This is the privacy policy for Sommerville Flury Limited (“we”, “us”, and “our”), provider of real estate services. Our company’s registered address is 21 Ellis Street, Knightsbridge, London, SW1X 9AL. For the purposes of the General Data Protection Regulation (GDPR), we are the data controller of the personal data you submit via telephone enquiries, email, SMS or otherwise. Our ICO registration number is ZB391388. We are committed to protecting your privacy and the security of the personal data we hold and process on your behalf. This Privacy Policy explains how we collect information, what we use the information for, our legal basis for doing so, and what controls you have. We reserve the right to change this privacy policy from time to time by changing it on www.sommervilleflury.com. This privacy policy was last updated on 19th September 2022. What information do we collect from you? Information you give to us We may collect and process the following personal information about you: -
General personal details, which may include:
1) Your name which will be at least one form of photographic identification such as a passport, driving license or national identity card
2) Your residential address which may be one form of documentation proofing that address
3) Your contact details (email address and/or your telephone number)
4) Your date of birth
5) Your bank account details
6)Your current and past employment
7) Your source of wealth and source of funds
8)Your other information required to satisfy prevailing anti-money laundering regulations
9) If dealing with an entity such as a trust or charity, personal information on beneficiaries, trustees, settlors, and protectors
10) If dealing with a company, personal information on directors and shareholders holding above 25% or otherwise controlling the entity
Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns, or comments regarding the Website, our service, or general comments. What we do with your data?
We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal data will only be shared with others in accordance with this Privacy Notice.
We use your personal data for the following purposes:
Providing our services to you - We need to process certain personal information in order to provide our services to you, which includes registering you as a contact or client and complying with Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR) to enable us to act on your behalf to sell or search for a property for you.
Contacting you about our services - If you have given us your contact information, we may use these details to get in touch with you about the services we offer such as by following up on an incomplete registration process or to email you newsletters you may be interested in. You may opt out of this at any time by telling us, or if we have contacted you via email, you will be given an option to opt out by replying to the relevant email.
Customer Support and account administration - We may use your personal data to provide you with customer support or to investigate complaints or concerns about your account.
Related products and services - We may use your personal data to provide you with information on services that you may be interested in. This information will be provided electronically via email. We will not transfer any of your personal data to third parties for this purpose unless you give us your explicit consent.
Providing information to third parties for marketing purposes and for related products and services - In certain circumstances we may ask for your consent to share your personal data with explicitly identified third parties so that they can contact you for marketing purposes or provide you with their own products or services. We will only do so if you have given us your explicit consent to share your personal information in this way. You can withdraw your consent at any time by writing to us at Sommerville Flury Limited, 21 Ellis Street, Knightsbridge, London, SW1X 9AL Mark Sommerville by telephone on 07703642380; or by emailing mark@sommervilleflury.com.
Processing necessary for us to operate the administrative, technical, and regulatory aspects of our business efficiently and in compliance with MLR We will need to verify the accuracy of information we hold about you and to undertake checks for MLR compliance. The processing of personal data in accordance with the MLR is lawful and necessary for the prevention of money laundering or terrorist financing and is the performance of a task carried out in the public interest. We may outsource certain administrative functions to third parties who specialise in such services including ensuring compliance with MLR. Our lawful basis for processing your personal data Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.
We will only collect and process your personal data in accordance with one of the below lawful bases: - Performance of our contract with you: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as providing you with a quote. This lawful basis covers the following purposes:
1)Providing our services to you - Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include: 1) Improving our service
2)Providing you with marketing information about our services o Providing you with customer support
3) Providing you with information about services offered by the us. - Consent: You may be given the option to explicitly consent to share your data with selected third parties for marketing purposes or to sign up for related products and services. This will be via a separate notice via email. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.
Compliance with our legal obligations: We will use your personal information to conduct due diligence in accordance with requirements of the MLR and other legal or regulatory obligations including responding to a request by law enforcement or when investigating a civil claim. We will use MLR compliance experts as required. - We will share your personal information with your appointed solicitors and the solicitors and agents acting for the other side of the deal as is necessary to facilitate the sale or purchase
We may also share your personal information with joint or multi agents or developers, as the case may be. - We will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property.
Data storage and international transfers
We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored on cloud servers within the EEA and we will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.
Your rights
You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice. If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.
You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine-readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.
Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails. You can exercise any of your rights by contacting us via the details at the bottom of this page.
How long we will keep your data for
We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.
What happens if you don’t provide us with the information we need
As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations. Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you and in certain circumstances we may feel it appropriate to inform the authorities.
Complaints
If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided above. Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO).
Cookies and Web Beacons
Like most websites, www.sommervilleflury.com uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
For more general information on cookies, please read “What Are Cookies”.