Privacy Policy

1. Introduction

Winkworth Franchising Limited (“WFL”) is a company registered in England and Wales with company registration number 0395011, whose registered office is at 4th Floor, 1 Lumley Street, London W1K 6TT. Our registered VAT number is 802 4915 49.

All of the Winkworth offices are independently owned and operated by franchisees (“Franchisee(s)”) under licence from WFL as the franchisor. In this privacy policy, references to “we” or “us” shall be deemed to mean WFL and its subsidiaries, any holding company of WFL and its subsidiaries and the Franchisees (whether separately or altogether).

We are committed to protecting your personal data. This privacy policy gives you detailed information on when and why we collect your personal data, how we use it and how we keep it secure. Please read this policy carefully alongside our Cookie Policy and our Data Retention Policy to understand our views and practices regarding your personal data and how we will treat it.

More information can be provided on request. Definitions, and words in bold type, are defined in the Appendix at the end of this privacy policy.

2. Our responsibilities

For the purposes of the applicable Data Protection Legislation, we are the data controller of any personal data we process. As a data controller, we are responsible for ensuring our systems, processes, suppliers and People comply with Data Protection Legislation in relation to the personal data we handle.

We provide our People with training and require our People to comply with this privacy policy, our Cookie Policy and our Data Retention Policy when dealing with personal data.

We take Personal Data Breaches very seriously, and are required to notify the Information Commissioner’s Office in the event of such a breach.

When using, collecting and disclosing personal data, we follow the core data protection Principles underlying the Data Protection Legislation.

We have policies, procedures and records to demonstrate compliance with the Principles. Please contact us for further information on these policies, procedures and records.

3. How we collect, use and disclose your personal data

Generally, we collect your personal data when you interact with us (for example, when entering into a relationship with us as Customer, a third party service provider or one of our People). However, from time to time we also need to collect personal data from other third parties in connection with our relationship with you. We also look at how our users access and use our Website, so we can offer the best possible experience. The following tables, available by clicking the dropdowns, summarise how we collect, use and disclose your personal data:

Winkworth Customers

Types of personal data

Collection

Purpose

Disclosure

Retention Period

​Information such as:

  • your name;
  • your postal and email address;
  • your phone number(s);
  • information regarding your moving situation;
  • personal identification documentation;
  • financial information:
  • as evidence of proof of funds (buyers and tenants);
  • to transfer funds (landlords); and
  • to reimburse funds (tenants),
  • images/photographs of your property (vendors and landlords);
  • information regarding your employment status and salary (buyers and tenants); and
  • reviews/feedback from tenants (landlords).   

Your personal data will be collected from various sources including:

  • when you contact us (through one of our departments and/or our Associated Agents) via email, telephone or in person;
  • providers of background checks;
  • notes and records kept for the duration of your engagement with us as a Customer (including details of any instructions, complaints and meetings with us regarding our relationship and your engagement as a Customer);
  • CCTV while on our premises;
  • from property portals (such as Rightmove); and
  • publicly available sources.

Your personal data will be used for the following purpose:

  • delivering and improving the services we provide to you;
  • internal administration and management purposes;
  • fulfilling our contractual obligations;
  • fulfilling our legal obligations; and
  • where you have given us your clear, unambiguous consent to do so, your personal data may be used to contact you about and provide you with:
  • communications and/or marketing material for which you have specifically subscribed; and/or
  • to contact you about, and provide you with, the communications we think are relevant to your interests and preferences.

Photographs and images of your property (internal and external) may be used in our marketing and promotional material including our Website only where you have given us explicit consent to do so. Often you will have given this consent as part of formalising our engagement.  

Your personal data may be transferred to:

  • our third party service providers  who support the operation of our business;
  • other parties involved in the transaction, for the purposes of fulfilling our contractual obligations;
  • Associated Agents, for the purposes of fulfilling our contractual obligations;
  • other third parties such as our legal and other professional advisers and government departments; and
  • where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you.

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

Please refer to our Retention Policy.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

 

Service Providers

Types of personal data

Collection

Purpose

Disclosure

Retention Period

Information such as your:

  • name and business information;
  • name and email address of your representatives;
  • identification documentation; and
  • payment details.

Your personal data will be collected from you directly.

Further information (e.g. to verify your identity) may be collected from third parties, such as publicly available sources.

Your personal data will be used for relationship management and file opening, administration, to fulfil our contractual obligations and as required by law (e.g. anti money laundering).

Your personal data may be disclosed to:

  • our Customers; and
  • our Associated Agents,

for the purposes of fulfilling our contractual obligations.

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.  

Please refer to our Retention Policy.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

 

Subscribers to our promotional material

Types of personal data

Collection

Purpose

Disclosure

Retention Period

Information such as your:

  • name and business information;
  • email address;
  • job title; and
  • who you work for.

Additional information may be processed where it is provided by you, for example:

  • in correspondence, in connection with any properties, or
  •  in letting us know your interests and how/when you wish to be contacted by us. 

Your personal data is collected when you register and ‘opt in’ to receive:

  • marketing/promotional material;
  • information and updates about our properties; and
  • details of events.

You can contact us at any time to amend your preferences or opt out of communications from us. You will also be sent the option to opt out of future communications in every communication you receive from us.

Where you have given us your clear, unambiguous consent to do so, your personal data will be used to:

  • contact you about, and provide you with, the communications we think are relevant to your interests and preferences; and
  • understand our subscribers’ preferences and interests so we may improve our services, communication and marketing material. 

Your personal data may be transferred to our third party service providers who support the operation of our business.
Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you.
We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

Please refer to our Retention Policy.
We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

 

Users of our Website

Types of personal  data

Collection

Purpose

Disclosure

Retention Period

Information such as:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, type of device used to access our Website and the location of where you access our Website via a mobile device;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), products 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 and any phone number used to call our customer service number; and
  • your name and  email address/other contact details.

Your personal data is collected when you:

  • use our Website (e.g. browsing, searching);
  • provide us with personal information to enable us to contact you and let us know of your marketing preferences; and
  • contact us via email
  • contact us using our online forms.

Your personal information is used to:

  • tailor and enhance your user experience;
  • improve the functionality of our Website;
  • ensure our Website caters to our users’ preferences;
  • contact you about, and provide you with, the communications we think are relevant to your interests and preferences; and
  • contact you and provide you with information about our services.

Your personal data may be transferred to our third party service providers who support the operation of our business.

Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to carefully selected third parties (including but not limited to Facebook) who may process your personal data to provide you with information about properties and/or property related services.

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

Please refer to our Retention Policy.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

 

Our People and People making applications to become our People

Types of data

Collection

Purpose

Disclosure

Retention Period

Personal data such as

  • your name, address, contact details, education and employment history;
  • background checks (financial and criminal);
  • identification documentation;
  • right to work status;
  • information relating to next of kin/ dependants; and
  • financial information including bank details and identifiers (e.g. National Insurance numbers).

We may also process sensitive personal data such as health details, racial origin, religious beliefs and information about offences/ alleged offences.

Your personal data will be collected from various sources including:

  • your application form/CV;
  • recruitment agencies and websites;
  • providers of background checks;
  • notes and records kept for the duration of your employment (including absences, appraisals, disciplinary action);
  • providers of occupation health services; and
  • CCTV and security access devices.

Your personal data will be used for the following purposes:

  • human resources administration;
  • assessing suitability/eligibility and/or fitness to work;
  • security; and
  • training.

Photographs and images of you, your name, and information about your education and employment may be used in our marketing and promotional material including our Website and pitches to Clients.

Your personal data may be transferred to

  • our third party service providers  who support the operation of our business;
  • our Customers; and
  • our Associated Agents,

for the purposes of fulfilling our contractual obligations.
We shall only transfer personal data to a third party which has been limited to the relevant purpose.

Please refer to our Retention Policy.
We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

 

4. Transfers of personal data

Personal data may be transferred to one of our Associated Agents for the purposes of fulfilling our obligations to our Customers.

We also use a number of suppliers in connection with the operation of our business and they may have access to the personal data we process.  For example, an IT supplier may collect data on our behalf and/or see our personal data when providing software support, or a company which we use for a marketing campaign may process contacts' personal data for us.

When contracting with suppliers and/or transferring personal data to a different jurisdiction, we take appropriate steps to ensure that there is adequate protection in place and that the Principles are adhered to.

All Winkworth offices are independently owned and operated. We operate as a network of estate agent offices, including offices in Europe and our China Desk, and therefore the data you provide to us may be transferred within the network for the applicable Purpose. For example, if you are looking to purchase a property and you give your personal data to one of our offices for that purpose, that office may share your details with other offices to enable us to send you details of other properties which may be of interest to you.

5. Your rights

Personal data must be processed in line with an individual’s rights, including the right to:

  • request a copy of their personal data;
  • request that their inaccurate personal data is corrected;
  • request that their personal data is deleted and destroyed when causing damage or distress; and
  • opt out of receiving electronic communications from us.

Should you wish to make a request in line with your rights as an individual, please contact us as follows:

If you are:
A Winkworth customer - please contact the Winkworth office you have registered with, or, alternatively, your local Winkworth office .

A Service Provider - please contact the Winkworth office you are working with, or, alternatively, your local Winkworth office.

A Subscriber to our promotional material - please contact the Winkworth office you have registered with, or, alternatively, your local Winkworth office.

A User of our Website – please contact This email address is being protected from spambots. You need JavaScript enabled to view it..

One of our People or a person making an application to become one of our People – please contact the Winkworth office that employs you or with whom you have been dealing, or Winkworth’s recruitment team.

Anybody else – please contact the Data Protection Office.

The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation (as applicable).

6. Security

Information security is a key element of data protection.  We take appropriate measures to ensure our systems, processes, suppliers and People secure personal data and protect it from loss or unauthorised disclosure or damage. Please contact us if you require further information regarding our policy and approach to information security.

7. Computer Security

Keep yourself safe from malware and viruses with adequate, up to date security on your computer. You can usually download free basic protection from providers such as AVG and McAfee, but for more comprehensive cover, it's best to choose security software. Keep your software switched on and up to date, and make sure that your operating system has the latest updates. It's a good idea to run regular scans on your computer.

When you're opening emails, be careful. Don't click on links to download files or open attachments you haven't asked for, or aren't expecting, as they may contain viruses. Back up all your files so they're available if the worst happens and your computer is infected by a virus.

8. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.  For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

9. Consent to marketing

Where we wish to transfer your personal data to third parties who are not involved in the provision of our services (for example, mortgage providers and providers of legal services) but who we consider might interest you, we will always ask you to give your consent. Where you give us such consent (e.g. you tick the relevant consent box when registering in person at one of our offices), but you then decide/omit to provide consent at a subsequent opportunity (e.g. you later re-register online and do not tick the relevant consent box, having previously ticked an equivalent consent box in our office) you will be deemed to continue to consent until you contact us to formally confirm you wish to withdraw your initial consent (which you can do at any time).

10. Changes to our privacy policy

We keep our privacy policy under regular review. If we make changes to our Privacy Policy that affect how we handle your data, we will let you know by email. Minor changes will not be notified. You can check our Privacy Policy at this page at any time. 

11. Questions, comments and complaints

Questions, comments and complaints regarding this privacy policy should be addressed to:

The Data Protection Office
Winkworth Franchising Limited
4th Floor, 1 Lumley Street
London
W1K 6TT


or by writing to us at This email address is being protected from spambots. You need JavaScript enabled to view it.


Our People must inform our Data Protection Office immediately if they receive a complaint relating to how we have processed personal data so our complaints procedure can be followed.

Appendix

Associated Agents: estate agencies in the UK and also in jurisdictions outside of the UK who have either:

(a) engaged us to provide estate agency services on their behalf in the UK.; or

(b) been engaged by us to provide estate agency services on our behalf in a jurisdiction outside of the UK.

China Desk: a WFL department dedicated to providing a full property service to Chinese clients looking to buy and sell in Europe.

Consent: means the freely given, specific, informed and unambiguous consent given by a data subject in relation to his/her personal data being processed.

Controller: a personal/organisation who determines the purpose for which, and the manner in which, any personal data is processed.

Customer: a current or prospective Winkworth customer being a vendor, buyer, landlord or tenant.

Data Protection Legislation: the Data Protection Act 1998 and any other applicable laws relating to the processing of personal data including the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all related regulations, regulatory codes of practice, opinions and guidance issued from time to time, including by the Information Commissioner, and in each case any amending, superseding or replacement applicable law including (from and including 25 May 2018, where applicable) the General Data Protection Regulation 2016/679/EU.

People: all people providing services to or working for us, including but not limited to our employees, directors, members, Franchisees and contractors.

Personal data: information (including opinions) which relates to an individual and from which he or she can be identified either directly or indirectly through other data which we have or are likely to have in our possession. These individuals are sometimes referred to as data subjects.

Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by an organisation electronically. A personal data breach may mean someone outside the organisation gets unauthorised access to personal data, but a breach can occur if there is unauthorised access within the organisation or if an employee accidentally alters or deletes personal data.

Principles: these core principles specify personal data should be: processed lawfully, fairly and in a transparent manner; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and, where necessary, kept up to date; kept for no longer than is necessary; processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. Additionally, organisations must adhere to the principle of accountability.

Process: the ‘processing’ of personal data captures a wide range of activities, and includes obtaining, recording and holding personal data and performing any operation of the personal data (including erasure/destruction).

Processor: any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

Purpose: the purposes identified in the “Purpose” column of the tables in section 3 of this privacy policy (How we collect, use and disclose your personal data), as applicable.

Sensitive personal data: data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.

Third party: a person, organisation or other body other than the data subject, controller or processor.

Website: www.winkworth-international.com (including all pages linked within the site map).

 

Last updated 22 May 2018