RWinvest Group is committed to protecting the privacy and security of your personal data.
This policy describes how we collect and use the personal information you provide to us when you use our services, in accordance with the General Data Protection Regulation (GDPR). In this policy “we, us or our” means the RWinvest entity (as defined below). The relevant RWinvest entities are:
- RW Invest North Ltd a company incorporated in England and Wales having a registered office at 44 The Pantiles, Tunbridge Wells, England, TN2 5TN (Company number: 10237041).
- RW Invest UK Ltd a company incorporated in England and Wales having a registered office at 44 The Pantiles, Tunbridge Wells, Kent, England, TN2 5TN (Company Number: 05052108).
- RW Invest London Ltd a company incorporated in England and Wales having a registered office at 44 The Pantiles, Tunbridge Wells, England, TN2 5TN (Company number: 11404488)
- RW Invest Manchester Ltd a company incorporated in England and Wales having a registered office at 44 The Pantiles, Tunbridge Wells, England, TN2 5TN (Company number: 12909834)
References to “you” means the individual whose personal information we collect, use and process, whether this information is collected on our website www.rw-invest.com, in person, by telephone or otherwise.
We are a “controller” as we are responsible for deciding how we hold and use personal information about you. We are registered with the Information Commissioner’s Office for this purpose under registration numbers: RW Invest UK: ZA101993, RW Invest North: ZA243108 and RW Invest London: ZA458969
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information from which you can be identified when using our services; you can be assured that it will only be used in accordance with this policy.
It is important that you read this policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
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 data).
There are “special categories” of more sensitive personal data which require a higher level of protection. We do not currently process special category personal data but will update you should this position change.
We may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses, including social media handles and messaging service identifiers.
- Job title and place of work.
- Demographic information such as your postcode.
- Information about your use of our information and communications systems, including information about how you use our website (for example, the searches you undertake, your preferences and the properties and pages you look at).
- Information you provide to us in any correspondence with us.
- Bank account details.
- Identity verification documentation (including certified photographic ID (passports and driving licences), bank statements and utility bills).
- Date of birth.
- Financial data – this includes bank account and payment card details, for accounting purposes, payment approvals and refunds/reimbursements. Card details are destroyed after the payment is taken.
How is your personal information collected?
We typically collect personal information about our service users through:
- Directly over the telephone and in face to face meetings.
- Email correspondence.
- Property portals we use – including, Zoopla, Rightmove and Google.
We may collect additional personal information about you in the course of your relationship with us.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- 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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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 on +44(0)151 808 1250 or by emailing firstname.lastname@example.org.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to provide you with our services, perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. This includes:
- Determining the terms of your relationship with us.
- To understand your needs and to provide you with appropriate services.
- To allow us to provide you with the services you have requested, including providing information about properties available for sale, recommended solicitors, to arrange viewings and to organise face to face meetings.
- To improve our services.
- Internal record keeping.
- Administering any contract we have entered into with you or your employer.
- To communicate with you about the services you have requested.
- To make suggestions and recommendations to you about property investments that may be of interest to you.
- To keep you updated with construction updates for your property investments.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. For more information please contact Julian Ramsden at email@example.com.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide you with our services or perform any contract we have entered or trying to enter into with you.
Change of purpose
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 notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may also use your personal information for the purpose of direct marketing, for example to:
- Send promotional emails and text messages about new property investments special offers or other information which we think you may find useful or interesting using the email address and telephone number which you have provided.
We will only use your personal information for the above purposes when you have requested us to do so. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
In addition, you will receive marketing communications from us if you have made an enquiry or requested information from us about our services and/or property investments or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving future marketing communications. 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.
Automated decision making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
We do not envisage that any decisions will be taken about you using automated means, however, we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Some of the third parties we use to provide processing services store information outside of the EU. In each case, we have taken steps to ensure that there are sufficient safeguards in place to keep your data secure and the third parties are under contractual obligations as required by the GDPR. You can expect a similar degree of protection in respect of your personal information as if it were processed in the UK or EU.
To obtain further details and a copy of the appropriate safeguards please contact firstname.lastname@example.org.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
”Third parties” includes third-party service providers. The following third-party service providers may process personal information about you for the following purposes:
- We share your identity verification documents and the information provided by you in our reservation form with solicitors for the processing of your purchase.
- We share the information provided by you in our reservation form with the developer for the purpose of processing your purchase.
- We share your bank details with the developer for the purpose of processing interest payments.
- We share your name / address / email with CRM platforms that we use for the purpose of communicating with you.
- Our insurers to comply with our insurance obligations.
- Third parties to 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 notice.
A full list of names Third parties we share your personal data with is available on request from email@example.com.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third-party links on our website
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We have put in place technical and organisational measures to protect the security of your information. Details of these measures are available upon request.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available on request from firstname.lastname@example.org. 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. Once you are no longer a client of the company we will retain and securely destroy your personal information in accordance with any applicable laws and regulations.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right 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 that 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 the 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 stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- 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 as 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 your rights and freedoms.
- 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. 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.
- Be made aware of any automated decision making processes or profiling.
If you want to exercise your rights in relation to any of the personal data we process about you, please contact Julian Ramsden, Director in writing at Unit 101 Tea Factory 82 Wood Street Liverpool L1 4DQ, or email email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Julian Ramsden, Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data privacy contact
We have appointed a data privacy contact, Michael Gledhill to oversee compliance with this policy. If you have any questions about this policy or how we handle your personal information, please contact the data privacy contact on firstname.lastname@example.org. 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.
Changes to this policy
We reserve the right to update this policy at any time. We may also notify you in other ways from time to time about the processing of your personal information.