Privacy Policy Introduction Welcome to Cavanna Homes’ privacy policy. Cavanna Homes respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and during its provision of services to you and tell you about your privacy rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. IMPORTANT INFORMATION AND WHO WE ARE THE DATA WE COLLECT ABOUT YOU HOW IS YOUR PERSONAL DATA COLLECTED HOW WE USE YOUR PERSONAL DATA DISCLOSURES OF YOUR PERSONAL DATA INTERNATIONAL TRANSFERS DATA SECURITY DATA RETENTION YOUR LEGAL RIGHTS 1. Important information and who we are Purpose of this privacy policy This privacy policy aims to give you information on how Cavanna Homes collects and processes your personal data through your use of this website and during its provision of services to you. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them. Controller For the purposes of this policy, the term “Cavanna Homes” comprises the following legal entities: Cavanna Homes Limited Cavanna Homes (Cornwall) Limited Cavanna Homes (Devon) Limited Cavanna Homes (South West) Limited Cavanna Homes (Torbay) Limited Cavanna Group Management Services Limited This privacy policy is issued on behalf of the above companies, so when we refer to “Cavanna Homes”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the list above responsible for processing your data, each of which is processing your data in their capacity as a data controller. Changes to the privacy policy This policy was last updated on 24th May 2018. Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, including any changes to your opt-ins, by contacting us at salesprivacy@cavannahomes.co.uk. Exercising Your Rights We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Data Privacy Manager Cavanna Group Limited Cavanna House, Riviera Park, Nicholson Road, Torquay TQ2 7TD Email: dataprivacy@cavannahomes.co.uk You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 2. The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data includes first name, last name and title. Contact Data includes residential address, plot number, email address and telephone numbers. Financial Data includes bank account and/or payment card details. Transaction Data includes details about payments to and from you in relation to property transaction(s) and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does NOT directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data to compile market research relating to property transactions. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, a reservation or contract for sale). In this case, we may have to cancel the transaction but we will notify you if this is the case at the time. 3. How is your personal data collected? We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us in person at one of our sales offices, by post, phone, email, social media or otherwise. This includes personal data you provide when you: enquire about buying a Cavanna Home; contact us via the website to request property details or any other enquiry; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: (a) analytics providers such as Google based outside the EU; (b) advertising networks such as SurveyMonkey, which may be based inside or outside the EU; and (c) search information providers such as Google, which may be based inside or outside the EU. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our banking partners, which may be based inside or outside the EU. Identity and Contact Data from estate agents or aggregators based inside the EU. 4. How we use your personal data 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. Where we need to comply with a legal or regulatory obligation. 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 email, text message, post or phone. You have the right to withdraw consent to marketing at any time at salesprivacy@cavannahomes.co.uk. Purposes for which we will use your personal data We have set out below, in a table format, 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 have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at salesprivacy@cavannahomes.co.uk 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. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new prospect and uploading your information onto our internal database using the Prospects form (a) Identity (b) Contact Performance of a contract with you To process your property transaction: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Complete a Reservation Form (d) Communicate with mortgage providers (e) Communicate with solicitors (f) Communicate with surveyors (g) Provide Sales Extras and Colour Choices (h) Assist with exchange, completion and access to property (i) Provide post-sale customer care (j) Communicate with utility providers (k) Communicate with estate management companies (l) Other third-parties as required to provide our Services e.g. trades and suppliers (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation To carry out NHBC (or equivalent) customer satisfaction survey post completion (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications Necessary for our legitimate interests (to study customer satisfaction in order to improve our services) To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business) Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased a property from us, and, in each case, you have not opted out of receiving that marketing. In all other instances we will only send you electronic or printed communications where we have received your consent to do so. Third-party marketing We will get your express opt-in consent before we share your personal data with any third-party company which will send you marketing communications. Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at salesprivacy@cavannahomes.co.uk at any time. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at salesprivacy@cavannahomes.co.uk. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 5. Disclosures of your personal data We may disclose personal data to third parties in the following circumstances or to the following entities: Legal purposes. Where we are under a duty to comply with any legal obligation under applicable laws. Marketing. We may share your personal data with third party marketing companies where you have consented to receiving third party marketing communications. Affiliates. Our subsidiaries and parent company and businesses, and other affiliated legal entities and businesses with whom we are under common corporate control. We shall ensure that all of our parent, subsidiary, and affiliated legal entities and businesses that receive your information from us will comply with the terms of this privacy policy. Third party purchaser. In the event that we sell or buy any business or assets we will disclose your personal data to the prospective seller or buyer of such business or assets. Enforcing our rights. In the event that we are required to take action to enforce the terms of this Privacy Policy, the Reservation Form or the Contract for Sale. Provision of services. To provide you and our other customers with the services in accordance with this Privacy Policy, the Reservation Form or the Contract for Sale we may share information with: the New Homes Group or similar entities (for mortgage advice and credit checking); Help to Buy providers or other similar Governmental scheme participants; Professional Advisors (legal advisors, estate agents, insurers, banker, auditors and surveyors) based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; HM Revenue & Customs, regulators and other authorities in the United Kingdom who require reporting of processing activities in certain circumstances; Trades and suppliers (e.g. plumbers, electricians and decorators) for post-sale customer care; Utility providers; Estate management companies; any other third-parties necessary for performance of our Services. 6. International transfers We do not transfer your personal data outside the European Economic Area (EEA). 7. Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8. Data retention How long will you use my personal data for? 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. We retain: Customer plot files for 10 years from the date of completion. Potential customer information for 5 years from the later of the date of first enquiry or the last time you authorised us to extend the retention period. 9. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data: 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. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. The Cavanna Group Cavanna House Riviera Park Nicholson Road Torquay TQ2 7TD 01803 618688 Barley Meadow Bellevue – New Berryfields Broadleigh Park Cales Reach Cavanna @ Wolborough Hill Equinox I Equinox II Lyme View Future Developments Offers & Promotions Your Property Shortlist Why Choose a Cavanna Home? 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