Privacy Policy

We currently collect and process the following information:

• Personal identifiers, contacts and characteristics (for example, name and contact details) and company details if applicable
• Telephone numbers and email addresses
• Information to enable us to check and verify your identity, for example your date of birth
• Your gender information, if you choose to give this to us
• Your billing information, transaction and payment card information
• Your professional or personal online presence, for example LinkedIn profile, social media profiles if you choose to share it with us
• Your contact history, transaction and instruction history with us
• Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, for example if you are a prospective tenant
• Information to enable us to undertake Anti Money Laundering and Terrorist Financing electronic checks on you
• Information about how you use our website, IT, communication and other systems
• Your responses to surveys, competitions and promotions

All of the information we ask is in relation to a specific process or various processes where the information is required in order for us to serve you efficiently. Failure or delays in providing information may result in a delay or inability to provide you with our service.

Most of the personal information we process is provided to us directly by you by phone, text, WhatsApp, email, in person and via our website/App/Portal.

We also receive personal information indirectly, from the following sources in the following scenarios:

• From Companies House or HM Land Registry to verify ownership of property and Directorship of companies and to verify identity.
• Sanctions screening providers, Credit referencing agencies and Customer Due diligence agencies for Anti Money Laundering reasons, to ascertain suitability of a prospective tenant/s and Customer for performing background checks and other screening on the customer to ensure that they are properly risk-assessed before being onboarded
• Property search portals such as but not limited to Rightmove & Zoopla

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.
• 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. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where it is necessary for us to comply with  legal and regulatory requirements.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via telephone, post, email or other electronic means. You have the right to withdraw consent to marketing at any time by contacting us.

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our Service - these cookies are essential to enable use of the Website, they manage session information and enable users to navigate through the Website.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

We may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We may have to share your personal data with the parties set out below for the purposes set out in the above table under ‘reasons for using your personal data’

• Any anti money laundering check providers, who in turn engage with Experian and Equifax
• Contractors;
• Mortgage brokers;
• Solicitors;
• Surveyors;
• Photographer/Floorplanner/EPC engineers;
• For Sale/To Let Board Companies;
• Zero Deposits, provider of tenancy deposit guarantees;
• Inventory Clerks;
• Tenant/Guarantor Refencing Companies;
• Utility providers – Tenants of managed properties will have their contact details sent to providers in order that an account can be set up in their name;
• Third parties involved in your transaction e.g. Landlords, Vendors, Tenants or Purchasers;
• Third parties with whom we need to work with in order to perform our contract with you;
• Fee recovery/debt collectors;
• Local authorities & government enforcement agencies;
• Deposit schemes;
• Other agents for the purpose of receiving due commission if we introduce you to a property and they later; and
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
• Should the situation arise then we will share your name and contact details with NHS Track & Trace.

We require any third parties which we have contracted with 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.

The information we collect from or about you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the processing of your payment details and the provision of support services. By using our website, or otherwise submitting your personal information to us, you agree to this transfer, storing or processing. Wren & Co Residential Ltd will take reasonable steps to ensure that your data is treated securely and in accordance with the General Data Protection Regulation (GDPR).

Once we have received your information we will use strict procedures and security features to try and prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of information transmitted to our site. Any transmission is at your own risk and you agree that we will not be liable for any breach of security unless it has been proved that we have been negligent. We do not accept any responsibility for the protection of information or images provided to third party online sites that link to or from our website

Information may be held at our offices as well as third party service providers and representatives as described. We have security measures in place to seek to ensure that there is appropriate security for information we hold.

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We hope that any concerns or queries can be easily and quickly resolved by speaking to us about the use of your information. If you have any concerns about our use of your personal information, you can make a complaint to us on the details below under ‘How to contact us’

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted via post, or by phone to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF - Phone 0303 123 1113 website: https://www.ico.org.uk

This privacy policy was completed and published on 28th April 2022. Every now and again we may make amendments to our policy. When we do we will update our website for your information on www.wrenresidential.com

You can contact us by the methods laid out below if you have any questions about our privacy policy or the information we hold about you.

Wren & Co Residential ltd
Company Registration Number 13837600
1 College Yard, 56 Winchester Avenue, London, NW6 7UA
0207 871 2820
info@wrenresidential.com
www.wrenresidential.com
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