At CS Property Group Ltd (trading as CSPG) we are committed to protecting and respecting your privacy.
This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.
Our contact details
Have you got any questions about this policy and our privacy practices?
- Send us an email to firstname.lastname@example.org
- Write us a letter to our office at CS Property Group Ltd, 2 Falcon Gate, Shire Park, Welwyn Garden City, Hertfordshire, AL7 1TW
Who are we?
We are a group of companies working on behalf of landlords and tenants for property management and other property related services.
In this policy any references to ‘CSPG, ‘we’, ‘us’ or ‘our’ is to CS Property Group Ltd and companies owned by CS Property Group Ltd (subsidiaries), including CS Lets Ltd, CS Block Management Ltd, Clean Start Construction Ltd and Clean Start Furniture Ltd.
CS Property Group Ltd (“CSPG”) is a company registered in England and Wales (registered number is 11530729).
Any reference to “you” or “your” is a reference to you as a user/customer/client of a CSPG website or our services.
Children’s privacy protection
Our services are not designed for, or intentionally targeted at, children 13 years of age or younger. We do not intentionally collect or maintain data about anyone under the age of 13.
How do we collect information from you?
Information you give us directly
You may give us your personal information yourself, by filling forms online or by corresponding with us via emails, post or otherwise. This includes personal data you provide when you:
- Fill-up web-forms on our website
- Send us an email
- Telephone or text us
- Send us a WhatsApp message (as an alternative to text messaging)
- Send us a message via marketing platforms, such as SpareRoom, OpenRent, IdealFlatmates, Zoopla and other platforms where we may advertise our rooms/services
- Send us a message/enquiry via social media where we have our presence, such as Facebook, Instagram, LinkedIn, etc
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
- National Landlord Association (based inside EU)
- Companies House (based inside EU)
- Electoral Register (based inside EU)
What type of information is collected from you?
Depending on the nature of your engagement with us – we may collect the following data from you:
- Identity (name, gender, date of birth, personal profile information, picture of yourself, copy of passport, payslips from work or bank statements, NI number, nationality, previous addresses)
- Contact (email address, residential address, billing address, telephone numbers)
- Financial (bank account and payment details)
- Transaction(details about payments to/from you)
- Technical (internet protocol address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, location data and other similar identifying information required for the customer’s device(s) to communicate with websites and applications on the internet)
How and why is your information used?
How long is your information kept for?
We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).
We review our retention periods on a regular basis.
Who has access to your information?
We do not sell or rent your information to third parties.
We do not share your information with third parties for marketing purposes.
However, we may disclose your information to third parties to achieve the other purposes set out in this policy. These third parties may include:
- Service providers acting as processors who provide IT and system administration services
- Tenancy deposit administrators (such as the Tenancy Deposit Scheme)
- Referencing agencies (we use NLA at the moment) to be able to identify you, confirm your current and past residency, check linked addresses, check electoral roll search, perform CCJ search, validate bank account, check previous tenancy references, calculate affordability, verify income/employment.
- Insurance agencies to be able to obtain rent guarantee insurance when necessary
- Our business partners with whom we have working relationships to provide property management and room lettings services to satisfy your property management needs
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or marketing.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it like when you buy CSPG’s or a subsidiary company’s named products and services.
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority.
Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share your information with the emergency services.
Where it is reasonably necessary to achieve our (or others’) legitimate interests. We consider the following to be our legitimate interests in running CSPG towards our goals and ideals:
- send post, text or email communications in relation to services or products we provide;
- conduct research to better understand the market and to gather feedback;
- monitor who we deal with to protect CSPG against fraud, money laundering and other risks;
- enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers;
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us by law.
You have a choice about whether you wish to receive information from us. If you do not want to receive certain communications from us, then simply contact us by email email@example.com (or other alternative contacts above) stating your preference and we will amend our records accordingly.
Under UK data protection law, you have certain rights over the personal information that we hold about you.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office, https://ico.org.uk/
If you would like to exercise any of your right below – please send us an email to firstname.lastname@example.org or alternatively use contact details or postal address provided above. We may be required to ask for further information and/or evidence of identity before we disclose any information.
Right of access
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, phone or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email, phone or by post (see above).
Right to restrict use
You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.
Right of erasure
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object
You have the right to object to processing where we are using your personal information based on legitimate interests.
Keeping your information safe
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.
Non-sensitive details (such as your email address, etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We retain personal information for a length of time appropriate for the activity we are undertaking in accordance with lawful processing as described above. This does not affect your rights and choices. Our contact details will be clearly shown on our correspondence for any queries relating to the use of data.
Changes to this policy
Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you’re happy with any changes.
Review of this policy
We keep this policy under regular review. This policy was last updated in November 2019