PRIVACY & COOKIE POLICY

Mission Statement

At The Leaders Romans Group, we are passionate about safeguarding the personal data of all stakeholders – our valued customers, dedicated employees, and trusted partners. We believe that data protection is not just a legal requirement, but a moral imperative. That’s why we go above and beyond to implement the most robust and state-of-the-art security measures to protect all personal data entrusted to us. We are committed to compliance with all relevant laws and regulations and will only use personal data for lawful business purposes. We strive to ensure that the data we collect is accurate, complete, and up-to-date, and that it is kept safe from unauthorised access, loss or damage. Data protection is at the core of our values, and we believe everyone has a right to privacy.

Legislation

The Leaders Romans Group must look after your personal information by law. The main legislation that applies to protecting your information is:

• General Data Protection Regulations (UK) (GDPR UK)
• Data Protection Act 2018 (DPA)
• Human Rights Act 1998 (Article 8) (HRA)
• Privacy and Electronic Communications Regulations 2003 & 2011 (PECR)
• Money Laundering Regulations 2017
• Proceeds of Crime Act 2002
• The Data Protection, Privacy and Electronic Communications (Amendments etc.)(EU Exit) Regs 2019
• Telecommunications (Lawful Business Practice)(Interception of Communications) Regulations 2000
• Regulation of Investigatory Powers Act 2000 (RIPA)

The Leaders Romans Group Limited is the overall Data Controller and we have a legal duty to protect any information we collect from you. The phrases ‘us’, ‘we’ or ‘our’ will mean those businesses listed above which form the Leaders Romans Group Limited.

Our statutory Data Protection Officer is Zara Harrington. She can be contacted by email at dataprotection@lrg.co.uk or in writing at Crowthorne House, Nine Mile Ride, Wokingham, RG40 3GZ.

“Special category” personal data. This sensitive personal information is given more protection in law. For example, details of your health or nationality.
For more details of these definitions see below.

However, we may also obtain your personal data from other sources including:

• information we collect when you visit our websites, please see our Cookies Policy here
• other Leaders Romans Group companies, for example our mortgage brokering service
• companies which support advertising services that promote our services including online property portals (such as Rightmove and Zoopla), social media and networking sites (such as Facebook and Twitter) and online advertising platforms
• information provided to us by other third parties, such as your solicitor
• other publicly available sources such as the Electoral Roll and Land Registry

We may request additional information from you which is relevant to the provision of specific services. If we do this, we will always tell you why the information is needed.

If you ask us to provide you with life, critical illness, or landlord insurance and we may need to gather “special category” personal information, we treat this sensitive information in accordance with the additional protection it is given under the Data Protection Act 2018 and GDPR.

Information we collect when you visit our websites
We use cookies and other technologies to collect information when you visit our web sites, including when you make use of our online chat.

We may collect personal information in connection with your use of our website, such as:

• your name, email address, telephone number and property address when you register to arrange a viewing, register for property alerts, request a valuation, lettings appointment, book a mortgage appointment, book a holiday rental or submit an enquiry.
• data sent from your browser may include, the date, time and length of your visit, the site from which you have come (for example Google, Firefox etc.) and your IP address

Details of how we use cookies are provided in our Cookies Policy.

Information obtained from third party online portals
Where you contact us via online portals such as Rightmove or Zoopla, we will use your contact details to enable us to communicate with you and offer the services you have enquired about.

Information obtained from third parties
Where we are required by law, or for legitimate business needs, we will obtain information about you from third parties, but only after we have your consent to do so. For example, the third parties we may need to contact include: credit reference agencies, employers, banks, solicitors, etc. in order to obtain references, verify your identity and confirm your income.

Criminal disclosures
Certain types of insurance may involve disclosure by you of information relating to historic or current criminal convictions or offences. When we process any criminal records checks we do so in accordance with The Data Protection Act 2018 (Schedule 1, Part 3, Paragraph 33) and Article 10 GDPR UK. We will only carry out such checks where they are necessary.

CCTV & Telephone Call recording
We currently have CCTV installed in only a few branches for the prevention and detection of crime and to protect our business assets. All our cameras are overt and visible. Appropriate signage is displayed if CCTV is installed. Please ask branch staff if you have any concerns. CCTV may also be installed in some block management properties. CCTV signs will always be displayed.

We may record incoming telephone calls at our call centre, property management centres or branches for training and monitoring purposed only. You will hear a notification to advise you the call may be recorded however, not all calls will be recorded. Any recordings made are kept for one month before being over-written.

• • To provide estate agency services, including marketing your property, valuing your property, arrange and carry out accompanied viewings, selling your property and helping you search for a new home
  • To provide a full lettings service for tenants, prospective tenants and landlords
  • To provide full property management and maintenance services
  • To provide holiday rental booking services, such as marketing your property, holiday reservations
  • To advise on financial products, such as mortgages, insurance and protection products
  • To provide property auction services

To carry out regulatory checks to prevent fraud, unauthorised transactions, money laundering, tax

• evasion etc.
• To register a tenant’s deposit with a deposit protection scheme
• To process payments of rent, and maintenance for you if a property is being let
• To arrange an energy performance certificate or home report/survey inspections for you
• To offer an inventory and check in/check out service for rented properties
• To liaise with utility companies and local authorities regarding property services
• To carry out tenant referencing and credit reference checks
• To carry out guarantor referencing and affordability checks
• To monitor and improve our products and services
• To enable you to take part in a prize draw, competition or complete a survey

Customer Surveys
We may invite you to participate in surveys from time to time to help us gather feedback on our products and services, to make improvements. We may use a third party company to carry out these surveys on our behalf.

Prize draws and Competitions.
We may from time to time use your personal data to enable you to take part in a prize draw or competition and to contact you if you win a prize.

If you are entered into a prize draw or competition, you will be provided with specific terms and conditions that will apply and these will include details about how to opt in or out.

We do not use a third party to administer our prize draws or competitions and all prize draws and competitions will be administered by the Leaders Romans Group. We will let you know if we do decide to use a third party at any time in the future.

Credit scoring & Automated Decisions
Some of the services provided by third parties may involve an automated decision or credit scoring to determine whether we are able to provide a service or product. You have a right to challenge an automated decision and ask for the issue to be considered by human intervention.

Performance of a contract Article 6 (1)(b) GDPR – this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party.

Legal obligation Article 6 (1)(c) GDPR – where the collection and processing of your personal data is necessary for compliance with a legal obligation, for example, to comply with the Data Protection Act, verify your identity, for fraud and money laundering prevention.

Processing is necessary for the performance of a task carried out in the public interest Article 6 (1)(e) for example carrying out money laundering checks.

Legitimate interests Article 6 (1)(f) GDPR – some personal information is processed by the Leaders Romans Group as part of its legitimate interests which includes direct marketing, web analytics, sales and lettings.

The lawful basis for processing “special category” personal information
The Leaders Romans Group processes “special category” information only when it is necessary. The lawful basis we use to process your “special category” information is:

Explicit Consent Article 9 (2)(a) GDPR – is freely given, specific and unambiguous consent before the processing of your data. For example, your health information will be needed to process an application for critical illness insurance.

Data that has been made public Article 9 (2)(e)

Establishing, exercising or defending a legal claim Article 9 (2)(f) GDPR – for advice on underwriting, arranging or administering an insurance contract (Schedule 1 Part 2 of Data Protection Act 2018) or on the suspicion of money laundering in line with the Proceeds of Crime Act 2002 (Section 339ZB) You may want to inform us of your “special category” data voluntarily to enable us to offer you appropriate products or services. For example, you may have a health condition that means you are unable to climb stairs. We will record your needs/preferences without recording your medical/health conditions in most cases.

Withdrawing consent
You have the right to withdraw your consent at any time. Please contact the branch or office you have been dealing with.

Children’s privacy
We do not offer any products or services to children (defined as under the age of 16 in GDPR UK). In some circumstances, for example a mortgage application, we may be required by the mortgage provider to collect the names and dates of birth your dependent children or other adults who may reside with you.

Please see below third party organisations we share your information with and why,:-

• For lettings we keep your information for 6 years + 1 after you have stopped using our service.
• For property sales we keep your information for 6 years + 1 year after the sale has been completed.
• For property auctions we keep your information for 8 years after the sale has been completed.
• For planning advice and design, we keep your information for 4 years.
• For financial records, we keep your information for 8 years if your application is successful.
• For insurance policies we keep your information for 6 years + 1 year after the policy expiry date.
• For mortgages and records, we keep your information for 30 years.
• For general enquiries and marketing, we will keep your information for 2 years.
• For block management we will keep your information for 7 years + 1 after you have stopped using our service.
• Any copies of ID documents needed to verify your identity will be kept on file for anti-money laundering for 5 years. For tenancy reference checks we will keep your information for 1 year.

Anonymised information on properties and geographical areas may be kept for longer to assist us with property market forecasting and trends. Anonymised information is not subject to privacy legislation or the Data Protection Act 2018 and may be kept for as long as it is needed.

Where you contact us via our website, in branch, by phone, or via online portals such Rightmove or Zoopla for help searching for a property to buy or rent, we will use the details you have supplied to us to provide you with property details by email. You can choose to unsubscribe at any time by contacting unsubscribe@lrg.co.uk.

• ask us for access to a copy of your personal information we hold about you. This is called a data subject access request. We may ask you to provide ID to verify your identity.
• ask us to correct your personal information if it is inaccurate. We may ask you to provide confirmation to ensure the information we hold is accurate.
• ask us to delete your personal information. We are unable to delete your information if the law requires us to keep it for a statutory period or there is a lawful reason we must keep the information. We will always investigate any request and advise you, if we are unable to erase your data.
• ask us to transfer your data if your information is processed by automated means.
• withdraw your consent to use your personal information. Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by simply contacting the branch or team you have been speaking to.
• ask us to restrict the use of your personal data, including direct marketing.
• object to our use of your personal data for our legitimate business interests. You have an absolute right to object to our use of your data for direct marketing.
• object to an automated decision.

Subject Access Request
If you wish to make a request for access to a copy of your personal data, or to exercise any of your other rights, please write to your local branch in the first instance. Further information on the request process and a subject access request form is available from dataprotection@lrg.co.uk Please be aware if we receive all the necessary information with your request, we are able to locate your data and send it to you more quickly. We will endeavour to respond to and comply with your request as quickly as possible. We are aware of the statutory deadline for a subject access request, however we will always try to send your information before the legal deadline.

• Your name, contact email address and the address of the property (if regarding a tenancy, a sale, maintenance issue, mortgage or insurance policy)
• The business trading name (see below), branch location and names of any staff members
• A description of the complaint, time period or relevant dates, and
• Please attach details if your issue relates to a letter, property description, copy of email etc.

Once we have the information above, an investigation will be carried out by the Data Protection Team. We aim to respond to your complaint as soon as possible, but no later than 10 days from receipt. If you remain dissatisfied following a complaint to our Data Protection Officer, you can submit a complaint about data protection, privacy and data sharing issues directly to the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Website: https://ico.org.uk/ Email: casework@ico.org.uk Telephone: 0303 123 1113

• The ICO registration for The Leaders Romans Group Ltd is ZA781332.
• The Leaders Romans Group Limited is a registered company. Our registered office address is Crowthorne House, Nine Mile Ride, Wokingham, Berkshire RG40 3GZ. Our registered number is 09939099.
• Further information regarding the Leaders Romans Group can be found by visiting https://www.lrg.co.uk
• These companies have the following regulatory status:
  • Bode Insurance Solutions Limited is authorised and regulated by the Financial Conduct Authority
  • The Romans Group (UK) Limited is an introducer appointed representative of Bode Insurance Solutions Limited
  • Leaders Limited is an introducer appointed representative of Bode Insurance Solutions Limited
  • LRG Financial Services Limited is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited
  • Mortgage Scout is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited

Updates to our Privacy NoticeWe reserve the right to amend and update this Privacy Notice as required, therefore it is advisable you review this notice at regular intervals.

This Privacy Notice was last updated: Sept 2023.

COOKIE POLICY

By using Leaders Romans Group Digital Channels you agree to our use of cookies as described in this Cookie Policy.

What are ‘COOKIES’?

Cookies are small text files which are downloaded to your computer or mobile device when you visit a website or application. Your web browser (such as Internet Explorer, Safari or Google Chrome) then sends these cookies back to the website or application on each subsequent visit so that they can recognise you and remember things like personalised details or user preferences.Cookies are very useful and do lots of different jobs which help to make your experience on websites as smooth as possible. For example, they let you move between web pages efficiently, remembering your preferences and generally improving your experience(see below for more examples). They can also help to ensure that the properties displayed to you are more relevant to you and your criteria.

Cookies are referred to as session or persistent, depending on how long they are used:

• Session cookies only last for your online session and disappear from your computer or device when you close your browser.
• Persistent cookies stay on your computer or device after the browser has been closed and last for the period of time specified in the cookie. These persistent cookies are activated each time you visit the site where the cookie was generated.

Which COOKIES do Leaders Romans Group use and why?

When you use our Digital Channels, the following 4 categories of cookies may be set on your device:

1. 1. ‘Strictly necessary’ cookies
      These cookies are essential in helping you to move around our websites and use their features, such as accessing secure areas ofthe website. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information aboutyou that could be used for marketing or remembering where you’ve been on the internet.Some examples of these essential cookies include: 
      • Remembering previous actions (such as text you’ve entered in a registration form) when navigating back to a page in the same session
      • Identifying you as being signed in and keeping you logged in throughout your visit so that you don’t need to sign in each and everytime you visit

       

1. 1. Functional cookies
      These cookies allow websites and applications to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect is usually anonymised which means we can’t identify you personally. They do not gather any information about you or remembering where you’ve been on the internet.We use these types of cookies to improve your experience on our Digital Channels. Some examples of how we do this include:

       

      • • Remembering if we’ve already asked you if you want to fill in a survey or if you’ve completed a survey, so you’re not asked to do it again
      • • Remembering if you’ve been to the site before so that messages intended for first-time users are not displayed to you
      • • Remembering when you’ve voted in a poll or rated a product or article so that you don’t do this more than once during your visit
      • Supporting social media components, like Facebook or Twitter (where a website uses a plugin from these third party platforms, forexample)

       

      If you would like a list of the functional cookies used on Leaders Romans Group Digital Channels or have any further questions, you can contact us at compliance@lrg.co.uk .

1. Analytics cookies
   In order to keep Leaders Romans Group Digital Channels relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use them. For example, we can see which parts of our Digital Channels are most popular, identify which properties have been viewed online, identify when errors occur and test different versions of a page or feature to see which one works best.These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as “web beacons” or “tracking pixels” that may be included on Leaders Romans Group Digital Channels. These areused to count the number of times something has been seen. These web beacons are anonymous and do not contain or collect any information that identifies you.

   The web analytics services may also use cookies and similar technologies to make the information collected by the web beacons more useful. When you are viewing a website, a cookie is transferred to your browser by the web server and is stored on your computer. It can only be read by the server that gave it to you.

   Cookies allow web analytics services to recognise your browser or device and, for instance, identify whether you have visited our Digital Channels before, what you have previously viewed or clicked on, and how you found us. The information is anonymous andonly used for statistical purposes. It allows us to track information, such as how many individual users we have and how often they visit our websites. It also helps us to analyse patterns of user activity and to develop a better user experience.

   We use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future. This means that after visiting Leaders Romans Group you may find advertising banners on other websites associated with your browsing history. The technology behind these services are based on cookies. This is a service offered to suggest services which may be of interest to you. This is an anonymous service and no personal or identifiable information is recorded by this advertising method,however if you do not wish to view these types of adverts you can opt out of these services at the following links:Opt out of Google Display Network retargeting

   Web analytics data and cookies cannot be used to identify you as they never contain personal information such as your name oremail address.

Other third party cookies

Please note that on some pages on our Digital Channels you may notice that cookies have been set that are not related to Leaders Romans Group. When you visit a page with content embedded from, for example, YouTube / Vimeo videos, these service providers may set their own cookies on your web browser. These anonymous cookies may be set by that third party to track the success of their application or to customise their application to you. Leaders Romans Group do not control the use of these cookies and cannot access them, as cookies can only be accessed by the party who originally set them. Check the third party websites for more information about these cookies.

Commenting on Leaders Romans Group Digital Channels

Some of our websites allow you to leave comments about our Digital Channels. One of the tools we use to enable comments on our websites is provided by a third party. In providing this service, they may set cookies on your web browser to track your use of their commenting tool on Leaders Romans Group Digital Channels. To do this, they may use third-party analytics tools to help measure traffic and usage trends for their commenting tool on an anonymised and aggregate basis.

How to control your COOKIES

Leaders Romans Group do not use cookies to collect personally identifiable information about you. These cookies are set to improve your experience on our websites and to enable you to benefit from specific features and to set preferences. However, there are various ways that you can control and manage your cookies which are discussed in more detail below. Please note any settings you change will not just affect Leaders Romans Group cookies. These changes will apply to all websites that you visit (unless you choose to block cookies from particular sites).

Managing cookies in your browser

You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details on how to manage cookies, please read further on how to manage cookies and check your browser settings and options. Most modern browsers will allow you to:

• See what cookies you’ve got and delete them on an individual basis
• Block third party cookies
• Block cookies from particular sites
• Block all cookies from being set
• Delete all cookies when you close your browser

You should be aware that any preferences will be lost if you delete cookies, including where you have opted out from cookies, as this requires an opt-out cookie to be set. Blocking cookies completely will mean that many websites will not work properly and some functionality on these websites will be compromised. For this reason we do not recommend turning cookies off when using our Digital Channels.

To find out more about how to manage your cookies follow the links below which take you to the ‘Help’ sections for each of the major browsers:

• Internet Explorer:https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internet-explorer
• Firefox: http://support.mozilla.org/en-US/kb/Cookies
• Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
• Opera: http://www.opera.com/browser/tutorials/security/privacy/
• Safari: https://support.apple.com/en-gb/HT201265
• Android: https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DAndroid&hl=en
• Blackberry: http://support.blackberry.com/kb/articleDetail?ArticleNumber=000003865

Managing analytics cookies

It is possible to opt out of having your anonymised browsing activity within websites recorded by analytics cookies. Leaders Romans Group use the following analytics provider and you can opt out of their cookies by clicking on the following link. Please note that this will take you to the relevant third party’s website and generate a ‘no thanks’ cookie, which will stop any further cookies being set bythose third parties.

Once again, please note that by not allowing analytics cookies, we are unable to learn what you like or don’t like about our Digital Channels and thus cannot improve your user experience.

• Google Analytics: http://tools.google.com/dlpage/gaoptout