GDPR Privacy Policy

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

GDPR Privacy Policy 

This privacy policy covers the data you provide to us or that we have collected from you or about you.  It explains why we collect your data and what we do with your data. 

Our services and website may include links to other independent websites and services not provided by us.  As these sites and services are independent they are not under our control and as such we have no responsibility for content on these sites or services and have not approved or checked their privacy notices. 

This privacy policy may be subject to change and will be updated accordingly. 

For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Kai Carter Estates Limited, a company registered in England under company number 12270233, registered address is 72-73 Bartholomew Street, Newbury, RG14 5DU.   

Information we collect 

We typically ask you to provide the following personal details and information: 

  • Your full name, address and other important contact details (fixed phone line number, mobile phone number and email address). 
  • We are required by law to collect information relating to your identity to comply with the Immigration act and 2017 Money Laundering Regulations. 
  • We are required to conduct conflicts of interests under regulatory obligations and will ask for information on your close connections if applicable. 
  • In order to find a suitable property for you we will ask for information on any access requirements which may consist of special category personal data including details of disabilities or other relevant health information. 
  • We will collect information about visits to our website and usage (which enable our website to remember information about you and your preferences) and use of our site. This can include website visit information, including the full URL, [clicks through from and to our site (including time and date), pages viewed by you or searched for, length of visits to certain pages and the phone number used to call our office or customer service number. 
  • Technical information, such as devices you use to connect to our app or website, the device location data unless this function has not been disabled by you on your device. 
  • Any communication between you and us including correspondence via telephone and email when you have contacted us with an enquiry on our services or properties. 

We may be required by law to collect your personal data (to meet our obligations to prevent money laundering and fraud for example) or under the terms of any contract we have with you.  If you are unable to provide the data required when requested, we may be unable to perform or provide the product or service that we have or are trying to enter into with you. In this case, we may have to cancel the contract or service you have asked us to supply, but you will be notified if this is the case as soon as possible. 

Processing personal information 

Under current data protection legislation we have legal grounds to process your personal data are as follows: 

  • In order to perform a contract for a product or service to which you are a party, or to undertake the necessary process before entering into a contract with you for that product or service. 
  • We have your explicit consent to the processing of your personal data for one or more specific purposes, namely 1) electronic marketing by us where you have given us consent and/or 2) to process your Special Category Personal Data described above. You can still receive our services without providing marketing consent. 
  • It is a necessary requirement as part of our legitimate business interests, unless our interests are overridden by the interests, rights or freedoms of individuals affected (such as you). A number of factors are considered to determine this, such as our correspondence and conversations at the time you provided the data, your expectations from the processing of the data, the type and nature of the data, and the impact of us processing your data. Our legitimate interests include processing your data to promote and improve product and services provided by us and to develop a better understanding our customers’ interests and our knowledge of the market in which we operate and for the day to day administration and the technical aspects of our service and products. 
  • In rare circumstances and to comply with legal obligations. 
  • In order to protect your interests or the interests of a 3rd party; and/or 
  • Where it is required for official purposes or is in the public interest. 

Information required and usage 

Your personal information will be held and used in the following ways: 

  • To provide you with our products and services. 
  • We may be required to share your information with others to provide a product or service for which we are obligated to you or where acting as agent for a third party on your behalf. 
  • As part of our regulatory and statutory and obligations, including identity verification, prevention of money laundering and fraud. 
  • We may communicate and have contact with you during the course of providing our product and services, for example dealing with your requests and enquiries. 
  • Your data may provide statistics that can be analysed to plan for future products and services and help manage our business. 
  • Where we have your permission to do so or if you are an existing customer your data will be used to provide you, or to enable third parties to provide you with information about goods or services we believe may be of interest or relevant to you. Where we choose to contact you by electronic means (including email or text) with information about our own goods and services similar to those which you have already obtained from us or negotiated to obtain from us. You can unsubscribe from marketing messages at any time. 
  • Your usage of our website and other online services will be tracked and maybe used to improve these services. 
  • You may be notified of changes to our products or services 
  • Your data will be used to ensure our products and services are presented to you in the relevant online format for your device or computer. 

Data storage 

Your personal data will be retained for different periods depending on the product or service we provide you. This may be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period or need to retain it in the event of a legal claim or complaint. 

Sharing your data 

  • As part of our daily business activity we may pass your data to service providers in order for us to deliver the services you expect from us.  These include but are not limited to cloud based business process applications. 
  • We will also pass your details where necessary to your legal services and possibly the legal services of other parties to your transaction. We may also disclose your personal information to third parties: 
  • Your personal data will be disclosed to any prospective buyer or seller in the event that we buy or sell any business assets. 
  • Should we sell our company the personal data held by us will be considered part of the sale and transferred to the 3rd party acquiring the business. 
  • If there is a legal duty or regulatory obligation with which we must comply or to protect the rights, property, or safety of our company, our customers, or others we will disclose or share your personal data. This includes exchanging information with other companies and organisations for the purposes of credit risk reduction and fraud protection 
  • Prior consent will be obtained from you before we share your information with third parties for marketing related purposes. 

Data and information security 

Your data will be held on secure servers which may or may not be located in the EEA (European Economic Area).  All reasonable operational and technological measures have been put in place to safeguard your data, our content and our systems from any unauthorised access.  Wherever possible any identifiable information will be secured, encrypted or minimised. 

User rights – Accessing and updating your information 

It is your right to request a copy of the personal data and information we hold about you.  This is known as a data subject access request. It is also your right to request that information we hold about you which may be incorrect, or which may have changed since you first told us, is updated or removed. There is no charge for this service.  Please send requests to Ms Natalie Carter, Data Protection Officer at Kai Carter Estates, 72-73 Bartholomew Street, Newbury, RG14 5DU. 

Deleting your information and data 

It is your right to ask us to delete or remove personal data where there is no good reason for us continuing to store and process it. It is your right to ask us to delete or remove your personal information and data where you have successfully exercised your right to object to processing (see below), where we no longer have your consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to delete your personal information and data to comply with local law. Note, however, that it is not always possible to comply with your data and information deletion request for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Withdrawing your consent 

It is your right at any time to withdraw any consent you have given us to process your personal information and data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Your consent preferences can be changed at any time by contacting Kai Carter Estates at 72-73 Bartholomew Street, Newbury, RG14 5DU. 

Restricting or objecting to our use of your data and information 

It is your right to ask us to suspend the use of your data and information in certain scenarios, or object to our processing your information and data where we are relying on a legitimate interest ground (or those of a third party) and you believe it impacts on your fundamental freedoms and rights, or where your data and information is being processed for direct marketing purposes. Each case will be investigated and in some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your data and information which override your freedoms and rights. 

Often your data is essential to the supply and delivery of a service provided by us to you.  Please note that if you want us to restrict or stop processing your data and information this may impact on our ability to provide that product or service. Depending on the extent of your request we may be unable to continue providing you with our service. 

Questions, concerns or any other enquiry relating to the way we process and use your data and information is being used can be sent to Ms Natalie Carter, Data Protection Officer at Kai Carter Estates, 72-73 Bartholomew Street, Newbury, RG14 5DU. 

Complaints procedure 

Complaints regarding the use of your personal data and information will be investigated. If you wish to raise a complaint on how we have handled your personal data and information, you can contact us to have the matter investigated by writing to Ms Natalie Carter, Data Protection Officer at Kai Carter Estates, 72-73 Bartholomew Street, Newbury, RG14 5DU. 

If you believe we are not handling or processing your personal data and information in accordance with the law or if you are not satisfied with our response to a data information complaint or request you can complain to the UK data protection regulator, the Information Commissioner’s Office.  Further details can be found at www.ico.org.uk or 0303 123 1113. 

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