme or any other consumer ombudsman or trade association.

9. How long we keep your information for

We will keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Policy, and to fulfil our legal and regulatory obligations.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

For further information about how long we will keep your information, please contact the Property Data Protection Officer by email at [email protected]

10. When we communicate with you

We will send you service-related communications.

We may also contact you in order to provide you with information about our products and services which we believe may be of interest to you, and which relate to your needs.

11. How we communicate with you

For service related communications, we will contact you either by email or through the post. We may also telephone you or send you SMS (text) messages, which may include automated SMS (text) reminders for viewings and other appointments.

We give you choices about how we communicate promotions and offers to you.

11.1 By email

You may provide us with your name and email address for the purpose of receiving our email newsletter.  These are stored with our newsletter service provider Aweber.

We may use these details to send you promotional emails relating to the products and services we offer that we feel may be of benefit/interest to you. You may unsubscribe from these at any time by following the “Unsubscribe” link at the bottom of the message.

You may also contact us to request your name and email be permanently removed from our records at Aweber via info@hadleywoods.co.uk or calling our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

11.2 By post

We only send you promotional postal mail if you explicitly select to receive these (you opt in). You can stop receiving promotional postal mail from Hadleywoods contacting via email at info@hadleywoods.co.uk or calling our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

11.3 Mobile Text Messages

We will only send you promotional text messages if you explicitly select to receive these (you opt in). You can stop receiving promotional text messages from Hadleywoods by following the opt-out instructions provided in the text message, contacting us via email at [email protected] or calling our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

11.4 Telephone

We will only contact you by phone for promotional reasons if you explicitly select to receive these (you opt in). You can opt out of receiving promotional telephone calls from Hadleywoods by informing our telephone agents / staff / Area Managers, contacting us via email at [email protected] or calling our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

12. Your statutory rights

12.1 Your personal information

You have a number of rights concerning the personal information we use. These include the right to:

• Ask us for access to a copy of your personal information we hold about you;
• Ask us to correct your personal information;
• Ask us to delete your personal information.

You can request for us to delete any personal information in your account that we have about you, and it will mean any data about how you’ve used the online account will be made anonymous.

However, deleting your online account will not delete any data you’ve shared with us for reasons that are not connected with your online account. If you wish us to delete your data which is unconnected with your online account, please contact us via email at [email protected] or call our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

12.2 Withdraw your consent to use your personal information

Under the terms of the Privacy Policy, you can:

• Ask us to correct, delete or restrict the use of your personal data, including direct marketing;
• Object to our use of your personal data;
• Object to an automated decision, including profiling (for example, in terms of credit risk);
• Obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller;
• Lodge a complaint with the Information Commissioner’s Office, if you object to the way we use your personal information. For more information please go to ico.org.uk.

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data in relation to good or service we are still contracted to provide.

If you would prefer not to receive information from Hadleywoods or carefully selected third parties you can opt out by contacting us via email at [email protected] or calling our Head Office on 0800 099 6072 (Monday-Friday 8:30am to 5:30pm).

You can also update your marketing communication preferences in the emails sent from [email protected].

We will act to respond to your request to stop receiving promotional email, phone, text or postal messages from Hadleywoods as quickly as is practicable (approximately 10 working days).

We will keep information for record keeping purposes to ensure we fulfil your request not to send particular types of messages.

If you wish to make a request for access to a copy of your personal data or exercise any of your other rights, please write to Hadleywoods, 15A Wellington Road Enfield London EN1 2PD or email [email protected]

We will acknowledge your request and let you know what we will need from you to carry out your request. Every effort will be made to respond to or comply with your request as quickly as possible, and we will ensure our systems are updated as soon as is practicable in response to your request.

13. Our use of cookies

13.1 What are cookies?

A cookie is a small file placed on your device when you visit a website that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and to store your preferences when using a particular site. It may contain a unique identifier to ensure that you are not shown the same information and/or are only shown information you have stated that you are interested in.

Other tracking technologies are also used (similar to cookies) include pixel tags and tracking URLs.

A cookie records your preferences when using a particular site, ensuring that you are not shown the same information and/or are only shown information you have stated that you are interested in. In order to use the Hadleywoods site www.hadleywoods.co.uk you agree to let cookies be saved as they are an important part of navigation of the Site.

The following are examples of information we may collect:

• Information about your device browser and operating system;
• Your internet protocol (IP) address used to connect your computer to the internet;
• Browser type and version
• Time-zone setting;
• Operating system and platform;
• Information about your visit to the co.uk website including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); embedded links; pages you viewed or searched for; 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 away from the page.

13.2 Third party cookies used on the site

We may use cookies, tracking pixels and similar technologies on our website to gather data about our visitors’ use of our website.

The types of Cookies we use on the www.hadleywoods.co.uk website, and the purposes for which they are used, are set out below:

(i) Strictly necessary cookies: These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our site.

(ii) Analytical/performance cookies: These cookies collect information about how you and other visitors use our site, for instance which pages you go to most often, and if you get error messages from web pages. We use data from these cookies to help test designs and to ensure a consistent look and feel is maintained on your visit to the website. All information these cookies collect is aggregated. We use this data to improve your experience of our website, to analyse the visitors’ use of the site and to provide you with relevant, interest-based marketing.

• We use Google Analytics to anonymously track website usage and activity. Google Analytics is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymisation, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB;
• You can refuse the use of Google Analytics by downloading the following add on: https://tools.google.com/dlpage/gaoptout. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting hadleywoods.co.uk;
• Further information concerning the terms and conditions of use and data privacy can be found at https://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking);

(iii) Security cookies: Our security software may use your IP address and browser version to help protect our systems and provide diagnostic information in the case of an issue;

(iv) Functionality cookies: These cookies allow our site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.  These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting.  The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

(v) Targeting cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies are dropped only with your consent. You can give your consent either by closing the cookie banner displayed at the bottom of the landing page of our website or browsing the website outside the cookie banner and clicking on any of its item. Please note that we track your consent using a technical cookie; therefore, in the event you delete any cookies stored on your devices you see the cookie banner once again. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

(vi) Social media cookies: These cookies allow you to share what you’ve been doing on our Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

(vii) Pixel tags: Also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of our Site but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.

(viii) Tracking URLs: These are used to determine from which referring website the website is accessed.

If you do not want to allow Cookies at all, or only want to allow use of certain Cookies, please refer to your browser settings. You can also use your browser settings to withdraw your consent to our use of Cookies at any time and delete Cookies that have already been set. Please note that by deleting our cookies or disabling future Cookies you may not be able to access certain areas or features of our site.

To find out more about Cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.  We are also happy to answer any questions you have via email at [email protected]

14. How we protect your information

We store your personal information on our computer systems and in our paper records.

We have implemented strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information.

The information that we collect is stored in a secure facility with restricted physical access.

We also use a number of security measures to prevent electronic access.

Where, in line with this Privacy Policy, information is shared with third parties, similar security measures are used to protect your information.

15. Data transfers

We ourselves do not currently transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

If, in the future, we or our partners need to transfer your information to recipients in other countries we will:

(i) Perform those transfers in accordance with the requirements of applicable law and subject to appropriate safeguards; and

(ii) Protect the transferred personal information in accordance with this Privacy Policy.

16. Children’s privacy

We do not offer any products or services to children. In certain circumstances (for example a mortgage application) we may need to collect the name and date of birth of children from mortgage applicants and share this with the selected mortgage provider.

17. Links to other websites

Our websites, other electronic portals and documentation may provide links to other websites for your convenience and information. These may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review.

Where linked websites are not owned or controlled by us, we are not responsible for their content or data privacy practices.

18. Our Promise to you

When you provide us with this information, you agree to the collection, use and sharing of your information in accordance with this data Privacy Policy. Our promise to you is that

• We’ll work with other businesses to put together offers we think you might like;
• You are in control of your data;
• You can change your privacy settings at any time;
• If you don’t think the data is correct tell us and well put it right;
• We will keep your data secure;
• We also promise to collect, process store and share your data safely and securely and to make sure the businesses we work with do the same.

19. Updates to our Privacy Policy

We will occasionally update our Privacy Policy, so we suggest that you review this Notice from time to time. If we make substantial changes to our Privacy Policy, we will endeavour to inform you directly about these changes.