PRIVACY POLICY
GDPR ComplianceThe Doyen Land (DL) privacy notice provides information on how DL and any of its branches or representative offices and any 3rd party providers collect, use, secure, transfer and share your information. DL serves lenders, investors, developers, commercial businesses, corporations, local authorities, housing associations and the general public via the following business units/divisions.
Our website address is: www.doyenland.com
1 Types of information collected
Typically, DL collect:
- Title
- Employer/personal phone numbers
- First Name
- Middle Name
- Surname
- Company address
- Price requirements
- Landlord/Tenant Info
- Lease/ownership details
- Tenure details for property requirement
- Job title
- Credit check detail if required
- Website details
1.1 Methods of collection
In the general conduct of business, DL collects information relevant to the services being sought across the range of services it offers from:
- Yourself
- The DL Website
- ‘trusted’ sources including Property Portals
- through consent to third parties disclosing information about you to us that they have collected
Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our offices or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers. In addition, you may choose to submit information directly to us via several methods, including:
- through DL and affiliates websites
- in response to marketing or other communications
- through social media
- by signing up for a DL product or service
- through participation in an offer, program or promotion
- in connection with an actual or potential business or employment relationship with us
- at events, conferences, and seminars
You may also agree to third parties disclosing information about you to us that those third parties have collected.
We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may
We may use third-party web analytics services on our websites and mobile apps the analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.
‘Your Rights and Choices’ section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected.
1.2 Purposes of collection
Generally, we will collect, use and hold your information for the purposes of:
- Assessing applications for and providing DL products/services Conducting business, developing relationships with DL and affiliates
- Process payments/transactions
including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities - Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes
- Create and manage any accounts, associated authentication criteria (id’s and passwords) you may have with DL
- Provide, administer and communicate with you about DL products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.
- Compile business directories, including business contact information
- Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
- Developing new products and services
- Managing
communications, assess effectiveness and optimisation of advertising Functionality of our websites, mobile applications other digital assets- Evaluate your interest in employment and contact you regarding possible employment opportunities
- Enforce DL ‘Terms of Use’, other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over DL or its affiliates.
- Comply with industry standards and DL policies
- In order to provide focused marketing and information
1.3 Lawful basis of processing
DL processes your information under the following:
- Performance of a contract: where you enter into a contract with DL and we need to process your information as part of this contract
- Legitimate interests: some information is processed by DL as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller
- Public interest: some information is processed in accordance with public interest such as relocations
- Consent: where we process information under consent we will seek you clear and unambiguous consent prior to processing your data
2 Information we share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to:
- Vetted affiliates and partners / Financial Institutions / Insurance Companies for business facilitation to provide required services, such as mortgages, insurance cover etc.
- Formally contracted service providers to perform services on our behalf:
- Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services
- Helpdesk, Call Centres etc.
We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements:
- Councils, health and care providers
- Law firms
- Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies
- Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
- Perspective employers requesting references via your written consent
On websites, features can be accessed where we partner with other entities that are not affiliated with DL. These include social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features. DL reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect/use your information consistent with our Global Privacy Notice. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.
2.1 How long do we keep information for
We will keep information for a reasonable amount of time in order to perform the purposes listed above. We only keep your information for as long as necessary. We generally keep personal information for 7 years after the last contact with you. However, DL reserves the right to keep information for longer if we feel that this is in the legitimate interests of DL.
2.2 Profiling
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential un-authorised activities, DL engages in profiling activities via direct use or anonymisation of sensitive personal information.
2.2.1 Direct profiling
Direct profiling is engaged for the fair and lawful purposes, to provide DL with the ability to enforce DL ‘Terms of Use’, legal reporting as may be required by applicable laws, regulations, policies/standards or requested by any judicial process or governmental agency having or claiming jurisdiction over DL or its affiliates; including, but not limited to:
- Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.
- Background checks for existing and new employees, clients, business partners, affiliates
- Financial Viability analysis/reports
- Business partner/client portfolio position, performance, risk positions
- Anti-money laundering
- Tax reporting
- Credit defaulting / exposure
2.2.2 Indirect profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:
- Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners/affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.
- Compiling and communicating promotional and marketing information about products and services that DL Group, affiliates and other organisations that we have affiliations with have and that may be of interest to you.
- Conducting market research
- Facilitating our internal business operations, including the fulfilment of any legal requirements.
2.3 Your rights and choices
Your rights regarding the sensitive/personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.
2.4 Access and correction
You may have the right to:
- obtain confirmation that we hold personal information about you
- request access to and receive information about the personal information we maintain about you
- receive copies of the personal information we maintain about you
The right to access personal information may be limited in some circumstances by local law requirements. To exercise these rights, please contact us as set forth below.
2.5 Update and correct inaccuracies in your personal information
If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information you feel is incorrect or inaccurate
2.6 Object to the processing of your personal information
If you would like to object to any processing of your information by DL you can contact us outlining what processing of information you would like to object to.
2.7 Have the information blocked, anonymised or deleted.
If you would like DL to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised. To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us.
2.8 Opting out of processing
You can opt-out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website However without cookies you may not be able to use all of the website features and/or online services. DL operates a cookie policy Some of our service providers and partners may collect information about your online activities over time and across third-party websites to customise and target our adverts. You can at any time tell us not to send you marketing communications by:
- e-mail; info@doyenland.com
- unsubscribing via the ‘unsubscribe link’ within the marketing e-mails you receive from
us, or - contacting DL as indicated below.
2.9 Withdrawal of consent
If we obtain your information by consent you have the right to withdraw any consent you previously provided to us. If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information. DL we will apply your preferences going forward. You can exercise your right to prevent data processing by following the instructions on the pages where we collect your data or alternatively invoke the right to be forgotten by clicking the Unsubscribe: stop all email communications link listed on all our email communications. On receipt of this request, we will remove your personal data from our central CRM system and all email marketing will cease with immediate effect.
3 How to Contact Us / Complaints and Feedback
If you:
- make a complaint about a breach of your personal information, applicable privacy laws/principles or concern about DL privacy practices
- would like access and/or update information or preferences you provided to us,
You may e-mail us
If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us. To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time. If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
3.1 How We Protect Personal Information
The security of your personal information is very important and DL is committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. We use SSL encryption on a number of our websites from which we transfer certain personal information. DL stores personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was
4 Updating this privacy statement
We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.
December 2018