Privacy Policy
This privacy policy is issued on behalf of The Milton Group Limited so when we mention “Milton”, “us”, “we” or “our” in this privacy policy, we are referring to The Milton Group Limited that is responsible for processing your data.
This privacy policy aims to give you information on how we collect and process your personal data when you use our services, attend our events or premises, use our website and/or services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. We may occasionally make changes to this Privacy Policy. Any new Privacy Policy will be automatically effective once it is published on this website. You should therefore return here regularly to review the up-to-date Privacy Policy.
WHO WE ARE
This website is owned and operated by The Milton Group Limited, a company incorporated in England, Company Registration Number 03656214, with its Registered Office being 4 Station Court, Station Approach, Borough Green, Sevenoaks TN15 8AD.
The Milton Group acts as the Data Controller in relation to the personal data which it collects on this website and is responsible for this website.
THE DATA WE COLLECT 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact Data includes home address, business address, email address and telephone numbers.
- Financial Data including bank account and payment card details.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Marketing and Communications Data including contact details, marketing history and marketing preferences.
- Technical Data includes internet protocol (IP) address, 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.
- Transaction Data includes details about your property, any leases or rental arrangement and other transactions.
- Usage Data includes information about how you use our website.
We do not collect any Special Categories of Personal Data 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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
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 Identity and contact details 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 services, give us feedback, contact us, visit our properties, sign our books and registers when entering our properties, through health and safety audits and fire risk assessments or sign up for onsite property training seminars which we may hold or organise.
- CCTV cameras, Automated technologies or interactions. We collect data from you through CCTV cameras positioned at some of our properties. In addition, as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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.
- 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.
- In connection with actual or proposed litigation.
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. You have the right to withdraw consent to marketing at any time by contacting us.
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 we are relying on to process your personal data where more than one ground has been set out below.
Purposes for which we will use your personal data
We may use your personal data for the following purposes:
- To consider and review lease agreements, property purchase agreement and/or, contractor agreements;
- To prepare, enter into and/or enforce rights under applicable contracts and other legal documents, including without limitation:
- lease agreements;
- loan agreements; asset purchase agreements; and
- supply, sale or purchase agreements connected with the business of Milton.
- To manage our relationship with you including without limitation:
- Notifying you about changes to our terms or privacy policy;
- Monitoring your performance of any applicable contracts we may have with you;
- Receiving and reviewing any information we receive from you relevant to any applicable contracts we may have with you; and
- Attending and engaging in meetings with you as necessary under any applicable contract.
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 which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO MAY USE YOUR PERSONAL DATA
We may share your personal data with the third parties set out below for the purposes set out above.
- Landlords and property owners whom we manage their properties and who are based in the United Kingdom and Jersey (the Channel Island).
- Service providers based in the United Kingdom who provide software, IT supply and support, data storage and system administration services.
- Property Management Companies who provide property maintenance, payment collection and/or key holding services.
- Consultants based in the United Kingdom including maintenance contractors, project managers, mechanical and electrical consultants, architects, structural engineers and quantity surveyors.
- Professional advisers including lawyers, bankers, accountants, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 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 policy.
THIRD-PARTY LINKS
This 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.
INTERNATIONAL TRANSFERS
We may transfer your personal data to jersey (the channel island), which is located outside the European Economic Area (EEA), for the purposes of approving and/or renewing lease agreements. The European Commission has made a decision recognising jersey as a jurisdiction which offers an adequate level of protection in relation data protection. We will put in place appropriate security measures to safeguard your personal data.
DATA SECURITY
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.
DATA RETENTION
We will keep your personal information for as long as we need it for the purposes set out above in the ‘How We Use Your Personal Data’ section and in accordance with any retention periods required by applicable laws and during the relevant statutes of limitations. Where you have made a transaction with us, we will keep a record for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example on property or rental enquiry or complaint) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your personal information, we will delete it.
Please note that where you unsubscribe from our marketing communications, we will keep a record of your communication information to ensure we do not market to you in future.
We will not delete your personal information where it refers to an active relationship or a product or service explicitly requested by you (for example, an ongoing property rental or transaction).
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
To the extent permitted by applicable law and regulations, you may have the right to gain access, correct, update, restrict, delete, be forgotten, or object to the processing of, or request data portability of the personal data collected about you subject to some exceptions and conditions. If we have relied on your consent as the lawful basis for processing your personal data, you may have the right to withdraw that consent at any time.
You can find out more about these rights from: https://ico.org.uk/your-data-matters/
We will take all reasonable steps to delete your data from our system upon written request, unless restricted by law. We may keep a copy for as long as is necessary in compliance with applicable laws and regulations.
We will respond to any of your above-mentioned requests within one month, but we reserve the right to verify your identity in advance. 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.
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.
CONTACT US
If you have any questions about this privacy policy or our privacy practices, please contact ususing any of the following contact details:
The Milton Group Limited
Postal address: 4 Station Court, Station Approach, Borough Green, Sevenoaks TN15 8AD
Phone: 01732 780 101
Email address: Admin@milton-investment.co.uk
This Privacy Policy was last updated January 2020