PRIVACY POLICY
Templeton Robinson
AT A GLANCE
This summary tells you the most important things about how we use your personal data. Full details follow in the sections below.
•Who we are: Templeton Robinson, a property agency based in Northern Ireland. Contact: michaelyoung@templetonrobinson.com
•What we collect: your name, contact details, property preferences, and financial information where relevant to your property transaction.
•Why we collect it: to help you buy, sell, let or rent a property, and to keep you informed about relevant services.
•Who we share it with: service providers such as solicitors, mortgage brokers, referencing agencies and marketing platforms - only
where necessary.
•How long we keep it: varies by data type; typically up to 7 years for transaction records in line with legal requirements.
•Your rights: you can access, correct, delete or restrict your data at any time. Contact us at michaelyoung@templetonrobinson.com
•Cookies: we use cookies on our website. See Section 10 for details.
•Complaints: you have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or 0303 123 1113.
1. WHO WE ARE AND HOW TO CONTACT US
Templeton Robinson ('we', 'us', 'our') is the data controller responsible for your personal data collected through this website and in the course of our property services.
Registered address: 563 Lisburn Road, Belfast, BT9 7GQ
Email: michaelyoung@templetonrobinson.com
ICO Registration Numbers by office:
Lisburn Road - ZB013164
Ballyhackamore - ZB013139
Lisburn City - ZB013157
North Down - Z2467718
Our Data Protection Officer (DPO) can be contacted at the email address above. If you have any questions about how we handle your personal data, please get in touch.
2. WHAT PERSONAL DATA WE COLLECT
We collect personal data in a number of ways, including in branch, over the telephone, via email, through online enquiry forms on this website, and through our terms of business and application forms. We may also receive your data from third parties such as referencing agencies or data suppliers (see Section 7).
The categories of personal data we collect include:
•Identity and contact data: name, address, email address, telephone number.
•Property and financial data: details of property you wish to buy, sell, let or rent; financial information relevant to your transaction such as mortgage status or proof of funds.
•Employment and reference data: information required for tenant referencing, such as employer details and previous landlord references.
•Marketing preferences: your preferences regarding receiving marketing communications from us.
•Website and technical data: IP address, browser type, pages visited, and other data collected via cookies and analytics tools (see Section 10).
We do not ordinarily collect special category data (such as health information or details of criminal convictions). If we ever need to do so for a specific purpose, we will explain why and seek your explicit consent at that time.
3. WHY WE USE YOUR DATA AND OUR LAWFUL BASIS
The UK GDPR requires us to have a lawful basis for each type of processing we carry out.
The information below sets out our main processing activities and the basis we rely on for each.
Providing property services
•Purpose: managing your property transaction, matching you with suitable properties, liaising with solicitors, mortgage brokers and other parties on your behalf.
•Lawful basis: Contract processing is necessary to perform our agreement with you, or to take steps at your request before entering into one.
Legal and regulatory compliance
•Purpose:complying with Anti-Money Laundering (AML) regulations, including verifying your identity and source of funds.
•Lawful basis: Legal obligation - we are required by law to carry out these checks.
Marketing communications
•Purpose: sending you information about properties, services and market updates that may be of interest to you.
•Lawful basis: Consent (for email and SMS marketing) or Legitimate interests (for postal marketing to existing clients). You can opt out at any time.
Improving our services
•Purpose: analysing how our website and services are used to improve them.
•Lawful basis: Legitimate interests - it is in our and your interests that we provide an effective and improving service.
Responding to enquiries
•Purpose: responding to questions, complaints or requests submitted through our website or otherwise.
•Lawful basis: Legitimate interests or Contract, depending on the nature of the enquiry.
4. WHO WE SHARE YOUR DATA WITH
We do not sell your personal data. We may share it with the following categories of recipients, only where necessary and for the purposes described above:
•Professional service providers: solicitors, mortgage brokers, surveyors and other professionals involved in your property transaction.
•Referencing and verification agencies: for tenant referencing and AML identity checks.
•IT and platform providers: companies that host our systems, CRM software, email platforms and website.
•Marketing service providers: companies that help us manage and deliver marketing communications.
•Analytics providers: such as Google Analytics, to help us understand how our website is used.
•Legal and regulatory authorities: where we are required to disclose data by law, court order, or regulatory obligation.
All third parties we engage are required to handle your data securely and in accordance with the UK GDPR. Where they act as data processors on our behalf, we have appropriate contracts in place as required by Article 28 of the UK GDPR.
5. DATA WE OBTAIN FROM THIRD PARTIES
We sometimes purchase contact data from third-party data suppliers for the purpose of marketing our property services to individuals who may be interested in buying, selling or letting property.
Where we do this:
•The data has been collected lawfully by the supplier and they have the right to provide it to us for marketing purposes.
•You will have been given information about potential sharing with organisations like ours at the time your data was originally collected.
•We will tell you the source of your data the first time we contact you, as required by Article 14 of the UK GDPR.
•You can opt out of any further contact at any time by contacting us at michaelyoung@templetonrobinson.com
6. INTERNATIONAL TRANSFERS
We aim to keep your personal data within the United Kingdom. Where any of our service providers (such as cloud hosting or analytics platforms) transfer data outside the UK, we ensure that appropriate safeguards are in place, such as the UK's International Data Transfer Agreement (IDTA) or transfers to countries covered by a UK adequacy regulation. You can request further information about these safeguards by contacting our DPO.
7. HOW LONG WE KEEP YOUR DATA
We do not keep personal data for longer than is necessary for the purpose for which it was collected. Our standard retention periods are:
•Property transaction records: 7 years from completion, in line with AML regulatory requirements and potential legal claims.
•Tenancy records: 6 years from the end of the tenancy.
•Enquiries and correspondence that did not lead to a transaction: 2 years from last contact.
•Marketing contact records: until you opt out, or 3 years from last engagement, whichever is sooner.
•Website analytics data: 26 months (Google Analytics default).
When data is no longer required it is securely deleted or destroyed. You may request deletion at any time (see Section 9).
8. HOW WE KEEP YOUR DATA SECURE
We take the security of your personal data seriously and have appropriate technical and organisational measures in place to protect it against unauthorised access, loss, destruction or disclosure. These include:
•Access controls ensuring only authorised staff can access personal data.
•Secure, lockable storage for physical documents.
•Secure deletion and physical destruction of data that is no longer required.
•Staff training on data protection and security obligations.
If we become aware of a personal data breach that is likely to put your rights and freedoms at risk, we will notify the Information Commissioner's Office (ICO) within 72 hours and, where required, inform you directly without undue delay.
9. YOUR RIGHTS
Under the UK GDPR you have the following rights in relation to your personal data. You can exercise any of these rights by contacting us at michaelyoung@templetonrobinson.com. We will respond within one calendar month.
•Right to access: you can request a copy of the personal data we hold about you (a 'Subject Access Request'). There is no fee for this.
•Right to rectification: you can ask us to correct inaccurate or incomplete data.
•Right to erasure: you can ask us to delete your data in certain circumstances, for example where it is no longer needed or where you withdraw your consent.
•Right to restriction: you can ask us to restrict processing of your data in certain circumstances while an issue is resolved.
•Right to data portability: where processing is based on consent or contract and carried out automatically, you
can ask us to provide your data in a structured, commonly used, machine-readable format.
•Right to object: you can object to processing based on legitimate interests or for direct marketing purposes. We will stop unless we have compelling legitimate grounds to continue.
•Right to withdraw consent: where we rely on consent, you can withdraw it at any time. This will not affect the lawfulness of processing before your withdrawal.
•Rights regarding automated decisions: you have the right not to be subject to decisions based solely on automated processing that significantly affect you. We do not currently carry out this type of processing.
If you are unhappy with how we have handled your data, you also have the right to complain to the Information Commissioner's Office (ICO):
•Website: ico.org.uk
•Telephone: 0303 123 1113
•Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
10. COOKIES AND TRACKING TECHNOLOGIES
Our website uses cookies and similar tracking technologies. A cookie is a small text file placed on your device when you visit a website. We use the following types of cookies:
•Strictly necessary cookies: essential for the website to function. These cannot be switched off. No consent is required for these.
•Analytics cookies: we use Google Analytics to understand how visitors use our website (pages visited, time spent, referral sources). This data is anonymised and aggregated. These cookies are only placed with your consent.
•Marketing cookies: if we run any remarketing or advertising campaigns, these cookies help us show relevant adverts. These are only placed with your consent.
When you first visit our website, you will be presented with a cookie banner asking for your consent to non-essential cookies. You can change your cookie preferences at any time via the cookie settings link in the footer of our website.
For more information about the specific cookies we use and how to manage them, please see our separate Cookie Policy.
11. LINKS TO OTHER WEBSITES
Our website may contain links to third-party websites. This privacy policy applies only to our website. We are not responsible for the privacy practices of any linked sites and encourage you to read their privacy policies before providing any personal data to them.
12. CHILDREN'S PRIVACY
Our website and services are not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data about a child, please contact us immediately so we can delete it.
13. CHANGES TO THIS POLICY
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. When we do, we will update the 'Last updated' date at the top of this page. We encourage you to review this policy periodically. Where changes are significant, we will take steps to notify you directly.
14. HOW TO CONTACT US
If you have any questions about this privacy policy or the way we handle your personal data, please contact our Data Protection Officer:
Email: michaelyoung@templetonrobinson.com
Address: 563 Lisburn Road, Belfast, BT97GQ
This policy is made in accordance with the UK General Data Protection Regulation (UK GDPR) as retained in UK law by the European Union (Withdrawal) Act 2018, and the Data Protection Act 2018.
