Kellen Homes Website Privacy Notice

The website www.kellenhomes.com (the site) is owned and operated by Kellen Homes Limited (we or us).

Your privacy is important to us. This privacy notice explains what personal data is collected by us when you visit our site, how it is collected, how we may use that information, where we store it, how long we store it for and how we protect it. We will also explain your rights in relation to your personal data and how the law protects you.

Please read the following carefully to understand our views and practices regarding your personal data and how we may collect and treat it. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This site is not intended for children and we do not knowingly collect data relating to children. For convenience, we have divided our data protection policies into two separate pages:

Our Privacy Notice (this notice)
Our Cookie Notice

This notice explains more about how we may collect personal data about you via cookies (it also explains what cookies are).

If you have any questions please do not hesitate to contact us at data@kellenhomes.com or, if you would prefer to call or write to us, then you can find our contact details at the bottom of this page.

Who we are

We are a registered company in England and Wales. Our registered number is 12807501 and our registered office is at 1st Floor, 103 Dalton Avenue, Birchwood Park, Warrington, United Kingdom, WA3 6YF.

We have appointed a Privacy Manager who 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, please contact the Marketing department by e-mailing Data@kellenhomes.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This site 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 data about you. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy notice of every website you visit.

The personal data we collect about you

This privacy notice applies to our site, www.kellenhomes.com and any other services that we may provide to you through our site (we’ll just call these “our services” for short).

In the context of this privacy notice “personal data” means information which, on its own or in combination with other information, can be used to identify you, in particular by reference to an identifier such as your name, your address, or location data. It does not include data where the identity has been removed (anonymous data).

Because we are a business located in England, the personal data that you give us or that we collect from you will be held under UK data protection legislation (but we’ll just refer to this as “the legislation”). The legislation requires that we tell you that we are a data controller for your personal data or, in other words, we determine the purposes for which and the manner in which any of your personal data are, or are to be, processed by us.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone number.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, 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 this site.
Profile Data your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our site, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. 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 site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide the personal data

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 into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to our service or publications;
- request marketing to be sent to you;
- reserve a property on one of our developments;
- enter a competition, promotion or survey;
- complete a contact us form on our site; and
- give us some feedback.
Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://kellenhomes.com/cookie-policy further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google based outside the EU;
  - advertising networks based inside OR outside the EU; and
  - search information providers based inside OR outside the EU
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

How we use your personal 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:

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure 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 personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of contract 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 with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our site, products/services, marketing, customer relationships and experience	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To process your property reservation including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have therefore established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company or third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or any other transactions between us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly. For more information about the cookies we use, please see https://kellenhomes.com/cookie-policy .

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

Please remember that our Cookies Notice covers matters such as using your personal data for analytics purposes.

In some cases we may disclose information about you with select third-parties:

Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you or providing you with services.
Debt collection agencies where you have breached a condition of any contract entered between us and you.
If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about you may be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any agreements with you, or to protect our rights, property, or safety of our pupils, our employees, or others.
Service providers acting as processors based in the UK who provide IT and system administration services, email or website hosting services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we store your personal data

The personal data that we collect from you will be stored within the United Kingdom. We will not knowingly transfer your personal data outside of the European Economic Area (EEA).

Where it may be necessary for us to transfer your personal data outside of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO.
Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK .

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 and they are subject to a duty of confidentiality.

All personal data you provide to us is stored on our secure servers. Any online payment transactions will be encrypted using Secure Socket Layer/Transport Layer technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted from our site and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We apply a ‘Privacy by Design’ approach to protecting your personal data in order to promote privacy and data protection compliance from the start.

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.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access 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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about 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. You also have the right to object where we are processing your 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (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.
Request the transfer 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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.

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.

We try to respond to all legitimate requests within 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.

How long will you hold onto my personal data?

Depending on how you engage with us it may be necessary for us to store your personal data for shorter or longer periods of time. Either way, we will only store your personal data will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

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.

Please remember that this privacy notice only applies to how we may collect, store, use, and retain your personal data when you visit our site. If you become our client , then you will be bound by the terms of additional policies that specifically relate to how we may use your personal data

Changes to our privacy notice

We may need to change this privacy notice if it’s necessary for legal reasons or to reflect changes to our site and services. In any case, the provisions of this privacy notice may be changed without prejudice to your rights. When we change our privacy notice we will make the updated privacy notice available on our site and we will also update the “Last Updated” date.

Once we change our privacy notice, it will become legally binding on you 30 days after we post it on our site. During that period you’re welcome to contact us if you have questions about the changes.

If you don’t agree with our changes to the privacy notice (regardless of whether you get in touch with us) then unfortunately we may need to restrict or limit your use of the parts of our site that require your personal data in order for us to deliver our services to you. We’re sorry we have to say that, but we hope you’ll appreciate that in order for certain parts of our site to work properly and in order for us to identify you in connection with our services we need to have everyone using our site and our services under the same rules instead of different people having different rules – that’s why we encourage you to get in touch with us if you have queries.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

This version was last updated on July 2021 previous versions can be obtained by contacting us.

Contact us

If you have any questions, comments or requests regarding our privacy notice then please do not hesitate to get in touch with us. To make things easier for both of us we would appreciate it if your queries were addressed to:

Data Privacy Manager
Kellen Homes, 1st Floor 103 Dalton Avenue, Birchwood Park, Warrington, United Kingdom, WA3 6YF

data@kellenhomes.com