1. About this policy
1.1. This is the privacy and cookies policy for the RO Group relating to the RO businesses: RO Trading Limited and RO Properties Ltd ("RO" , "we", "us" "our") registered in England at the registered office Graham House, 7 Wyllyotts Place, Potters Bar, EN6 2JD. See here for more key information about other trading businesses forming part of the RO Group or to access our group company websites.
1.2. This policy sets out what personal information is collected by the RO, how it is used, disclosed and protected and how you can exercise choices in respect of your information.
1.3. This policy covers website visitors to www.rogroup.co.uk and other persons of whom we hold personal data such as contractors, suppliers, clients, agents and tenants.
1.4. We are acting as Controller in respect of your personal data and it is therefore our responsibility to ensure that any sharing or processing of this data is compliant with:
a) The Data Protection Act 2018
b) The General Data Protection Regulations (EU) 2016
c) The Privacy and Electronic Communications Regulations 2003
1.5. If you have any questions, please contact us using the details at the end of this policy.
1.6. The RO is committed to ensuring that your privacy is protected and the personal information you provide will be used in accordance with this policy.
1.7. RO may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. This policy is effective from 25 May 2018.
2. What we collect - information you provide
Under the General Data Protection Regulations, personal information is defined as “any information relating to an identified or identifiable natural person”. Personal data, or personal information means any information about an individual, from which that person can be identified. We collect personal data, or personal information, directly from you, for example when you:
2.1. visit our website and complete a form or request other information on this site;
2.2. contact us by any means (e.g. telephone, email and written correspondence) and provide information about you to enquire about us or our services;
2.3. engage with one of our marketing emails or on social media;
2.4. engage us to provide services or we engage you to provide services on behalf of the RO;
2.5. participate in surveys or questionnaires we may email or provide to you.
3. Information collected automatically from your use of this website
When you visit our website we collect personal information you have submitted such as name, contact details and purpose of enquiry. We may automatically collect additional information from your device about your engagement with the site content. This may include information about the type of device you use to access the site and the type of browser you use, details of any website from which you have come to this site and log information such as your Internet Protocol (IP) address (the unique address that identifies your device on the internet) and when and how often and for how long you interact with the site. We may also approximate your location using your IP address. This information is used to collect broad demographic information about how visitors interact with the site to develop and improve the service we offer.
Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent this or to notify you each time a cookie is set. To find out more about cookies, including how to control and disable them using different types of browser, please visit http://www.allaboutcookies.org. Please note however that by blocking or deleting cookies you may not be able to access all features of the site.
You are under no obligation to provide any of the above information. However if you should choose to withhold requested information we may not be able to provide you with certain services.
4. Information collected from other sources
4.1. We may receive information about you from other group companies and subsidiaries of the RO. For example this may happen when an enquiry by you to one of the RO Group companies is referred to us in order to ensure an appropriate response to your enquiry.
4.2. We may also obtain your data from third parties such as estate / land agents or individuals with whom you have agreed to share your information.
4.3. We may capture your image by our CCTV cameras at our property sites.
5. Email marketing
We use Dotmailer to send out newsletters and marketing e-mails. More information on Dotmailer can be found at https://www.dotmailer.com/term.... We may use Dotmailer to contact you with emails in order for us to keep you updated with news which we feel is relevant to you and we consider a legitimate interest. Subscription to our newsletter and email marketing communication is voluntary and you can unsubscribe by following the link at the bottom of every email.
6. Google Analytics
We use the following types of cookies:
a) Strictly necessary cookies – we use a session cookie so that visitors can move smoothly from one page to another within the site
c) Performance cookies – we use performance cookies for the collection of information on how visitors to our site interact with our content. This derives aggregate statistics on site usage from which we can improve our site and services.
7. Social plug-ins
We have implemented social plug-ins from social networks so that you can share content of interest with friends and social connections.
You are under no obligation to provide any of the above information described in this section. However if you should choose to withhold requested information we may not be able to provide you with certain services.
8. What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular we process this information for the following purposes:
8.1. to carry out our obligations arising from any contracts entered into between you or your agents and us and maintain our internal records;
8.2. to improve our products and services;
8.3. to contact you where requested by you, by email, telephone or post in order to respond to your queries or comments;
8.4. to notify you about changes to our service.
9. Information Sharing
9.1. We may share personal information submitted by you with companies working on behalf of the RO. Our agents and contractors will only use your information to the extent necessary to provide their support functions and subject to appropriate safeguards.
9.2. We may disclose aggregate statistics about visitors to the site in order to describe our services to prospective partners but these statistics will not include personal identifiable information.
9.3. We may disclose your personal information to our agents or contractors who help us in providing services. Our agents and contractors will only use your information to the extent necessary to provide their support functions and subject to appropriate safeguards.
9.4. As mentioned above, we may, with your consent, pass your information to other group companies who may communicate information about their products or services.
9.5. In the event that we undergo a reorganisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
9.6. We reserve the right to disclose your personal information if legally entitled or required to do so (for example if required by law or by a court order or if we believe that such an action is necessary to prevent fraud or cybercrime or to protect the site, its visitors or our customers rights, property or personal safety.
9.7. We do not sell or distribute your personal data for commercial gain.
10. Security and data storage
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
When you give us personal information, we take steps to ensure that it’s treated securely and stored on secure servers in the United Kingdom and may also be transferred to other countries outside the European Economic Area (EEA). By way of example this may happen if one or more of our service providers are located outside the EEA. If we transfer your information in this way we will take steps to ensure that your privacy rights continue to be protected.
Policies and procedures are in place to safeguard it from loss, misuse and improper disclosure. We also have 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.
11. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
12. Legitimate interests
In specific situations, we require your data to pursue our legitimate business interests in a way which might reasonably be expected as part of running our business. We make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will 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).
13. Your rights
You may request details of personal information which we hold about you under the General Data Protection Regulations. You also have a right to correct any errors in that information or seek the erasure of your information in certain circumstances.
Please find below more details and information on how and when you can exercise your rights. We will respond to your request within one month. If the request of access is complex we reserve the right to extend the period by a further two months.
13.1. The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
13.2. The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.
13.3. The right to request deletion of your personal data if:
a) your personal data is no longer necessary for the purposes for which we collected or processed them; or
b) you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
c) you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
d) your personal data is unlawfully processed; or
e) your personal data has to be deleted for compliance with a legal obligation.
13.4. The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
13.5. The right to restrict the processing of personal data, if:
a) the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
b) the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
c) we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
d) you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
13.6. The right to data portability. You may request us to receive the personal data that concern you. You may also request us to send this personal data to a third party, where feasible. You only have this right if it regards personal data you have provided us, the processing is based on consent or necessary for the performance of a contract between you and us, and the processing is done by automated means.
14. Retention period for using your personal data
We 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, regulatory or reporting requirements. To determine the appropriate retention period for personal data, we consider:
a) the amount, nature, and sensitivity of the data;
b) the potential risk of harm from unauthorised use or disclosure of the data;
c) the purposes for which we process the data; and
d) the applicable legal requirements.
15. Contacting us
If you have any questions, comments, concerns or requests regarding your personal information, please write to: Graham House, 7 Wyllyotts Place, Potters Bar EN6 2JD or email [email protected]