1 IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this privacy notice
We hope you will enjoy using the Tulloch Homes website (our “website”) and we want to make sure your experience is as safe and useful as possible. Here you can find out how our website works, what data we collect from you, how we use it, circumstances where we may disclose this data to others and how we keep it secure. By using our website and providing your personal data you agree to be bound by the terms of this policy.
TULLOCH HOMES GROUP LIMITED (Company Number SC496362) is the data controller of any personal data you provide to us and is responsible for your personal data (referred to as “Tulloch Homes”, “we”, “us” or “our” in this privacy notice).
2 INFORMATION THAT WE COLLECT FROM YOU
2.1 What is personal data?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).
2.2 What personal data do we collect from you?
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, 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;
- Usage Data: includes information about how you use our website, products and services; and
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preference.
3 HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- request information on any of the products or services that we offer;
- fill in any forms on our website;
- interact with our website, marketing and advertising;
- subscribe to our service or publications;
- request marketing to be sent to you;
- register to receive or download information, newsletters or other documentation;
- sign up to attend any events;
- enter a competition, promotion or survey; and
- give us feedback.
- Automated technologies or interactions: As you interact with our website, we may automatically collect personal data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
4 HOW WE USE YOUR PERSONAL DATA
4.1 What processing grounds do we rely on?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need it to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
4.2 How do we use your information?
We use your information:
- to help us with understanding more about how our website is used;
- to be able to send you communications that may be of interest to you, either electronically or otherwise; and
- for all other purposes consistent with the proper performance of our operations.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will explain the legal basis which allows us to do so.
5 DISCLOSURE OF YOUR INFORMATION
5.1 Disclosure to selected third parties
The information you provide to us will be treated as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out in the policy or for purposes approved by you, including to the National House-Building Council and suppliers who provide marketing, financial and cloud computing services.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection legislation. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.2 Transferring data outside of the EEA
6 DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
A “cookie” is a piece of software that attaches to the hard drive of your computer and remembers information about the configuration of your computer.
The cookies we use can be described as either session or persistent cookies:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer. Session cookies can be either strictly necessary or functionality cookies.
1. Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
2. Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as starring favourite homes and downloading bespoke information. The information these cookies collect is usually anonymised.
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. We currently use persistent cookies for Google Analytics and Facebook. The persistent cookies we use are performance cookies. These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular. They also allow us to deliver custom content that may be of interest to you on other websites.
We use the following cookies which carry out the functions described:
• utma – This is a Google Analytics cookie and tracks the number of times you have visited our Site.
• utmb and __utmc – This is another Google Analytics cookie and acts to calculate how long you have spent on our Site in each session.
• utmz – This Google Analytics cookie tracks what search engine you have visited the Site from and which search terms you used to find our Site.
• utm_source – used to identify a search engine, newsletter name or other source.
• utm_medium – used to identify a medium such as email or cost-per-click.
• utm_campaign – used for keyword analysis and to identify a specific product promotion or strategic campaign.
• Facebook pixel - this is an analytical tool that helps us measure the effectiveness of our advertising. For more information on our use of pixels please go to: https://www.facebook.com/business/help/651294705016616
To change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site, and some features may not work properly. We recommend leaving cookies enabled to ensure full functionality on our website.
8.1 It is your choice whether you receive information such as marketing from us. If you indicated that you are interested in receiving regular information about our activities, we will send you communications electronically. We will not contact you for marketing purposes unless you have given your prior opt-in consent. If, at any time, you no longer wish to receive this information, please send an email to email@example.com
8.2 You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
9 THIRD PARTY WEBSITES
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11 YOUR RIGHTS
11.1 Individual rights
Under applicable data protection legislation, you have the right under certain circumstances to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it;
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes;
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
• Request the transfer of your personal information to another party; and
• Withdraw your consent to the processing of your personal information at any time.
If you would like to exercise any of your rights above, please contact us at firstname.lastname@example.org
11.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.
13 YOUR DUTY TO INFORM US
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
14 CONTACT US
14.1 Contact Details
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact: email@example.com
14.2 Making a complaint
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details set out above.