Keeping your data safe
Who we are
1. Lewis Pownall Ltd is a privately-owned asset management and property development company. We were incorporated at Companies House on 9th September 2015 with the registration number 9208907 and registered with the Information Commissioners Office on 23rd May 2016 with registration number A8413971.
Our registered address is: 8 Moorland Road, Neath, Cimla, SA11 1JW
Control of your data
What data is collected and from where
1. We collect some data directly from you when you register for information from us regarding our products and/or services in a professional and/or private capacity. Depending on the method you use to contact us and the purpose of your business with us, this data may include the following:
a. your full name;
b. your email address;
c. your company;
d. your telephone number;
e. your date of birth;
f. your gender (if you choose to provide it);
g. your postcode and address (if you choose to provide them); and
h. your direct marketing preferences.
2. We may also collect and store information that you voluntarily provide to us when you contact us with enquiries, notices, complaints or any other kind of communication, or information that you post about yourself on public areas of our site such as blogs (Voluntary Data). This data is only held if we believe it is directly relevant to our relationship with you and could be used to improve the service we provide to you, or to communicate with you about our company, products and services.
4. We may also log and use information about any service errors or interruptions that you have experienced in order to help us fix and/or make technical improvements to our site.
5. We may also collect anonymised publicly available information from social networking sites like Facebook and LinkedIn, such as likes, shares, and posts about us. This information is fully anonymised and is used for internal analysis.
What your data is used for
1. It is important that you understand how and why we use the personal data collected about you. Below we set out the different purposes for which we process personal data and which personal data is required.
Providing you with our services
1. We may use your personal and Behavioural Data to provide you with any services requested from us by you.
2. We may use information stored about you to contact you occasionally with messages or updates about our products and services.
Improving our services
4. We may use Behavioural and/or Voluntary Data to help us monitor, analyse and improve the services we provide. We use this data to help us understand which type of products and/or services may be of particular interest to you and to help us identify errors and/or problems. This helps us provide you with products and services to the best of our abilities.
Marketing and advertising
5. We may use Voluntary, Behavioural and Third Party Data for marketing and advertising purposes. This may include sending advertisements where we use your first name to personalise the communication. For more information, please see the section below titled "How your data is used for marketing and advertising purposes".
6. We may use and combine the data we hold about you anonymously to help build up an overall understanding of what our customers look like.
7. We may use and combine the data we hold about you to help inform the advertising that is sent to you so that is might be more relevant and interesting to you. If you opt out of targeted advertising, you may still see advertising from us on other platforms (such as Facebook), but this will not be specifically tailored to you. For more detail please see the section below titled "How your data is used for marketing and advertising purposes".
Archiving and deleting
1. We periodically review the data that we keep in on our systems. Where data is still believed by us to be of value or interest for the purposes of providing our products and services, such data will be securely archived for potential future reference. We periodically review our archive and will delete your data held where we consider it is no longer of value or interest for the purposes of providing our products and services.
How your data is used for marketing and advertising purposes
1. The success of our business relies upon development of property and the sale or letting of that property. Marketing and advertising are consequently vital parts of our activities. Below we identify the various different types of marketing and advertising that we carry out and how your data is used for each type of activity.
2. We will use your email address to send you marketing that we believe to be of specific interest or relevance to you. Such communications may include information about new products, newsletters, updates about the company, special launches or events and promotional offers.
3. Any individual may opt out of receiving such emails at any time by either following the clear instructions to unsubscribe at the foot of any of our email marketing communications or by sending an instruction to firstname.lastname@example.org. Your request should be dealt with immediately but it may take up to 72 hours and may not affect any marketing emails already scheduled to be sent in the future.
4. If you opt out of email marketing it may still be necessary for us to send you service communications by email occasionally to inform you about things like changes to our products or services. You may opt out of receiving such emails by sending an instruction to email@example.com.
Promoting our services via third party platforms
5. We may promote our own content and features via third party platforms such as social media sites (Facebook, LinkedIn etc.)
6. This is typically achieved by sending an encrypted identifier to the third party which is then matched to that third party's records to see if you are a user of that platform. If so, this allows us to send you promotions via your profile page on that platform about products and services we believe will be of interest to you.
7. You can opt out of this type of promotion at any time by sending an instruction to firstname.lastname@example.org which we will process as quickly as possible, although you may still see our promoted messages whilst your instruction is being administered.
8. Our content might appear on third party sites depending on your activity on these sites (for example, after liking one of our posts or products on Facebook). Similarly, our content might appear according to the activity of members of your networks (such as friends on Facebook liking our posts). Such messages are controlled by the third party site, but you should be able to change your preferences within the third party site to stop receiving such messages.
Third party advertising
9. Under no circumstances whatsoever do we share your personal data with third parties for the purpose of advertising.
10. We do not send out advertising communications on behalf of third parties advertisers. In the event you receive advertising communications purporting to be from us but promoting products or services unrelated to our business, kindly send notification and a copy of the communication to email@example.com
The legal basis for our using your data
1. Current data protection law obliges us to state what we believe is the legal basis for using or processing your personal data for the purposes outlined above.
2. We process your personal data for all of the purposes identified under the sections What your data is used for and How your data is used for marketing and advertising purposes on the basis that it is in our legitimate interests to carry out these activities as set out below.
Purpose: Providing you with our services
Legitimate interests: To ensure that you enjoy the best experience in dealing with us as possible and to ensure that you are kept up-to-date about matters that may be of direct interest or relevance to you.
Purpose: Improving our services
Legitimate interests: To make sure that we continue to improve our service and provide our users with the best and most effective service possible.
Purpose: Marketing and advertising
Legitimate interests: To provide relevant advertising to you to ensure you are kept up-to-date of offers, promotions and new product developments that may be of interest to you.
Purpose: Demographic profiling
Legitimate interests: To help us better understand the wants and needs of our customers who have previously expressed an interest in learning more about the products and serves we provide, to ensure you enjoy the best experience in dealing with us as possible.
3. At any time you have the legal right to object to us processing your personal data for the purposes above. In such instances, unless a compelling legitimate reason can be shown to continue processing your personal data, we will stop processing it.
4. You also have the legal right to request that your personal data we hold and process be deleted completely from our systems and archives. In such instances, unless a compelling legitimate reason can be shown to continue processing your personal data, we will delete it.
5. Regarding the use of your email address for email marketing purposes, this is processed on the basis that we have your consent to do so. You can withdraw your consent at any time by following the instructions to "unsubscribe" in the footer of any email marketing communication.
Freedom of information
1. We are required under the Freedom of Information Act 2000 to provide certain information in response to Freedom of Information requests. You can make a request by emailing firstname.lastname@example.org. To be able to respond to such requests you will need to provide your name, address, email address, phone number and information about your request, including any additional personal data you choose to share with us when you make your request. This data will be used to respond to any request and will be retained administrative purposes as per the section headed How long we keep your data for below.
2. More information about Freedom of Information is provided here.
Who we share your data with
1. In the course of our business we may need to share your personal data with some third parties who perform various services for us when necessary:
a. third party service providers who play a necessary part in the buying, selling and renting of property such as solicitors or mortgage brokers;
b. third party service providers who play a necessary part in the management of our properties such as development managers and contractors; in most cases these types of recipients will communicate directly with you as necessary once in receipt of your information;
c. other service providers such as security trustees who help us manage investment opportunities we offer; and
d. other service providers such as information security service providers who help us to manage our IT systems and ensure that they are secure; and
e. third party media platforms to enable us to send you communications about our products and services, as described in the section headed Promoting our services via third party platforms above;
2. We may also share your personal data with third parties in the following circumstances:
a. where you have specifically consented to us sharing your data with a particular third party; and
b. where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party.
c. We do not transfer or store your personal data outside the European Economic Area (EEA). If we do carry out any further transfers of your data outside the EEA, we will inform you and we will ensure that the recipient provides an adequate level of protection of your personal data.
How long we keep your data for
1. Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the period will be for a maximum of 10 years following receipt of your information in the event there is no legal reason we need to communicate with you and/or your interaction with our company has ceased.
2. We will send you an email to notify you of our intention to delete your personal information one week before doing so. If we do not receive a reply to this we will proceed to delete your information.
1. You have a number of rights under data protection law. Your rights and how you can exercise them are set out in this section.
2. We will respond to requests to exercise your rights within a maximum of one month from receiving your request and any necessary proof of identity or further information.
The right to access your information
3. You can access all of your personal information we hold and also the right to ask us to send you a copy of this information. Exercising this right is called a "subject access request" and must be made to: email@example.com
The right to object to us processing your information
4. You have a right to object to us processing any personal data where we are relying on legitimate interests as the legal basis of our processing. If there are compelling legitimate grounds to carry on processing your personal data, we may be able to continue to do so.
5. You can exercise this right by emailing firstname.lastname@example.org.
The right to ask us not to market to you
6. You can ask us not to send you marketing or advertising. You can do this either using the “unsubscribe” link at the bottom of all of our marketing communications or by sending instruction to email@example.com. Please note that it can take a short time for opt-out requests to take effect – see the section How your data is used for marketing and advertising purposes above.
The right to have inaccurate data corrected
7. You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible. To request corrections to your personal data please contact firstname.lastname@example.org.
The right to have your data erased
The right to have processing of your data restricted
9. You can ask to restrict processing of your personal data in certain circumstances which means we may only store your data and not carry out further processing of it unless you consent or unless its processing is required for legal purposes. If you would like to make a request to exercise this right, please contact email@example.com.
1. You have the right to complain at any time to the Information Commissioner's Officer (ICO) about how we have processed your personal data. Click here to find out how.
1. We may make changes to this policy at any time. All changes made will be posted and dated on this page. We may also notify you by email if significant changes are made.
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