Privacy Notice
1. Important Information
1.1 The Howard de Walden Estate respects your privacy and is committed to protecting your personal data.
1.2 Thisprivacy noticeinforms youhow HowarddeWaldenEstatesLimited(referredtoas “Howard de Walden Estates”, “HdWE”, “we”, “us” or “our” in this privacy notice) processes your personal data through all your engagements with us whether it be through using this website, service utilisation, or from any engagement, including any data you may provide when you contact us, our newsletters or request information about services from us. If you are a tenant or a prospective tenant, please consult our Tenant Privacy Notice which can be found here.
1.3 Itisimportantthatyoureadthisprivacynoticetogether withanyotherprivacy noticeor fair processing notice we may provide on specific occasions when we are collecting or processing personal dataabout yousothatyouarefullyawareof howand why weare using your data. This privacy notice supplements the other notices and is not intended to overridethem.
1.4 Our websiteis not intended for children.
1.5 Howard de Walden Estates Limited is the controller and responsible for your personal data. Please find our contact information at the end of this Privacy Notice.
2. The Data we Collect About you
2.1 We may collect, use, store and transfer different kinds of personal data about you whenever you contact us, including through this website, for example:
2.1.1 IdentityData includes - first name, maiden name, last name, username or similar identifier, marital status, title, date of birth andgender.
2.1.2 ContactData includes – billing address, delivery address, email address and telephone numbers.
2.1.3 CommunicationsData includes correspondence or messages (including emails, WhatsApp or SMS) that you send to us.
2.1.4 TechnicalData includes - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in typesandversions,operatingsystemandplatformandothertechnologyon the devices you use to access this website.
2.1.5 UsageData includes - information about how you use our website or services.
2.1.6 MarketingData- includes your preferences inreceiving marketingfrom us and our third parties and your communication preferences.
2.2 Personaldata,orpersonalinformation,meansanyinformationaboutanindividualfrom whichthatpersoncanbeidentified.Itdoesnotincludedatawheretheidentityhasbeen removed (anonymous data).
2.3 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to providethat data when requested, wemay not beable to performthecontractwehaveoraretryingtoenterintowithyou(forexample,toprovide you with our lease or tenancy services). Inthis case, we may have tocancel a service you have withus but we will notify you if this is the case at the time.
2.4 Itisimportantthatthepersonaldataweholdaboutyouisaccurateandcurrent.Please keep us informed if your personaldata changes during your relationshipwith us.
3. How is your Personal Data Collected
We usedifferent methods tocollect data from andabout youincluding through:
3.1 Directinteractions. You may give us your Identity, Contact and Financial Data by filling in forms, agreements or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide whenyou
3.1.1Apply for our services;
3.1.2Enter into an agreement withus;
3.1.3Subscribe to our service or publications;
3.1.4Request property details to be sent to you;
3.1.5Give us some feedback;
3.1.6lLike our social media pages;
3.1.8 Followour social media pages; and
3.1.9 Contact us via our social media pages.
3.2 Automatedtechnologiesorinteractions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.Wecollectthispersonaldatabyusingcookies andothersimilartechnologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3.3 Thirdpartiesorpubliclyavailablesources. We may receive personal data about you from various third parties and public sources as set out below:
3.3.1 Analytics providers such as Google
3.3.2 Credit and referencechecking agencies
3.3.3 Property agent networks
3.3.4 Identity andContact Datafrompubliclyavailablesources suchas Companies House and the Electoral Register
4. How we use your Personal Data
4.1 Our use of your personal data shall be strictly in accordance with applicable legal requirements. Data protection law requires us to have a valid reason to process your personal information for each of the different purposes for which we use that information. The law refers to each reason as a 'lawful basis'.
4.2 Generally wedonot rely on consent as alegalbasis for processingyour personaldata other thaninrelationtosendingthirdparty directmarketingcommunications toyou via emailor text message. Should youwish toopt out of such marketing communications, you may withdraw consent to marketingcommunications at any time by contacting us.
4.3 Below is a table outlining the purposes for which we intend to use your personal data, the legal grounds for processing, and, where applicable, the legitimate interests that justify such processing.
Purpose/Activity
To manage our relationship with you, including communicating with and notifying you of updates
To send our newsletter or an invitation to an event to you or information about our available properties
To notify you about changes to our terms or privacy policy
To make suggestions and recommendations to you about properties or services that may be of interest to you
To analyse and improve our websiteand services.
To respond to or assist public authorities.
4.4 Marketing
Identity Data Contact Data Communications Data
Identity Data Contact Data Communications Data MarketingData
Identity Data Contact Data
Identity Data Contact Data Communications Data
Technical Data Usage Data
Identity Data Contact Data Communications Data Technical Data
Necessary for our legitimate interests (to communicate with you and keepyou up todate).
Where you have provided your consent to us sending you marketing communications.
Necessary to comply with alegal obligation.
Necessary for our legitimate interests (to develop our services and grow our business).
Necessary for our legitimate interests (to develop and improve the website).
Necessary for our legitimate interests (to assist public authorities).
Westrivetoprovideyouwithchoicesregardingcertainpersonaldatauses,particularly around marketing and communications. You will receive marketing communications from us if you have opted to do so, haverequested information from us or entered into
4.5
a contract for services from us or if you provided us with your details when you registered interest in one of our properties in each case, you have not opted out of receiving such marketing.
Third-partymarketing
Wewillobtainyourconsentpriortodisclosinganypersonaldatatothirdpartiesfortheir marketing purposes.
4.6 Optingout
You can ask us to stop sending you our marketing communications including newslettersordetailsofpropertiesatanytimebycontactingus:MarketingDepartment, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163 or by email: marketingandcommunications@hdwe.co.uk Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship we have with you.
4.7 Cookies
Ourwebsiteusescookiestodistinguishyoufromotherusersofourwebsite.Thishelps ustoprovideyouwithagoodexperiencewhenyoubrowseourwebsiteandalsoallows us to improve our site. For more information about what cookies we use and how you can manage these cookies see our cookies policy.
5. Disclosures of your Personal Data
5.1 Where necessary, we may share your personal data with relevant third parties for the operation of your contract with us, for example with:
Internal third parties
External third parties to enable us to provide maintenanceand service facilities
Specific third parties listed in the table above
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Thirdpartieswithwhomweareunderadutytodiscloseorshareyourpersonaldata to comply with any obligations or protect our rights or the safety of our customers or others.
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with thelaw. We generally do not allow our third-party service providers to use your personaldata for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We willonly transfer your personal data out of the UK where appropriate safeguards (such as the UK International Data Transfer Agreement) have been put in placeto ensure that your personal data and your privacy rights are protected.
7. Data Retention
7.1 Wewillonlyretainyour personaldataforas longasnecessarytofulfilthepurposeswe collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
7.2 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 processyourpersonaldataandwhetherwecanachievethosepurposesthroughother means, and the applicable legal requirements.
7.3 Insomecircumstancesyoucanaskustodeleteyourdata:see‘Request erasure’ below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your Rights
8.1 You have a number of rights under data protection laws in relation to your personal data. When exercising any of the rights set out below, we may ask you for information to confirm your identity and, where applicable to help us locate your personal information.
8.2 You have the right to:
8.2.1 Requestaccess to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Pleasenotethatwhereyouexerciseyour rightofaccess,wearerequired by law to carry out a reasonable and proportionate search for your personalinformation.Whenrespondingtoyourrequest,exemptions(such as where disclosing your information would reveal legally privileged informationorthird-partypersonaldata)mayapply,meaningthatyoumay notalwaysreceiveallthepersonalinformationthatweprocessaboutyou. We consider and apply exemptions on a case-by-case basis.
8.2.2 Requestcorrection of the personal data that we hold about you. This enablesyoutohaveanyincompleteorinaccuratedata weholdaboutyou corrected,thoughwemayneedtoverifytheaccuracyofthenew datayou provide to us.
8.2.3 Requesterasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
8.2.4
Objecttoprocessing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about
8.2.5
your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.Youalsohavetheright toobjectwhereweareprocessingyour personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Requestrestriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the followingscenarios:(a)ifyouwantustoestablishthedata’saccuracy;(b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.2.6
8.2.7
Requestthetransfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawconsent at any time where we are relying on consent to process your personal data.However,this willnot affect the lawfulness of any processing carried out before you withdraw your consent. If you withdrawyour consent, we may not be able to provide certainproducts or services to you. We will advise you if this is the case at the time you withdraw your consent.
8.2.8 Complaintous about how we use your personal data. Please see the complaints section below.
8.3 If you wish to exercise any of the rights set out above, please contact us using the contact details set out below.
8.4 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.6 We try torespond to alllegitimaterequestswithin one month.Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enablingthose connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leaveour website, we encourage you toread the privacy notice of every website you visit.
10. Changes to this
Privacy Notice
We may update this privacy notice from time to time by publishing a new version on our website and advise you to regularly check www.hdwe.co.uk for the latest version.
11. Contact Details
The Data Protection Officer (DPO) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact the DPO using the following details: Data Protection Officer, Howard de Walden Estates Limited, 23 Queen Anne Street, London, W1G 9DL. Telephone: +44 (0)20 7580 3163, Email: DPO@hdwe.co.uk
12. Complaints
From19June2026,youwillalsohavetherighttocomplaintousabouthowwehandle yourpersonal dataor other people’sinformation. Whereyoumakeacomplaint,wewill acknowledge your complaint within 30 days and respond to it without undue delay.
If you have a complaint about how we manage your information, please contact us at companysecretary@hdwe.co.uk orDPO@hdwe.co.uk orwritetousfortheattentionof the Company Secretary, 23 Queen Anne Street, London W1G 9DL.
If,aftercompletingourinternalcomplaintsprocedure,youremaindissatisfied,youhave the right to escalate your complaint to the Information Commissioner’s Office by telephone on 0303 123 1113 or at: Make a complaint about how an organisation has used your personal information | ICO
13. Glossary
LawfulBasis
“Legitimate interest” means our business’s necessity to conduct and manage operations effectively, which enables us to give you the best service and most secure service and experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personaldata for activities whereour interests areoverridden by the impacton you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of acontract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply witha legal or regulatory obligation”means processing your personal data as required by law or in accordance with a regulatory obligationto which we are bound.
