Privacy Policy Emerson Developments (Holdings) Limited, Subsidiaries and Associated companies (The Emerson Group) are committed to protecting your personal information. Our privacy policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us. Our privacy promise We promise: To keep your data safe and secure Not to sell your data To give you ways to manage and review your marketing preferences at any time Identity of controller Emerson Developments (Holdings) Limited is registered with the Information Commissioner’s Office as a Data Controller. The Emerson Group is the Data Controller in respect of the personal data it receives in connection with the services provided under the relevant engagement between The Emerson Group and its customers and clients. How the law protects you As well as our privacy promise, your privacy is protected by law. Data Protection law states that we are allowed to use personal information only if we have a proper reason to do so. The law states we must have one or more of these reasons: To fulfil a contract we have with you; or When it is our legal duty; or When it is our legitimate interest; or When you consent to it A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If you wish to see a full list of all the ways that we may use your personal information, and which of the reasons we rely on to do so, please contact us at the address detailed below. When do we collect information about you? We collect information about you when you engage us for information in relation to various matters: Homes to purchase Homes to rent Commercial Property Rentals Commercial & Residential Property Management Overseas Property Purchases and Rentals General Construction Activities Purposes of Recruitment / Employment Hotel and Spa Reservations We may also collect information when you voluntarily complete client/customer surveys or provide feedback to us. Information relating to usage of our websites is also collected. We use your information to personalise your repeat visits to the site. If you use any forms on our websites to send an email to us, a record will also be made of your name, telephone number, postal address and email address. Why do we need to collect and use your personal data? The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations. Where special category data is required we will obtain your explicit consent in order to collect and process this information. How will we use the information about you? We collect information about you in order to provide you with the services for which you have contacted us. Who might we share your information with? If you agree we may email or contact you about other products and/or services that we think may be of interest to you. We won’t share your information for marketing purposes with other companies outside The Emerson Group. In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products and other service for you. Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions. Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit. To fulfil our obligations in respect of prevention of money laundering and other financial crime we may send your details to third party agencies for identity verification purposes. Where is your information processed? The majority of your information is processed in the UK and European Economic Area (EEA). However some of your information may be processed by the third parties we work with outside of the EEA. Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations. How do we protect your information? We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations. How long do we keep hold of your information? In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests. How can I access the information you hold about me? You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below. We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect. We regularly check our systems for accuracy and bias and feed any changes back into the design process. Marketing We would like to send you information about additional products and/or services which may be of interest to you. We may send you such information by email, telephone, text message and/or post, but only if you have given your consent for us to do so. If you have agreed to receive marketing information, you may withdraw this consent at any time. If you no longer wish to be contacted for marketing purposes, please contact us by email at privacy@emerson.co.uk or by post (at our main business address below), providing your full name and home address details so that we may update your records accordingly. Cookies Our websites use Google Analytics, a web analytics service provided by Google. Google Analytics sets a cookie in order to evaluate your use of our websites and compile reports for us on activity on the websites. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using our websites you consent to the processing of data about you by Google in the manner and for the purposes set out above. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit http://www.allaboutcookies.org You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result. Links to other websites Our websites contains links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept responsibility or liability for their policies or processing of your personal information. Please check their policies before you submit any personal information to such third party websites. What can you do if you are unhappy with how your personal data is processed? You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is: Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) Changes to our privacy policy We keep our privacy policy under regular review. We will also place any updates on our websites as and when they occur. This privacy policy was last updated on 17th February 2020. How to contact us Please contact us if you have any questions about our privacy policy or the information we hold about you: The Privacy Team, Emerson Group, Emerson House, Heyes Lane, Alderley Edge, Cheshire, SK9 7LF, UK