V2.2 November 2023
This policy notice is provided in a layered format so you can click through to the specific areas as set out below.
- Who are we and our Data Protection Officer
- Personal information we may collect about you
- How is your information collected?
- How and why we use your information
- Change of Purpose
- Sharing your information with third parties
- Where we store your information and transfers
- Data retention
- Your legal rights
- Contact and complaints
This policy aims to give you information about how we collect and process your personal data. please read the following carefully to understand our prctices regarding your personal data and how we will treat it.
2. Who are we and our Data Protection Officer
We are Mulberry Homes Yorkshire Limited, a wholly owned subsidiary of Broadacres Housing Association Limited. We develop, market, and sell residential properties.
Mulberry Homes Yorkshire Limited is a "data controler" in respect of the information we hold about you. This means that we are responsible for deciding how we use your personal information. We are registered as a data controller with the Information Commissioner's Office (the ICO) with registration number: ZA827351.
The person responsible for data protection at Mulberry Homes Yorkshire Limited is our Data Protection Officer. If you have concerns or questions about our use of your personal data, or any requests to exercise your legal rights, you can contact our Data Protection Officer as follows:
Data Protection Officer
Mulberry Homes Yorkshire Limited
Email - email@example.com
3. Personnal Information we may 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 the following types of personal data from you which we have grouped together as follows:
- Personal details about you and any person who will jointly be part of the property purchase : such as names, address, email address, telephone number(s) and any other contact details you provide to use during our communication;
- Financial information: such as proof of funds or mortgage promise;
- Information relating to the property purchase: property details, price, incentives offered, solicito details and estate agent details where there is a chain involved; and
- Information to verify your identity when logging onto Homematch platform, inluding name and email address;
- Your feedback: including survey responces and complaints raised; and
- Your communication preferences: in respect of marketing activity.
- Personal details about where you are selling land to us or purchasing land from us: such as name, address, email address and telephone number(s)
- Personal details of supplier contacts, including name and email address.
- Technical data: your IP address, operating system, browser type for system administration puposes and to report aggregatr information to our advertisers. this is statistical data about our users' browsing actions and patterns and does not identify and individual. We may also collect traffic data, location data, weblogs, and other communication data, whether this is required for our own billing puposes or otherwise and the website resources that access;
- Usage data: such as information about how you use our website;
- Automated technologies or interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details - Cookies link
4. How is your information collected?
The Above information which we collect about you will be obtained through a variety of sources which may include:
- From you directly: as part of a property enquiry, property application, provision of feedback or in communications with you.
- From third parties: such as estate agents or solicitors involved in the sale and purchase of the property, online advertising (such as Zoopla, Rightomve and New Homes), third party development contractors and landowners.
- From Broadacres Housing Association: where you ring the contact centre (calls are recorded).
- H ow and why we use your information
We use your personal data in the following ways and for the following purpose:
|Why we use your information
|Our lawful basis for using your information
To manage our relationship with you which will include:
6 (b) To take steps at reques of individual prior to entering into a contract.
|In the handling of feedback or complaints from you. Dealing with defects relating to your property
6 (b) Performance of contract
6 (f) Legitimate interests: It is necessary for our legitimate interest to help improve the service that we offer.
To send you details of properties we have for sale (direct marketing).
To send you a brochure on request.
|6 (a) Consent.
|To comply with our legal obligations such as to prevent fraud
|6 (c) Legal obligations: It is necessary to meet our legal obligations.
|To process the purchase and sale of land from/to individuals
6 (b) To take steps at request of individual prior to entering into contract.
6 (f) Legitimate interests: It is necessary that we communicate with specific contacts to progress the purchase/sale.
6 (1)(c) Legal obligations: It is necessary to meet legal/regulatory obligations.
|Communicating with our suppliers and professional representatives (e.g estate agents), including general contract management.
6 (1)(b) Contract: It is necessary in order for us to perform our contact with you.
6 (1)(f) Legitimate intersts: It is necessary for our legitimate interest where they are not overridden by your rights.
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
6 (1)(f) Legitimate interests: It is necessary for our legitimate interest where they are not overridden by your rights. (For running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)
6 (1)(c) Legal obligations: It is necessary to meet our legal obligations.
|To use data analytics to improve our website to ensure that content from our website is presented in the most effective manner for you and your device;
|6 (1)(f) Legitimate interest: It is necessary for our legitimate interests where they are not overridden by your rights. (To define types of customers for our products and services, to keep our website update and relevant).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
We may process your personal data to send you marketing by electronic means, but we will only do this if you have conesnted to such marketing. You may opt out of receiving such marketing at any point by clicking the unsubscribe link at the bottom of any such emails or by contacting us by any of the methods detailed in section 12 below.
We will not sell our marketing data to third parties without your consent.
7. Change of purpose
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 processing for the new pupose is compatible with the original purpose, please contact our Data Protection Officer by writing to Mulberry Homes Yorkshire Limited, Broadacres House, Mount View, Standard Way, Northallerton, North Yorkshire, DL6 2YD.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allow 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.
8. Sharing your information with third parties
We wil 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.
Some "third parties" are service providers (including contractors and designated agents) carrying out activities on our behalf. Other third parties will be "data controllers" in their own right. This means that they are not required to act on our instructions, and they are solely responsible for ensuring that they comply with the law when using your personal data. We are not responsible for their use of your data if we are acting lawfully whenever we share your data with them.
We may disclose or share your personal information with parties set out below:
- Third party contractors and service providers who preform services on our behalf, such as the supplier of our Homematch system used to administer the sales process.
- Professional advisers including solicitors or estate agencies who are assisting with the sale and purchase of properties, and our internal and external auditors.
- Broadacres Housing Association, for example to handle complaints or property defects.
- Relevant developer for purpose of resolution of defects
- Service providers who provide IT and system administration services:
- Third parties where we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Mulberry Homes Yorkshire Limited, our customers, or others. This includes exchanging information with other companies and orginisations for the purpose of fraud protection.
9. Where we store your information and transfers
We store your personal data on our servers which are located within the United Kingdom (UK). However we may needs to transfer data outside the UK as a result of some of the service providers we use. Before we transfer your personal data outside of the uk, we will ensure that there is adequate protection in place to ensure the security of your data. Please ask us if you would like to see a copy of these agreements with third parties in respect of data transfers.
10. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting or reporting requirements. 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 purpose for which we process your personal data and whether we can acheive those purposes through other means, and the applicable legal requirements. We will retain your information as follows:
If unsuccessful 3 months from date of decision
If successful 12 months from completion
|Completion documents, including memorandum of sale, completion statement, snagging, new homedemo and key release
|24 months from date of completion (aligned to defects period)
|Customer journey paperwork
|24 months from date of completion (aligned to defects period)
|Customer feedback surveys
|7 years from completion
|6 years after end of relationship
11. Your legal rights
Under certain circumstances, by law you have the right to:
- Right to access to your personal information (commonly known as a "subject accesss 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 we hold about you. If you discover that the information, we hold about you is incorrect or out of date, you may ask us to correct that information.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is not good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal data for direct marketing purposes. Where we process your date on the basis that you have consented to such processing, you have the right to withdraw your consent at any time by unsubscribinh from emails we send to you or contacting us. You have the right to ask us not to process your personal data for marketing purposes. we will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purpose.
- Request the restriction of processing of your personal inforamtion. 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of yur personal data, or request that we transfer a copy of your personal information to another part, please contact us by writing to us at: Data Protection Officer, Mulberry Homes Yorkshire Limited, Broadacres House, Mount View, Standard Way, Northallerton, North Yorkshire, DL6 2YD or email us at firstname.lastname@example.org. We may request proof of your identity before sharing such information with you.
12. Contact and complaints
If you have any questions, would like to exercise any of your rights or make a complaint, please contact us by writing to us at: Mulberry Homes Yorkshire Limited, Broadacres House, Mount View, Standard Way, Northallerton, North Yorkshire, DL6 2YD or email us at email@example.com or call us on 01609 767900.
If we are unable to resolve your complaint you may contact the Information Commissioner's Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone number : 0303 123 1113.
13. Other websites