GDPR & Our Privacy Notice

Big Red Property Box Limited Group
Privacy Notice

Trading as Alexander Fleming, Shepway Homes, AF Management, HytheProperty.co.uk &
FolkestoneProperty.co.uk



The Big Red Property Box Limited Privacy Notice provides information on how the company and
any of its subsidiaries, branches or representative offices and any 3rd party
providers collect, use, secure, transfer and share your information. Big Red Property Box Group, is a
provider of Residential Property Consultancy Practices, Surveying Services,
Leasehold Estate Management, Property Letting Service, Residential Sales and Valuations.
The Group operates from 2 offices based in Hythe and Folkestone, Kent, under
the trading names of Alexander Fleming, Shepway Homes, AF Management, HytheProperty.co.uk
& FolkestoneProperty.co.uk, as well as an online presence via corporate
website and property portals.

1. Types of Information Collected.

Typically, Alexander Fleming collect:

*Copies

1.1. Methods of Collection

In the general conduct of business, Alexander Fleming collects information relevant to the
services being sought across the range of services it offers (listed previously)
from:

• Yourself.

• Next of kin.

• Spouse /
partner / family member.

• Business
associates.

• Employers.

• “Trusted” sources including: • Government / Land / Police registers.

• Credit / Default Agencies • Financial Institutes (Banks, Building Societies, Loan
Agencies, Credit Card companies).

• Insurance Companies.

• Other Law firms.

• Health providers.

• 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 branches 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 Alexander Fleming website and affiliates websites.

• in response to marketing or other communications.

• through social media.

• by signing up for an Alexander Fleming product or service.

• through participation in an offer, program or promotion.

• in connection with an actual or potential business or employment relationship with us.

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 include: IP address, browser type,
operating system, referring URLs and information on actions taken or
interaction with our digital assets.

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 Alexander Fleming products / services.

• Conducting business, developing relationships with Big Red Property Box Group 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 Alexander Fleming.

• Provide, administer and communicate with you about Alexander Fleming 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.

• Enforce Alexander Fleming’s “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 Alexander Fleming or its
affiliates.

• Comply with industry standards and Big Red Property Box Group policies.

Anti-Money Laundering Regulations

In addition to help you with a property related service we have to comply with certain
regulations for example the “Money Laundering, Terrorist Financing and Transfer
of Funds (Information on the Payer) Regulations 2017 (referred to as “the
Regulations).” Alexander Fleming and other subsidiaries are required to obtain
certain information from you to comply with regulations. The information
provided will only be used by Alexander Fleming in relation to complying with
the Regulations and will not be shared with any other party outside of the
companies wholly owned by Big Red Property Box Group unless we are required to
do so under law.

If you decide to enter in to a business relationship with Alexander Fleming Estate Agents or any
wholly owned subsidiary to comply with certain regulations.

We will require two separate Identification documents one primary and one secondary document
even if it appears on both lists. The information may be required at various
stages of the process depending whether you are:

Purchasing (or Selling) Primary documents - proof of ID.

• Valid Passport with MRZ • Valid full UK photo driving licence.

• Valid full UK Driving licence (non-photo, paper) issued before 1998.

• Valid EU/EEA/Switzerland photo driving licence.

• Valid EU/EEA/Switzerland National Identity Card.

• Valid UK Armed Forces ID Card.

• Valid UK Biometric Residence Permit (copy of both sides.)

• Valid Blue Badge disabled drivers pass. (with photo.)

• Valid Freedom Pass.

• Valid Local Authority bus pass.

• Department for Works & Pensions letter confirming pension details including National
Insurance Number dated within the last 12 months. Secondary documents - proof
of residence (home.)

• Valid full UK photo driving licence.

• Valid full UK Driving licence (non-photo, paper) issued before 1998.

• Local Authority council tax bill (dated within the last 12 months.)

• UK Bank / Building societies statements/bills showing activity, dated within the last 6 months.
Including account number and sort code. (Internet printed acceptable.)

• UK mortgage statement (dated within the last 12 months.) (Internet printed acceptable.)

• Utility bill dated within the last 6 months including - Electricity bill, Landline, Gas,
Satellite TV, Water. (not mobile phone bills.)

• Her Majesty’s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement
(dated within the last 12 months) with National Insurance number.

• Department for Works & Pensions letter confirming pension details and NI Number. (dated
within the last 12 months).

We reserve the right to employ third party electronic verification for the purpose of
verifying identity. This search will not affect your credit rating.

1.3. Lawful basis of processing

Alexander Fleming processes your information under the following:

• Performance of a contract: where you enter into a contract with Alexander Fleming and we need
to process your information as part of this contract.

• Legitimate interests: some information is processed by Alexander Fleming as part of its
legitimate interests which include: Fraud, risk assessment, due diligence,
network and information security, suppressions and managing opting out of
communications, direct marketing, monitoring, web analytics, cloud storage,
acquisitions, updating customer details, lettings, sales, property management, financial
services and other core products and services provided by the data controller.

• Public interest: some information is processed in accordance public interest such as
relocations and sale / rental prices.

• Consent: where we process information under consent we will seek your 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:

• Landlords and landlord associates and sub processors.

• 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 (Software as a Service – SaaS, Platform
as a Service – PaaS, Infrastructure as a Service – IaaS)

• 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.

• Other 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.

• Prospective employers requesting references via your written consent on websites, features
can be accessed where we partner with other entities that are not affiliated
with Alexander Fleming. 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.

Alexander Fleming 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
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 6 years after last contact with you.
However, Alexander Fleming reserves the right to keep information for longer if
we feel that this is in the legitimate interests of Alexander Fleming.



2.2 International Data Transfers

Alexander Fleming may transfer the personal information collected about you to recipients
in countries other than the country in which the information was originally
collected. Those countries may not have the same data protection laws as the
country in which you initially provided the information. When we transfer your
information to other countries, we will protect that information as described
in this Privacy Notice or as otherwise disclosed to you at the time the data is
collected (e.g. via program specific privacy notice).



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 below.



2.5 Update and correct inaccuracies in your personal
information

If you feel that the information we hold about you in incorrect or inaccurate you can contact us
outlining the information you feel is incorrect of inaccurate If we refuse to
correct your personal information, we will provide you with a written notice
that sets out the reasons for our refusal (unless it would be unreasonable to
provide those reasons) and provide you with a statement regarding the
mechanisms available to you to make a complaint. We will provide you with
access to information we hold about you:



2.6 Object to the processing of your personal
information

If you would like to object to any processing of your information by Alexander Fleming 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 Alexander Fleming 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 as specified in
the “How To Contact Us” section below.



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 by using the Cookie Consent tool
displayed in the website (the browser you use may provide options on how to opt
out of receiving certain types of cookies). However, without cookies you may
not be able to use all of the website features and/or online services.

Alexander
Fleming operate 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 privacy@alexanderfleming.co.uk

• unsubscribing via the “unsubscribe link” within any marketing e-mails you receive from us, or

• contacting Alexander Fleming 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. Alexander Fleming we will apply your preferences
going forward. Doing so will mean that you cannot take advantage of certain Alexander
Fleming and affiliate products, services and promotions. The right to consent
removal may be limited in some circumstances by local law requirements and you
will be informed appropriately.



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 a concern about Alexander Fleming privacy practices.

• would like access and/or update information or preferences you provided to us,

You also may
e-mail us at:

privacy@alexanderfleming.co.uk

Or write to us
at:

Julian Alexander

Group Data
Protection Officer

84 High Street,

Hythe.

Kent. CT21 5AJ



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 via the details
in the "How To Contact Us" section above.

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 Alexander Fleming 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 our
website from which we transfer certain personal information.

Alexander Fleming stores personal information only for as long as it is necessary for the
fulfilment of the purpose for which the personal information was collected,
unless otherwise required or authorised by applicable law. We take measures to
destroy or permanently de-identify personal information if required by law or
if the personal information is no longer required for the purpose for which we
collected it.



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.

25th May 2018