Privacy Policy
Who We Are
01.
We are PRAKAL ESTATES LTD, registered number 16615056, registered address:
Open House Estate Agents
PRAKAL ESTATES LTD
2 Fullbrooks Avenue
Worcester Park
Surrey
KT47PE
Our Data Protection Lead can be contacted at swlondon-surrey@localagent.co.uk. We have produced this privacy notice to keep you informed of how we handle your personal data, in compliance with the UK Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 ("Data Protection Legislation").
The terms "Personal Data", "Special Categories of Personal Data", "Personal Data Breach", "Data Protection Officer", "Data Controller", "Data Processor", "Data Subject" and "process" have the meanings given to them in the Data Protection Legislation. "Data Protection Lead" is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.
02.
Your Rights
Your rights under Data Protection Legislation include:
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the right to be informed of how your personal data is used (through this notice)
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the right to access any personal data held about you
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the right to withdraw consent at any time, by emailing swlondon-surrey@localagent.co.uk
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the right to rectify any inaccurate or incomplete personal data held about you
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the right to erasure, where the information held doesn't satisfy any of the criteria in this policy, or where you've withdrawn consent
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the right to prevent processing for direct marketing, scientific/historical research, or anything likely to cause substantial damage to you or another, including profile building
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the right to object to processing that results in decisions about you made by automated processes, and to prevent those decisions being enacted
To exercise your right to access your personal data, contact swlondon-surrey@localagent.co.uk with the subject line "Subject Access Request." You'll need to confirm your identity with a photocopy of your driver's licence or passport. This is free of charge and we'll respond within 30 days, unless the request is deemed excessive or unfounded — in which case we'll tell you our reasonable administration costs and/or any delay in advance, so you can decide whether to proceed.
Questions about any right in this section can go to our Data Protection Lead at swlondon-surrey@localagent.co.uk.
03.
Who is the Data Controller?
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If we collected your data directly from you for our own purposes, we are the Data Controller.
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If we purchased your data from a third party for our own purposes, we are the Data Controller — we'll contact you before we first use it, or within one month of acquiring it at the latest.
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If a third party passed us your data for our own purposes, we are the Data Controller, under the same notice timing.
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If a third party passed us your data for a joint purpose we both influence, we are the joint Data Controller, under the same notice timing.
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If your data was passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have told you this at the point of collection — see "Third parties we work with" below.
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If we received your data as part of a business-to-business relationship, the Data Controller is your employer.
04.
Lawful Bases for Processing
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Under Data Protection Legislation, there must be a lawful basis for using personal data:
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your consent
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performance of a contract
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compliance with a legal obligation
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protection of your, or another's, vital interests
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public interest / official authority
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our legitimate interests
05.
Our Legitimate Interests
Legitimate interests are a flexible basis the law permits for processing personal data. To decide whether we have a legitimate interest, we balance the needs and benefits to us against the risks and benefits to you. This is done as objectively as possible by our Data Protection Lead. You can object to our processing, and we'll consider the extent to which this affects whether we still have a legitimate interest. For more on our legitimate interests, contact swlondon-surrey@localagent.co.uk.
06.
The Data we Collect
Personal data means any information about an individual from which that person can be identified. It doesn't include anonymous data. We may collect, use, store and transfer the following, grouped together:
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Identity Data — first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender
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Contact Data — billing address, delivery address, email address, telephone numbers
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Financial Data — bank account and payment card details
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Transaction Data — details of payments to and from you and products/services purchased
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Technical Data — IP address, login data, browser type/version, time zone and location, browser plug-ins, operating system and platform
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Profile Data — username and password, orders, interests, preferences, feedback and survey responses
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Usage Data — how you use our website, products and services
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Marketing and Communications Data — your preferences for receiving marketing from us and third parties, and communication preferences
We also collect Aggregated Data such as statistical or demographic data, which is not personal data in law unless combined with your personal data in a way that identifies you.
We do not collect any Special Categories of Personal Data (race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data), nor information about criminal convictions and offences.
07.
How we use your Data
B2B Marketing
Identity Data
Direct marketing to former, current and prospective clients. Lawful basis: our legitimate interests.
Contact Data
Source: directly obtained, or by referral from existing clients/partners/suppliers
Analystics
Technical Data
To understand how you use our website, how you reached us and how long you spend on it, to analyse and improve our service. Lawful basis: our legitimate interests.
Usage Data
Source: directly obtained, or indirectly via a client's website (notice given at point of collection)
Fraud Prevention
Identity Data
To combat fraud, we share information on clients who instruct their payment issuer to cancel payments to us without first informing us or giving us the opportunity to issue a refund, with credit reference agencies. Lawful basis: protection of your, or another's, vital interests.
Transaction Data
Source: directly obtained, or indirectly via a client's website (notice given at point of collection)
Contract Submission
Identity Data
When you post information about yourself on a forum or blog, we store it to make it available for viewing on the website. Consent is obtained at the time of posting and via reference to this notice. Lawful basis: your consent.
Contact Data
Source: directly obtained, or indirectly via a client's website (notice given at point of collection)
Phone Calls
Identity Data
We may record calls for training and/or auditing, and collect Calling Line Identification information, to help improve the efficiency and accountability of our customer service. Lawful basis: our legitimate interests.
Contact Data
Source: directly obtained
Email and Web Contact
Identity Data
If you contact us through our website or by email, we use the information you send to respond to your enquiry or complaint, and keep it to improve our overall service. Lawful basis: our legitimate interests.
Contact Data
Source: directly obtained, or indirectly via our website (notice given at point of collection)
Consumer Marketing
If you make a purchase with us, we add your contact information to our marketing list and send information we think may interest you. Lawful basis: our legitimate interests.
Identity Data
Contact Data
Transaction Data
Marketing & Communications Data
Source: directly obtained
08.
If you refuse to give us your Data
Information collected for the performance of our contracts is required for us to successfully fulfil our obligations to you. If you choose not to provide it, we won't be able to enter into a contract to provide the benefits we offer. If we're already processing your information under a contract, you'll need to end that relationship (as/where permitted) to exercise some of your rights.
Where we process personal information as part of a contractual relationship with a Data Controller, any request to restrict that processing should go to that Data Controller — they're responsible for discussing your concerns and making decisions.
09.
Automated Decision-Making
PRAKAL ESTATES LTD, not perform any profiling or automated decision-making based on your personal data.
10.
How long we keep your Data
We hold different categories of personal data for different periods, and aim to minimise both the amount held and how long we hold it.
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Where consent is the lawful basis, we retain data for as long as the original purpose and your consent remain valid. We review consent every 12 months and treat non-response to a renewal request as a withdrawal of consent. Occasionally we may identify a legitimate interest in retaining consent-based data — if so, we'll tell you and identify the interest specifically.
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Identity, Contact and Transaction Data are held indefinitely (subject to your objection, or individuals leaving our clients' business), to provide a better service to returning customers.
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Where legitimate interests is the basis, we retain data for as long as that purpose remains active, reviewed every 12 months.
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Data held because it's essential for performance of a contract is retained for six years, per the Limitation Act 1980, for exercising or defending legal claims.
Who else receives your Data
11.
We pass your data to the third parties listed under "Third parties we work with" below, for the purposes of providing our services to you, and for no other purpose.
12.
International Transfers
PRAKAL ESTATES LTD, uses overseas web and IT providers. Details of what data is sent where, and the safeguards in place, are set out in the "Third parties we work with" section below.
13.
Third parties we work with
Third Party
What we process for them
Their EU representative
HMRC, regulatory, or other authorities
We are joint Controller with these authorities, who require reporting of processing in some situations
N/A
Postal / courier providers
Where these act as Data Controller, we're joint Controller with them for sending you physical documents
N/A
[Agency Central]
Providing the software to syndicate listings to property portals. Your contact information is kept on a secure server so you can be contacted by your local agent. Replace with your actual processors — e.g. GoHighLevel (CRM), Spectre/HomeSearch (direct mail), Home.co.uk (valuation leads), and the portals themselves.
14.
How to Complain
You can send complaints directly to swlondon-surrey@localagent.co.uk, or to our supervisory authority. As we predominantly handle the personal data of UK nationals, our supervisory authority is the Information Commissioner's Office — complaints can be made at ico.org.uk.