Privacy Policy.

Circle Residential Management Ltd Privacy Notice

Version 1 16.5.18

Circle Residential Management Ltd (CRM Ltd) is committed to your privacy. This privacy notice explains our collection, use, disclosure, retention, and protection of your personal information.

We may amend this privacy notice at any time by posting an amended version on this site including the effective date of the amended version.

Personal Information we collect

What is Personal Information?

Personal Information is information relating to an identified or identifiable natural person.

We collect personal from you when you become a Freeholder who employs us to manage your properties, a Lessee who purchases a Leasehold property in a building which we manage, A sub-tenant of a Lessee who owns a property in a building which we manage, A lessee or subtenant in a property which we are asked to take over the management of, A contractor we use to do works on properties which we manage, A lessee of property for which we do ground rent and insurance collection on behalf of the Freeholder, A lessee of a property which we are asked to collect the service charges, ground rent or buildings insurance contribution for..

We also collect, update or amend your personal information, when you email us, call into our office, or otherwise correspond with us, make an insurance claim, own a leasehold property where we may do building works, initiate an inspection of your property as part of pre-sale enquiries.

Some of this personal information, such as a way to contact you by post, is necessary as part of a legal obligation so that you are able to adhere to the legal obligations of your lease.

Some of this personal information is necessary for legitimate interests such as insurance claims, building works, health and safety works.ie phone numbers and email addresses.

Personal Information you give us when your property is managed by CRM Ltd

• Identifying information such as your name, addresses, telephone numbers and email addresses when you complete our Data Verification Form
• You may also provide information through our web enquiry form

Personal information we may collect automatically when you contact us

• We will add your telephone number to our data base when you call into our office with a query
• We will add your email address to our data base when you email our office with an enquiry

We do not use cookies, web beacons, unique identifiers or any other similar technologies to collect information.

Personal Information collected from other sources

• We may check the information you have given us or supplement it using information from third parties. This information is only collected from the public domain ie The Land Registry

We do not use any form of Social Media to collect personal information

How we use your personal information

We use your information to provide and improve our services, contact you about your account and our services, and provide you with customer service.

We use the personal information we collect from you for a range of different business purposes and according to different legal and legitimate bases of processing. The following is a summary of how and according to which legal and legitimate bases we use your personal information.

We use your personal information to fulfil our contractual obligations with you on behalf of your Lessor and to provide you with our services, to comply with our legal and legitimate obligation, protect your vital interest, or as may be required for the public good.

This includes:

• To process statements of accounts relating to ground rent, services charges, administration fees and insurance whichever is applicable to your specific lease.
• To contact you regarding your account, to resolve a dispute, to collect monies owed or as otherwise necessary to provide you with customer service.
• When contacting you for such purposes as outlined above, we may contact you via email, telephone, SMS/text messages and postal mail
• When contacting you via telephone, to ensure efficiency, we may record the call
• To process an insurance claim
• To organise relevant building or health and safety works
• To organise a property inspection

We use your personal information to peruse our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:‍

• Continually review our procedures to ensure un-necessary use of information does not happen
• Monitor and improve the information security of our software and filing systems

We will not use your information for any marketing purposes or give to third parties for their marketing purposes.

Ways you can access, control and correct your personal information

We respect your right to access, correct request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.

• You have a right to know what personal information we maintain about you
• We will provide you with a copy of your personal information in a structured, commonly used and machine readable format on request
• If your personal information is incorrect or incomplete, you have the right to ask us to update it
• You have the right to object to our processing your personal information
• You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law and may impact some of our services.

Access, correction, and deletion of your personal information

You can request to see your personal information by phone, email or letter. You can update your personal information by either emailing us or writing to us.

We will honor any statutory right you might have to access, modify or erase your personal information. To request access please contact our office either directly or via the website enquiries form. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some caese in accordance with national laws.

If you request that we stop processing some or all of your personal information or you withdraw (where applicable) your consent for our use or disclosure of your personal information for the purposes set out in this privacy notice, we might not be able to provide you all of the services and customer support offered to our customers and authorised under this privacy notice.

Upon your request, we will close your account and remove your personal information as soon as is reasonably possibly, based on your account balance, lessee status and in accordance with applicable national laws.

How we might share your personal data

We may disclose your personal information to the following parties for the following purposes:

• Insurance Brokers, Loss Adjusters and Insurance Companies in relation to an insurance  claim
• Lessors in regard to their properties which you may be a Lessee of.
• Contractors for access for the purpose of building works, health and safety issues and property inspections.
• Your details may be seen by our IT consultants when working on upgrades to our software
• Your details may be seen by our software providers when working on upgrades to our system or during training sessions
• Your details may be seen by Accountants verifying end year accounts
• Your details may go on emails the provider of which is Office 365
• Any other third parties who we deem need this information to carry out a task as part of our ground rent management responsibilities.
• If you are an Employee your details may be seen by the payroll processor and given to our Peoples Pension Provider
• Your details are ultimately stored by a third party provider of cloud backup Acronis.

We hold copies of all our third party privacy statements where relevant

Law enforcement, legal proceedings and as authorised by law

• To comply with our legal obligations to our clients the Lessors in undertaking the management of their properties, or to protect anyone’s rights, property or safety.
• To law enforcement or government agencies, or authorised third-parties, in response to a verified request or legal process relating to a criminal investigation or alleged or suspected illegal activity or any other activity that exposes us, you, or any other of our customers or clients to legal liability. We will only disclose information we deem relevant to the investigation or inquiry such as name, address, telephone number, email address and account history.
• To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal basis, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report a suspected legal activity.

Change of ownership

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for new purposes.

How long we keep your personal information

We retain your personal information for as long as is necessary to provide the services necessary to undertake our contractual obligations, or for other essential purposes such as complying with our legal obligations, and resolving disputes.

Our specific retention times for personal information are documented in our record retention schedules. How long we retain personal information can vary significantly based on the context of the services we provide and our legal obligations. The following factors typically influence retention periods:

• How long is the personal information needed to provide our services. This includes maintaining and improving our services, maintaining appropriate business and financial record, maintaining insurance information. This is the baseline for most of our data retention periods.
• Is the personal information sensitive? If so, a shortened retention period is generally appropriate.
• Have you provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
• Are we subject to a legal, contractual, or similar obligation to retain your personal information? Examples can include mandatory retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal information retained for the purposes of litigation.

After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies.

We do not use Cookies or similar technologies on our website

How we protect your personal information

We protect your personal information using technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration. Some of the safe guards we use are firewalls and data encryption, physical access controls to our stored data and information access authorisation controls.

How to contact us

If you have a question or a complaint about this privacy notice, or our information handling practices you can contact us via our office 2 A P Ellis Road, Upper Rissington, Cheltenham , GL54 2QB, Telephone number 01242 222307 or email enquiries@circlemanagement.co.uk

Your right to file complaints with a data supervisory authority remains unaffected. The ICO website has all the information you may need on GDPR and how to complain if you do not think we have treated you correctly. www.ico.org.uk‍