Privacy Policy

About this policy

This policy describes how we use your personal data when you use our website (www.bch.uk.com) or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

Who we are and how you can contact us

We are Barrett Corp & Harrington, a Limited Company, registered in England & Wales, registration number 5909758. Our registered office address is at Charnwood House, Harcourt Way, Meridian Business Park, Leicester, LE19 1WP.

You can contact us in writing at Swan House, The Park, Market Bosworth, Warwickshire, CV13 0LJ, or by emailing info@bch.uk.com. If you would like to speak to us please call us on 01455 293510.

Please refer to the sections on Our data compliance manager, Your data rights and How you can make a complaint for further contact information.

Our data compliance manager

We have appointed a data compliance manager who oversees our handling of personal data.

Our data compliance manager is Jeremy Price. You can contact Jeremy Price in writing at Swan House, The Park, Market Bosworth, Warwickshire, CV13 0LJ or by email at jeremy@bch.uk.com or by calling 01455 293510. Please also refer to Who are we and how you can contact us and mark your correspondence for the attention of Jeremy Price.

What personal data we collect about you

We collect:

● personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website, post on social media sites that we run, or contact us in connection with services that you would like to buy, or have already bought from us. The personal data that you provide to us may include your name, address, email address, phone number, details of the property concerned and their contents, and financial and credit card information.

● personal data that we receive from third parties. When we work with other businesses such as Brokers, Managing Agents, Insurance Companies or use sub-contractors to provide our services to you or where we have been instructed through a third party on your behalf, these parties may provide and collect personal data about you which they will share with us. Types of information that we may be provided with include your name, contact details, access details, security details and contents itinerary.

● personal data about your use of our website. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages you viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouse-overs).

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 valuation data about all properties of a particular type in a specific postcode area to produce a valuation standard. 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 policy.

What we use your personal data for

Personal data that you provide to us is used to:

● provide, either you, or your Broker, Managing Agent or Insurance Company with the information, products and services that you request from us

● manage and administer our business

● market our services and business

● review and improve our service

Personal data that we receive from third parties such as Brokers, Managing Agents, Insurance Companies, or Agents/Representatives is combined with the personal data that you provide to us and used for the purposes described above.

Personal data about your use of our website is used to:

● administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

● improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device

● allow you to participate in interactive features of our service, when you choose to do so

● help keep our site safe and secure

● to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you to make suggestions and recommendations to you and other users of our site about services that may interest you or them

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here.

Credit card processing

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

● Stripe: Their privacy policy can be viewed at https://stripe.com/en-gb/privacy

● PayPal: Their privacy policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:

● we are entering into and carrying out our obligations under a contract with you

● we need to use your personal data for our own legitimate interests and our doing so will not interfere with your privacy rights.

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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.

Purpose/activity	Lawful basis
To engage you as a new customer	Necessary to enter into a contract with you
To process and deliver your order, including to manage fees and payments and to collect and recover monies owed to us	Necessary for carrying out obligations under our contract with you OR necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, including to notify you about changes to our terms or privacy policy or to ask that you leave a review or take a survey	Necessary for carrying out obligations under our contract with you OR necessary to comply with a legal obligation OR necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) OR necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you marketing communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

In exceptional circumstances we may wish to use your personal data for a different purpose which will require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.

Please refer to the section on How we use your personal data for marketing to read about how you can opt out of marketing.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.

Keeping your personal data up to date

It is your responsibility to ensure that you notify us if your personal data changes. If you notify us of a change, we will ensure that we promptly update our records.

Your data rights

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. This includes 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.

● request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

● request erasure of your personal data. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

● 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
o If you want us to establish the data’s accuracy
o Where our use of the data is unlawful but you do not want us to erase it
o 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
o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

● request the transfer of your personal data to you or to a third 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.

● 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. 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.

If you wish to exercise any of these rights, please contact us in writing at Swan House, The Park, Market Bosworth, Warwickshire, CV13 0LJ, or by email to info@bch.uk.com, or using the details in the Who we are and how you can contact us section, and Our data compliance manager section. Please mark your communication “data rights request” to assist us in ensuring that it is directed to the correct member of our team.

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 could refuse to comply with your request in these circumstances.

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 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 can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

● your Managing Agent, Broker, or Insurance Company, if they have requested a report regarding your property or if you have specifically requested that we share a report with them or if you have requested that we provide a report under a scheme we operate with your insurer or broker

● our suppliers and subcontractors we work with to provide you with the services that you have requested from us

● analytics and search engine providers that assist us in the improvement and optimisation of our website

We may also share your personal information with third parties on a one-off basis, for example, if:

● we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets

● we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use or our terms and conditions of supply and other agreements, or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:

● storing your personal data on our secure systems

● encrypting any payment transactions made through our third-party payments provider who use SSL technology

● ensuring that our staff receive regular data security awareness training

● keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises

● maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems

● enforcing a strict policy on the use of mobile devices and out of office working

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We send occasional business-to-business marketing communications to managing agents, brokers and insurers by email, telephone and post. We rely on our legitimate interest to send these communications. We include unsubscribe options in all marketing communications. If you no longer wish to receive these communications from us, please use the unsubscribe option in any of our marketing communications to opt out or contact us at any time using the contact information in the Who we are and how you can contact is section of this privacy policy.

We do not send marketing communications to consumers.

Note that our report services include providing reminders to update your report at recommended intervals. These reminders form part of the ongoing service that we provide to ensure that your valuation remains current and are not marketing communications.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside of the UK by us or by our sub-contractors, including where we, or our subcontractors, use IT systems or software that is provided by non-UK companies.

Whenever your personal data is transferred out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

● only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
● using specific contracts approved for use in the UK which give personal data the same protection it has in the UK (these are known as Standard Contractual Clauses or International Data Transfer Agreements).

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice, this means that that we will keep:

● a record of the services we provide to you, including your name and contact details and a copy of your full report, for up to 20 years following the production of your report

● compliant records for up to 20 years following provision of a report

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact our data compliance manager to discuss this using the contact details set out in our data compliance manager section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website (www.bch.uk.com) or you can contact us to ask us to send you the latest version of our policy.

Version: 2022.01.17