Privacy Policy

Druce & Co (International) Limited Privacy Policy & Notice

Version 1.0 – 25th September 2022

Change Record

Notice:

This document falls under Druce & Co (International) Limited. The following applies to this document:

1. This policy applies to all Druce & Co (International) Limited employees based in the U.K.
2. This document is controlled as part of Druce & Co (International) Limited governance control.
3. No changes to this document are permitted without formal approval from the document owner.
4. Any questions regarding this document should be raised to the Custodian.
5. Distribution, modifications and access must be addressed based on Druce & Co (International) Limited Data Protection Policy.
6. Revision details are described in the Change Record table above.

Druce and Co (International) Limited (“Druce”) consider Data Privacy of high importance and we are committed to ensuring that we are transparent about our use of your personal data.

The following information sets out how Druce will collect, process, manage and protected your personal data.

1. The Purpose and scope of this Privacy Policy

It is important that you read this Privacy Policy together with any other Terms and Conditions we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data.

Please be aware that we will collect your personal data when you visit our website or interact with us as a customer of Druce. We have a separate Data Policy and Procedure Document for collecting, retaining, and processing personal data to manage the employment relationship relevant for all employees, contractors, casual workers and job applicants.

Please also note that all personal data sent to a Druce email address (for whatever purpose) will be stored on our IT systems and may be subject to wider systematic monitoring procedures that we have implemented for the purpose of supporting and protecting our legitimate business interests.

The Druce website is not intended for children and we do not knowingly collect personal data from children.

2. Druce as the controller of your personal data

Druce is the controller of the personal data you submit to us and responsible for your personal data under the EU General Data Protection Regulations.

The data that we collect from you is stored within our organisation and accessible by Druce personnel only.

Druce is registered with the ICO as a Data Controller under registration number Z4989532 with the following information:

Druce and Co (International) Limited
Montpelier House
106 Brompton Road
London
SW3 1JJ

Company Registration Number: 13695288
VAT Registration Number: 398628627

The Chief Compliance Officer at Druce is the Data Protection Officer and is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy representative using the details set out below in the following ways:

• By email: mydata@Druce.com
• By post: FAO the Data Privacy Representative, Druce and Co (International) Limited, Montpelier House, 106 Brompton Road, London, SW3 1JJ

You also have the right, at any time, to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would however, appreciate the chance to address your concerns before you approach the ICO so please do contact us in the first instance.

Where a Tenant receives Home Setup Services provided by Just Move In then, for the purpose of fulfilling the contract for those services, we will need to also provide relevant personal data to Just Move In. Just Move In will store and be a controller of such personal data. Just Move In (full company name Ethical introductions Ltd) provides a privacy notice describing their use of data, available here: www.justmovein.com/privacy

3. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This last review of our Privacy Policy was undertaken in August 2022

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.

The Druce website may include links to third-party websites, plug-ins widgets and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Druce does not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

4. The data we collect about you

Personal data, or personal information, means any information about an individual from

which that individual can be identified. Personal data does not include personal information where the identity of the individual has been removed or anonymised.

As a business we collect, use, store and transfer different types of personal data depending on who you are (for example, a client, customer, or job applicant).

We may collect, use, store and transfer the following categories of personal data about you:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and copies of identification documents.
• Contact Data including current address, email address and telephone numbers.
• Residential Data including residential status and past addresses.
• Financial Data including salary, payslips, bank account, payment card details and financial statements.
• Transaction Data including details about your property requirements, details of property you have sold, purchased, let and/or rented, details of payments to and from you, and details of other related services we have provided to you.
• Profile Data including your username and password, transactions entered into by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical Data including 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.
• Usage Data includes information about how you use our website, products and services.
• In order to provide the Home Setup and Utility Management Services we may, in the course of provision of the services, share move-to and move-from addresses, moving dates, tenancy details, council tax status, and other data required for the provision of those services (including data relating to other occupants or household members) to Ethical Introductions Ltd (T/A Just Move In)

We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your response data to evaluate the response to a specific marketing campaign. In the event that we associate your Aggregated Data with your Personal Data to the extent that it directly or indirectly identifies you, we will treat the combined data as Personal Data, and the data will be processed and managed in accordance with this privacy policy.

We do not collect “Sensitive Personal Information” 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, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In certain circumstances, you may provide us with such Sensitive Personal Information, for example if you have disability related requirement or you may provide details of your dependents. We will treat that Sensitive Personal Information as Personal Data, and it will be processed and managed in accordance with this privacy policy.

5. How we use your personal data

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 to perform the contract we are about to enter into or have entered into with you or your potential landlord
• 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
• Where we need to comply with a legal obligation

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message or social messaging platform.

You have the right to withdraw consent to marketing at any time by contacting us.

6. Purposes for which we will use your personal data

We have set out below, the details of all the ways in which we intend to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate business interests are.

Note that 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 upon which we are relying to process your personal data.

• Marketing – We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
• Promotional offers from us – You will receive marketing communications from us if you have requested information from us or obtained services from us and you have not opted out of receiving that marketing from us.
• We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
• Third-party marketing – We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
• Change of purpose – We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis for our decision to use your personal data.

  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules where this is necessary, or permitted by law.

• Opting out – 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.

  Your right to opt out of marketing messages will not preclude you from receiving services from us or to our rights and obligations in relation to the personal data provided to us in order to receive a service from Druce.

• Cookies – You can set your browser to refuse all or some cookies. Please be aware that if you disable or refuse cookies, some parts of the website may become inaccessible or not function properly.

7. How we collect your personal data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us details of your identity, contact and financial data by filling in forms (including electronically submitted forms) or by corresponding with us by phone, email, post or on any communication channel that Druce uses. This includes personal data you provide when you:
  • use or apply for our products or services
  • create an account on our website
  • subscribe to our service or publications
  • request marketing to be sent to you
  • enter a competition, promotion or survey
  • give us feedback or contact us
  • enter or attempt to enter into a business or employment relationship with us
  • call us or participate in online web facilities, including chat bots
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may 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.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the UK
    • advertising networks based inside or outside the UK
    • search information providers based inside or outside the UK
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK.
• Identity and Contact Data from data brokers or aggregators based inside or outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House, the Electoral Register and the Land Registry.

8. Disclosures of your personal data

We do not sell or otherwise disclose your personal data except as set out in this privacy policy or as indicated via the consent process at the time the data is collected.

We may share your personal data Internal within the Druce Group and with External Third

Parties that may include:

• Landlords
• Water and other utilities companies
• Credit and reference agencies
• Service providers based in the United Kingdom who provide IT, cloud, backup and system administration services.
• Professional advisers including lawyers, accountants, finance partners and auditors based in the United Kingdom who provide legal, accounting and insurance services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom including Councils (Council tax purposes) and the Land Registry.
• Tenancy Deposit Scheme and Deposit Protection Scheme.

Third parties include those to whom or with whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may also share your personal data if required by law to do so, to prevent financial or reputational loss or for investigation of suspected or actual fraudulent or illegal activities.

9. International transfers

Some of our external third parties may be located outside the UK. Consequently, processing of your personal data could involve a transfer of data outside the UK.

Whenever we transfer your personal data to a third party who may transfer it out of the UK, we aim to ensure a similar degree of protection is applied to the handling of your data by following at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (Adequacy)
• Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK (Standard Contractual Clauses for the transfer of personal data to third countries).

10. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, accessed, altered, disclosed or used in an unauthorised way.

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 care and confidentiality.

Druce has put in place procedures to address any suspected personal data breach. We will notify you and any applicable regulator of a breach, where we are legally required to do so.

11. Data retention

We will retain your personal data for as long as reasonably necessary to fulfil the purposes for we collected it, including whilst you use our services and for at least 6 years after the conclusion of those services for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there to be the prospect of litigation in during or following our relationship with you.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) while maintaining the context for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In certain circumstances, you can ask us to delete your data. Please see the see below for further information.

12. Your legal rights

You have the following rights under data protection laws in relation to your personal data:

• The right to request access to your personal data. Commonly known as a “data subject access request”, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• The right to request information about the personal data we hold on you at any time. You can contact Druce by email or post and we will provide you with your personal data via your preferred channel.
• The right to request correction of the personal data that we hold about you. You have the right to request that any inaccuracies in your personal data be rectified, including the right to have incomplete personal data completed. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
• The right to request erasure of your personal data. You have the right to request the removal of your personal data from the Druce data records. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• The right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground if you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override this right.
• The right to request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• The right to request the transfer of your personal data to you or to a third party. Whenever Druce processes your personal data, whether by automated means based on your consent or where done based upon your contractual agreement, you have the right to request that a copy of your data be transferred to you. This right is limited to the personal data that you have submitted to Druce. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• The right to Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please be aware that if you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

13. 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.

• We may need time to respond. We try to respond to all legitimate requests within one month. Occasionally it could 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 will not have to pay a processing 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 could refuse to comply with your request if your request is clearly unfounded, repetitive or excessive.

14. Glossary of Terms used in this Privacy Policy

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subjected.