Your privacy is important to us and we are committed to taking all reasonable steps to safeguard your information.
Cowdel Clarke is a Private Ltd Company registration number, 4524457 and our registered office is Suite A, 2nd Floor Kennedy House, 31 Stamford Street, Altrincham, Cheshire WA14 1ES.
We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection
Regulation (EU) 2016/79 (“DATA PROTECTION REGULATION”). For more information relating to this policy please contact us at email@example.com.
What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to withdraw consent at any time, by emailing firstname.lastname@example.org;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of
the criteria outlined in this policy, or where you have withdrawn consent;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
Who is the Data Controller?
If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
What are the Lawful Basis for Processing Personal Data?
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:
a) 'your consent';
b) 'performance of a contract’;
c) 'compliance with a legal obligation’;
d) 'protection of your, or another's vital interests';
e) 'public interest/official authority’; and
f) 'our legitimate interests'.
About our Processing of Your Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Why we process your data
Where did we get your
personal data from?
· Identity Data
· Contact Data
Direct marketing to former, current, and prospective clients. This processing is
conducted lawfully on the basis of 'our legitimate interests'.
Directly obtained or obtained via a property portal.
• Technical Data
• Usage Data
To understand how you use our website, how you reached us and how long you spend on our website, in
order to analyse our performance and improve our service. This processing is conducted lawfully on
the basis of 'our legitimate interests'.
Directly obtained or indirectly obtained through a client's website.
· Identity Data
· Transaction Data
To combat fraud, we share information of clients who instruct the payment issuer to cancel payments
to us without first informing us of why and/or allowing us the opportunity to issue a refund with
credit reference agencies. This processing is conducted lawfully on the basis of 'protection of
your, or another's vital interests'.
Directly obtained or indirectly obtained through a client's website (notice given at the point of
Phone, Email and Web Contact
• Identity Data
• Contact Data
If you contact us through our website or by email, we will use the information you send in order to
respond to your enquiry or complaint. This information will be kept in order to improve our service
to you overall. This processing is conducted lawfully on the basis of 'our legitimate interests'.
Directly obtained or indirectly obtained through a client's website (notice given at the point of
The information you provide is stored in our secure database for our internal use. Your data is also sent securely to third parties for us to fulfil our legal obligations or to complete our marketing material.
We take all reasonable steps to keep these details secure and free from unauthorised access, and our internal systems are updated in accordance with changes in legislation or technology.
You have the right to tell us not to use your personal information for marketing purposes.
You can exercise this right by unsubscribing using the link in any of the marketing emails we send.
The data protection law also gives you the right to access your personal information, to object to the use of your personal information for certain purposes, and the right to erase, restrict or receive a machine readable copy of your personal information. You can exercise any of these rights by contacting us at email@example.com.
We will comply with the law in responding to your requests. That means that there may be some legal reasons why we can not respond.
Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.
• to allow essential parts of our web site to operate for you.
• to operate our content management system.
· to operate the online notification form - the form that you use to contact us for any reason.
This cookie is set on your arrival at our web site and deleted when you close your browser.
• to enhance security on our contact form. It is set for use only through the contact form.
This cookie is deleted when you close your browser.
• to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
• to record that a user has viewed a webcast. It collects information in an anonymous form.
This cookie expires when you close your browser.
• to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.
• to store your personal information so that you do not have to provide it afresh when you
visit the site next time. This cookie will last for a period of time after which it will delete automatically.
• to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube's privacy-enhanced mode.
What happens if I refuse to give you my personal data?
The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the benefits we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.
What are 'legitimate interests'?
Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.
How Long will your Personal Data be Kept?
We hold different categories of personal data for different periods of time to enable us to meet contractual and legal obligations. Wherever possible, we will endeavour to minimise the amount of personal data that we hold.
If 'consent' is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. We review the status of your consent periodically and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we process your data on the basis of 'legitimate interests', we will retain your data for so long as the purpose for which it is processed remains active. We review the status of our legitimate interests periodically and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
Who Else Will Receive Your Personal Data?
We pass your data to the third parties listed in the section 'Third Party Interests' below, for the purposes of providing our services to you, and for no other purpose.
Does Your Data Leave the EU?
We may use overseas web and IT providers. Details of what data is sent where, and the safeguards in place, are included in the section 'Third Party Interests' below.
Third Party Interests
Our Data Processors:
Name of Third Party
Purposes for Carrying out Processing
The Deposit Protection Scheme where tenancy deposits are lodged
Estate and letting agency software
The Property Jungle
Data may also be sent to solicitors for the purpose of confirming a sale or purchase of a property.
Who can you Complain to?
In addition to sending us your complaints directly to propertyecowdelcIarke.com, you can send complaints to our supervisory authority. As we predominantly handle the personal data of UK nationals, our supervisory authority is the Information Commissioner's Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting https://ico.org.uk/concerns
Get in touch
Call us on 01925 600200 or send us a message...