Horler & Associates Privacy Notice
Horler & Associates privacy notice provides information on how Horler & Associates and any of its subsidiaries, branches or representative offices and any 3rd party providers collect, use, secure, transfer and share your information.
Horler & Associates Registered Address is:
211 Clarence Road
Windsor
Berkshire
SL4 5AN
It serves most major lenders, investors, house builders, commercial businesses, corporations, local authorities, housing associations and the general public via the following business units / divisions. Full details can be found on our website
http://www.horler.co.uk/.
| Surveying |
Horler & Associates panel manage and
undertake valuations for the majority of UK
mortgage lenders.
|
| Marketing |
Markets Horler & Associates services via a
suite of websites and other means |
| Retail |
Sales & Lettings Services |
1. Types of Information Collected.
Typically Horler & Associates collect the following where applicable:
| First name |
How many Dependants? |
Personal Debt Details |
Salary |
| Middle Name |
Dependants Name |
Personal Expenditure |
Accountant Details |
| Surname |
Dependants DOB |
Existing Mortgage Details |
Previous Employers Details |
| Previous Name |
Primary ID |
Existing Insurance Details |
Employers Address |
| Date of Birth |
Address ID |
Email Address |
Employers Phone Number |
| Present Address |
Bank Statements |
Phone Numbers |
Health |
| Residential Status Credit Card |
Statements |
New Property Details |
Ethnicity |
| Previous Addresses Mortgage |
Statements |
Solicitor details |
Credit Card Details |
| Landlord Details |
Proof of Deposit |
Estate Agent Details |
Bank Details |
| Nationality |
Payslips |
New Mortgage Details |
|
| NI Number |
Self Employed Accounts |
New Insurance Details |
|
| UK National |
Gender |
Marital Status |
|
1.1. Methods of Collection
In the general conduct of business, Horler & Associates collects information relevant to the services being sought across the range of services it offers (listed previously) from:
yourself
next of kin
spouse / partner / family member
business associates
Employers
£trusted£ sources including:
Government / Land / Police registers
Credit / Default Agencies
Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)
Insurance Companies
Other Law firms
Health providers
Through consent to third parties disclosing information about you to us that they have collected
Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our branches or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers.
In addition, you may choose to submit information directly to us via several methods, including:
through Horler & Associates websites
In response to marketing or other communications
Through social media
By signing up for a Horler & Associates product or service
Through participation in an offer, program or promotion
In connection with an actual or potential business or employment relationship with us
You may also agree to third parties disclosing information about you to us that those third parties have collected.
Our service providers and partners may collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements,
mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.
We may use third-party web analytics services on our websites and mobile apps The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.
"Your Rights and Choices" section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected.
1.2. Purposes of Collection
Generally, we will collect, use and hold your information for the purposes of:
Assessing applications for and providing Horler & Associates products / services
Conducting business, developing relationships with Horler & Associates and affiliates
Process payments / transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit
Checks and related dispute resolution activities
Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent/franchise quality, integrity, compliance and security of business processes
Create and manage any accounts, associated authentication criteria (id£s and passwords)
you may have with Horler & Associates.
Provide, administer and communicate with you about Horler & Associates products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.
Compile business directories, including business contact information
Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
Developing new products and services
Managing communications, assess effectiveness and optimisation of advertising
Functionality of our websites, mobile applications other digital assets
Evaluate your interest in employment and contact you regarding possible employment opportunities
Enforce Horler & Associates £Terms of Use£, other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Horler & Associates or its affiliates.
Comply with industry standards and Horler & Associates policies
Anti-Money Laundering
In addition to help you with a property related service we have to comply with certain regulations for example the £Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (referred to as £the Regulations).£ Horler & Associates and other subsidiaries are required to obtain certain information from you to comply with regulations. The information provided will only be used by Horler & Associates in relation to complying with the Regulations and will not be shared with any other party outside of the companies wholly owned by Horler & Associates unless we are required to do so under law.
If you decide to enter in to a business relationship with Horler & Associates or any wholly owned subsidiary to comply with certain regulations.
We will require two separate Identification documents one primary and one secondary document even if it appears on both lists. The information may be required at various stages of the process depending whether you are:
Purchasing/Selling or Letting
Primary documents - proof of ID
Valid Passport with MRZ
Valid full UK photo driving licence
Valid full UK Driving licence (Non photo, paper) issued before 1998
Valid EU/EEA/Switzerland photo driving licence.
Valid EU/EEA/Switzerland national Identity Card.
Valid UK Armed Forces ID Card.
Valid UK Biometric Residence Permit (copy of both sides.)
Valid Blue disabled drivers pass. (With photo)
Valid Freedom Pass
Valid Local Authority Bus pass.
Department for Works & Pensions letter confirming pension details including National Insurance Number dated within the last 12 months.
Secondary documents - proof of residence (home.)
Valid full UK photo driving licence.
Valid full UK Driving licence (Non photo, paper) issued before 1998
Local authority council tax bill (dated within the last 12 months).
UK Bank / Building societies statements/bills showing activity, dated within the last six mths. Including account number and sort code. (Internet printed acceptable.)
UK mortgage statement (dated within the last 12 months.) (Internet printed acceptable.)
Utility bill dated within the last 6 months including - Electricity bill (with MPAN
number), Landline, Gas, Satellite TV, Water. (Internet printed acceptable.) (Not mobile phone bills.)
Her Majesty£s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement (dated within the last 12 months) with National Insurance number.
Department for Works & Pensions letter confirming pension details and NI Number. (Dated within the last 12 months).
We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search will not affect your credit rating
1.3. Lawful basis of processing
Horler & Associates processes your information under the following
Performance of a contract: where you enter into a contract with Horler & Associates and we need to process your information as part of this contract
Legitimate interests: some information is processed by Horler & Associates as part of its legitimate interests which include :Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications , profiling ,
direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller
Public interest: some information is processed in accordance public interest such as relocations
Consent : where we process information under consent we will seek you clear and unambiguous consent prior to processing your data
2. Information We Share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to:
Landlords and landlord associates and sub processors
Vetted affiliates and partners / Financial Institutions / Insurance Companies for business
facilitation to provide required services, such as mortgages, insurance cover etc.
Formally contracted service providers to perform services on our behalf:
Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services
Helpdesk, Call Centres etc.
We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal
requirements
Councils, health and care providers
Other Law firms
Credit agencies, Land Registry Office, Her Majesty£s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies
Additionally we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
Perspective employers requesting references via your written consent
On websites, features can be accessed where we partner with other entities that are not affiliated with Horler & Associates. These include social networking etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties' privacy policies if you use the relevant features.
Horler & Associates reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect / use your information. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.
2.1 How long do we keep information for
We will keep information for a reasonable amount of time in order to perform the purposes listed above.
We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However Horler & Associates reserves the right to keep information for longer if we feel that this is in the legitimate interests of Horler &
Associates.
2.2 International Data Transfers
Horler & Associates may transfer the personal information collected about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially
provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g. via program specific privacy notice).
2.3 Profiling
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential un-authorised activities, Horler & Associates engages profiling activities via direct use or anonymisation of sensitive personal information.
2.3.1 Direct Profiling
Direct profiling is engaged for the fair and lawful purposes, to provide Horler & Associates the ability to enforce Horler & Associates £Terms of Use£, legal reporting as may be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over Horler & Associates or its affiliates; including, but not limited to:
Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.
Background checks for existing and new employees, clients, business partners, affiliates
Financial Viability analysis / reports
Business partner / client portfolio position, performance, risk positions
Anti-money laundering
Tax reporting
Credit defaulting / exposure
2.3.2 Indirect Profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:
Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.
Compiling and communicating promotional and marketing information about products and services that Horler & Associates, affiliates and other organisations that we have affiliations with have and that may be of interest to you.
Conducting market research
Facilitating our internal business operations, including the fulfilment of any legal requirements.
2.4 Your Rights and Choices
Your rights regarding the sensitive / personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.
You will be sent a web access form to complete and login to access your data.
2.5 Access and Correction
You may have the right to:
obtain confirmation that we hold personal information about you
request access to and receive information about the personal information we maintain about you
receive copies of the personal information we maintain about you
The right to access personal information may be limited in some circumstances by local law requirements.
To exercise these rights, please contact us as set forth below.
2.6 Update and correct inaccuracies in your personal information
If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information you feel is incorrect or inaccurate
If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to
make a complaint. We will provide you with access to information we hold about you:
2.7 Object to the processing of your personal information
If you would like to object to any processing of your information by Horler & Associates you can contact us outlining what processing of information you would like to object to.
2.8 Have the information blocked, anonymised or deleted
If you would like Horler & Associates to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted , blocked or anonymised.
To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified in the £How To Contact Us£ section below.
2.9 Opting out of processing
You can opt out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to
opt out of receiving certain types of cookies). However without cookies you may not be able to use all of the website features and/or online services.
You can at any time tell us not to send you marketing communications by
e-mailing lettings@horler.co.uk for all lettings enquiries and post@horler.co.uk for all sales enquiries.
unsubscribing via the £unsubscribe link£ within the marketing e-mails you receive from us,
or
contacting Horler & Associates as indicated below.
2.10 Withdrawal of consent
If we obtain your information by consent you have the right to withdraw any consent you previously provided to us.
If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information.
Horler & Associates will apply your preferences going forward. Doing so will mean that you cannot take advantage of certain Horler & Associates and affiliate products, services and promotions.
The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.
3 How to Contact Us / Complaints and Feedback
If you:
make a complaint about a breach of your personal information, applicable privacy laws / principles or a concern about Horler & Associates privacy practices
would like access and/or update information or preferences you provided to us,
You also may e-mail us at:
lettings@horler.co.uk for all lettings enquiries
Or write to us at:
Horler & Associates
211 Clarence Road
Windsor
Berkshire
SL4 5AN
post@horler.co.uk for all sales enquiries
or write to us at
Horler & Associates
242 Dedworth Road
Windsor
Berkshire
SL4 4JW
If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us via the details in the "How To Contact Us" section below.
To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.
If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
3.1 How We Protect Personal Information
The security of your personal information is very important and Horler & Associates is committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
Horler & Associates stores personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently deidentify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it.
4 Updating this privacy statement
We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.
