Privacy & Cookies Policy

Introduction

1. We are committed to safeguarding the privacy of our website visitors, landlords, tenants, prospective landlords, prospective tenants, applicants, contractors, suppliers and service users.
2. This policy applies where we are acting as a data controller with respect to personal data processed through our website, property services and related communications.
3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
4. In this policy, “we”, “us” and “our” refer to Western Lettings Ltd. For more information about us, see Section 15.

The personal data that we collect

1. We may process data enabling us to contact you (“contact data”). The contact data may include your name, email address, telephone number, postal address and property address.
2. We may process information relating to communications between you and us (“communication data”). The communication data may include the communication content and metadata associated with the communication.
3. We may process information relating to property enquiries, valuation requests, letting services, tenancy matters, maintenance requests, repairs and related property communications (“property services data”).
4. We may process information relating to contractors, suppliers and other service providers where this is necessary for property management, maintenance, repair, access, inspection, compliance or administration purposes (“supplier and contractor data”).
5. We may process data relating to newsletter subscriptions, marketing preferences and consent choices (“marketing data”).
6. We may process information relating to recruitment enquiries, employment applications and submitted CVs (“recruitment data”).
7. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, together with information about the timing, frequency and pattern of your website use.
8. Please do not supply any other person's personal data to us unless we request you to do so or unless it is necessary in connection with a property-related enquiry, application, tenancy, maintenance request or service instruction.

Purposes of processing and legal bases

1. Website operations and administration - We may process contact data, communication data and usage data for the purposes of operating and improving our website, responding to enquiries, maintaining security and administering our business. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2. Letting and property services - We may process contact data, communication data and property services data for the purposes of responding to property enquiries, arranging valuations, managing landlord and tenant communications, coordinating maintenance, repairs, access, inspections and administering letting agency services. The legal basis for this processing is our legitimate interests, namely the operation and administration of our letting agency business and property services.
3. Referencing, identity checks and compliance - We may process personal data where necessary for tenant referencing, credit referencing, identity verification, anti-money laundering checks and related letting agency compliance. The legal basis for this processing is compliance with legal obligations and our legitimate interests.
4. Compliance and legal obligations - We may process personal data where necessary to comply with legal, regulatory, tenancy, property management, anti-money laundering or letting agency obligations. The legal basis for this processing is compliance with legal obligations and our legitimate interests.
5. Communications - We may process contact data and communication data for the purposes of communicating with you, handling enquiries and managing related communications. The legal basis for this processing is our legitimate interests, namely communications relating to our website and business.
6. Direct marketing - We may process contact data and marketing data for the purposes of sending direct marketing communications by email and managing marketing preferences. The legal basis for this processing is consent. You may opt out of marketing communications at any time.
7. Research and analysis - We may process usage data for the purposes of analysing the use of our website and services. The legal basis for this processing is consent.
8. Recruitment - We may process recruitment data for the purposes of assessing applications, communicating with candidates and administering recruitment processes. The legal basis for this processing is our legitimate interests, namely recruitment and staffing administration.
9. Record keeping - We may process personal data for the purposes of creating and maintaining our business records and database backups. We will only process personal data that is reasonably necessary for the relevant purposes described in this policy. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.
10. Security and legal claims - We may process personal data where necessary for security purposes, fraud prevention, the establishment, exercise or defence of legal claims and compliance with legal obligations. The legal basis for this processing is our legitimate interests and compliance with applicable law.

Providing your personal data to others

1. We may disclose personal data to our insurers, professional advisers, website hosting providers, technology providers and business service providers insofar as reasonably necessary for the operation of our website and business.
2. We may disclose personal data to landlords, tenants, prospective landlords, prospective tenants, contractors, maintenance providers, referencing providers, credit referencing agencies, identity verification providers, anti-money laundering service providers, inventory providers, inspection providers, utility providers, local authorities, regulatory bodies and other third parties where reasonably necessary in connection with letting agency, property management, repair, access, inspection, compliance or administration services.
3. We may disclose personal data where such disclosure is necessary for compliance with a legal obligation, or in order to establish, exercise or defend legal claims.
4. We may disclose personal data to prospective purchasers of, or successors in title to, our business.

International transfers of your personal data

1. Some of our third party service providers may process personal data outside the United Kingdom.
2. Where personal data is transferred outside the United Kingdom, appropriate safeguards will be implemented where required in accordance with applicable data protection law.

Retaining and deleting personal data

1. Personal data shall not be kept for longer than is necessary for the relevant purpose or purposes.
2. We may retain contact data, communication data, property services data and related records for as long as reasonably necessary for the administration of our website, property services and business.
3. We may retain recruitment data for a reasonable period following the completion of a recruitment process.
4. We may retain usage data in accordance with the retention settings of our analytics and technology providers.
5. Notwithstanding the other provisions of this Section 6, we may retain personal data where necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Security of personal data

1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2. Data transmitted between your browser and our website may be protected using encryption technologies.
3. You acknowledge that the transmission of data over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet.
4. Information submitted through our website may be transmitted to us by email or other communication systems. While we take reasonable precautions, email and internet communications may not always be fully secure.

Your rights

1. Your principal rights under data protection law are:
   1. the right to access - you can ask for copies of your personal data;
   2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
   3. the right to erasure - you can ask us to erase your personal data;
   4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
   5. the right to object to processing - you can object to the processing of your personal data;
   6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
   7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
   8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
2. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
3. You may exercise any of your rights in relation to your personal data using the contact details published on our website.

Third party websites and services

1. Our website may include links to third party websites or incorporate third party content and services.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Updating information

1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

About cookies

1. A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser.
2. Cookies may be either “persistent” cookies or “session” cookies.
3. Cookies may not contain information that personally identifies a user, but personal data that we store about you may be linked to information stored in and obtained from cookies.
4. You can review or withdraw previous consent at your Cookie Settings.

Cookie information

Amendments

1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you remain satisfied with any changes to this policy.

Our details

1. This website is owned and operated by Western Lettings Ltd.
2. We are registered in Scotland under company number SC344154.
3. Our principal place of business is Suite 5, Platinum House, Craighall Business Park, 23 Eagle Street, Glasgow, G4 9XA.
4. Our Letting Agent Registration Number is LARN1804001.
5. You can contact us by post, to the address above, by telephone on 0141 357 0436, by email at [email protected] or using any contact methods or enquiry facilities published on our website.