Privacy Policy
Introduction
Welcome to Wilton Blue’s privacy and cookie policy.
Privacy Policy
Wilton Blue respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you how we collect, use, and store your personal data, tell you about your privacy rights, and how the law protects you.
This policy was last updated in July 2023. We may update this from time to time; any updates will be posted on this page. Please revisit this page occasionally to ensure you are happy with any changes.
Please read the below carefully.
Who We Are
The data controller responsible for your personal data is:
Wilton Blue Limited, trading as “Wilton Blue”, company number 14530546, registered at 71-75 Shelton Street, Covent Garden, London, United Kingdom WC2H 9JQ. The terms “we” or “us” refer to Wilton Blue
By “personal data”, we mean information which may identify you directly, such as your name, or indirectly by a certain characteristic combined with information we already hold about you.
The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes.
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with property negotiation services). In this case, we may have to cancel your service with us, but we will notify you if this is the case at the time.
Information we collect from you
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, driving licence number, passport number, date of birth, and utility bills.
- Contact Data includes billing address, delivery address, email address, telephone numbers, and social media profile.
- Financial Data includes bank account details (i.e. bank name, account name and address, sort code) and credit history.
- Transaction Data includes details about payments to and from you and other services you purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website, www.wiltonblue.co.uk.
- Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.
We also collect, use, and share aggregated data, such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered ‘personal data’ in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, suppose we combine or connect aggregated data with your data so that it can directly or indirectly identify you. In that case, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
We only collect special categories of personal data about employees, work experience students, and contract workers (including details about your race, religion, ethnicity and medical information) strictly as necessary to report on diversity and safeguard such workers.
How is your data being collected?
Where we collect data about you from depends on how you interact with us. We use different methods to collect data, including the following:
- Direct interactions you may give us your identity and contact data by direct interaction with an employee of Wilton Blue, contact data, filling in forms, corresponding with us by email, phone, post, via our web portal to keep clients updated on their matter, through instructions and information we collect when you instruct us to act on a property negotiation, subscribing to our newsletter, via our website and applications or service that links to it, when you apply for a job position, work experience or send your CV to us on a speculative basis or feedback you provide to us.
- 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 data using cookies, server logs and other similar technologies. We may also receive Technical Data if you visit other websites employing our cookies. Please see our cookie policy for further information. We may also observe, detect, or create data about you without directly asking you to provide the information to us, for example, via CCTV or through a meeting. We may record phone or video calls and meetings and retain copies or transcripts of dialogue, e.g., via a web portal, live chat on our website, WhatsApp, or SMS.
Third parties or public sources
We may collect data about you from various third parties or publicly available sources (e.g., Companies House and Land Registry) when making anti-money laundering, identity and credit checks through third parties, recruitment consultants, referees, third parties collecting feedback on our behalf or reviews, banks, mortgage brokers and estate agents.
How we will use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- As needed to perform the property negotiation on your behalf;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests;
- Where we need to comply with a legal obligation;
- To give you information about the services we offer;
- To tell you about changes to our services;
- To invoice you for our services and to receive or, recover the payment owed to us;
- To allow you to participate in interactive features of our service and/or to follow any of our social media sites, including Facebook, Instagram, LinkedIn and Twitter when you choose to do so;
- The prevention of fraud and other criminal activities;
- To tell you about relevant training, events, products, news updates and announcements;
- To address a request from you in relation to the exercise of your rights. For example, if you have asked us not to contact you for marketing purposes, we will keep this information on a list;
- To make suggestions and recommendations to you and other users of our website about services that may interest you or them;
- To comply with our legal, regulatory, professional and ethical obligations;
- To invite you to take part in surveys regarding your experiences of working with us;
- To deal with, assess, investigate, defend and respond to any queries, complaints or claims; and/or
- For any other legitimate business purpose.
We will only use your personal data for the purpose for which we collect it unless we consider that we need to use it for another reason, and that reason is compatible with the original purpose.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Disclosure of your information
We may share your personal information with our staff working in our offices or remotely for us to provide our services to you. You agree that we have the right to share your personal information with selected third parties, including analytics and search engine providers, that assist us in improving and optimising our site.
If we sell or buy a business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Wilton Blue Limited or substantially all its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- To our suppliers and service providers, for example, insurers, accountants, tax advisors, experts, and auditors.
- Other organisations involved in your case or matter, e.g., mortgage brokers and banks.
Marketing
You will only receive tailored marketing from Wilton Blue (including services, events, webinars, latest news, updates on changes in our services, and newsletter), if you have signed up for our newsletter, if you are a client of ours, if we believe it is in your best interest to receive the communication, if you have given us your express consent.
If you would like to withdraw your consent, you can contact us. Withdrawing your consent will not remove our right to contact you regarding work we may carry out for you.
Where we store your personal date
All information you provide to us is securely stored inside the United Kingdom. If we transfer your personal data outside of the United Kingdom, we will take reasonable steps to ensure your personal information is adequately protected. Third parties we use may transfer your data outside of the United Kingdom. These countries may not have the same standards of protection and privacy laws in place, which means additional safeguards must be put in place.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Under certain circumstances, you have rights under data protection laws in relation to your personal data. You are entitled at any time to ask us for a copy of the personal data we hold about you, known as a data subject access request. You are also entitled to ask that any information we hold about you is supplemented, updated or rectified. You can make any of these requests free of charge by contacting us.
- In certain circumstances, you can also ask us to restrict our processing of your personal data, e.g. if you contest the accuracy of it. We will continually review your request and will inform you if we decide we are not required to action it. If you need us to restrict or stop processing your personal data in any way, this may impact our ability to provide our professional services to you. Depending on the nature of your requests, we may have to stop acting for you but will still have to pay any unpaid fees and expenses incurred on your behalf.
- You are entitled to ask that we send you a copy of the personal data we hold about you to another organisation for your purposes, for example, if you intend to instruct another property negotiation agent instead of us. If you want us to move, copy or transfer your data in these circumstances, please get in touch with us.
- You are entitled to ask us to erase your personal data without a good reason for us to keep it. If this happens, we will erase your data where possible and not be in breach of any legal or regulatory obligations by doing so. We will also consider whether we can redact or anonymise your data. This will not affect the lawfulness of any processing before your request.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask for further information to speed up this process.
We will aim to respond to your request within one month. Sometimes, it may take longer if your request is complex. In this case, we will update you.
Third Party Links
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements, and their security is not guaranteed. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Click on our website from a third-party website. We cannot be responsible for their privacy policies and practices of the owners and operators of that website and recommend you check the privacy policy of that third party website.
Contact Us
If you need to contact us regarding the use of your data please contact the data privacy officer us at:
Wilton Blue, 71-75 Shelton Street, Covent Garden, London, United Kingdom WC2H 9JQ.
We would appreciate a chance to resolve any concerns in the first instance.
If you are not satisfied with our response, you have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
Cookie Policy
This Cookie policy explains how we use cookies and similar technologies in our business, what these technologies are and why we use them. We also describe your rights to control our use of them.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website or application, for example, Instagram and LinkedIn. Cookies are widely used by online service providers, to, for example, make their websites or services work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner or service provider, in this case, Wilton Blue, are called “first party cookies”. Cookies set by parties other than the website owner, in this case our third-party service providers are called “third party cookies”.
Third party cookies enable third party features or functionality to be provided on or through the Website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third party cookies can recognise your computer both when it visits the Website or service in question and also when it visits certain other websites or services.
Why do we use cookies?
We use first-party and third-party cookies to track and target interests of visitors to our Website and our social media channels to improve the performance of our website and media applications to users. For example, we use cookies to tailor the content and information displayed to you to improve the functionality of our Website. We use third party cookies for analytics and other purposes which are described in more detail below.
Analytics Cookies
Google (_gat _ga) – Google Analytics gathers information allowing us to understand your interactions with our Website and help us to ensure we improve the experience for you.
Third Party Cookies:
Please note that we have no control over the cookies third parties use for example advertising networks and web traffic analysis services. Please see the cookie policies of third party providers for information on how they collect cookies. These third parties are likely to be analytical, targeting or performance cookies. Please refer to their website for the most current version of their cookie policy each time. Below are the policies for our third party social media applications:
Instagram: https://help.instagram.com/1896641480634370
Tik Tok: https://www.tiktok.com/legal/page/global/cookie-policy/en
LinkedIn: https://www.linkedin.com/legal/cookie-policy
Twitter: https://help.twitter.com/en/rules-and-policies/twitter-cookies
Facebook: https://www.facebook.com/help/1896641480634370
YouTube: https://www.youtube.com/intl/ALL_uk/howyoutubeworks/user-settings/privacy/
How to opt-out of cookies
You can change your web browser’s settings to reflect your cookie preferences. Use these links to find out more information about how to delete or disable cookies for these common browsers:
Also, you can opt out of third party advertising cookies at any time by visiting this page, or, by visiting the consumer page of the relevant third party to manage the cookies.
Just bear in mind that if you disable cookies, web beacons and similar technologies there might be some functionality that will not work nor, operate correctly on our website and social media channels.
Where can I get further information?
If you have any questions about our use of cookies or other technologies, please email us at: [email protected]
