Cluttons LLP on behalf of its subsidiary companies, including Cluttons Investment Management (UK) LLP, associated undertakings and licensees is committed to protecting and respecting your privacy.

This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (GDPR), the data controller is Cluttons Investment Management (UK) LLP of Yarnwicke, 119-121 Cannon Street, London EC4N 5AT.

Information we may collect from you

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site www.cluttonsim.com (our Site). This is limited to basic contact information which you provide at the time of registering interest in a particular property or requesting further services or information;
• If you contact us, we may keep a record of that correspondence and your contact details;
• Details of your visits to our Site including, but not limited to, traffic data, location (country), IP address and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Lawful Basis

Our lawful basis for processing this data is:

• Our legitimate interest in improving the usability of our website
• Negotiation of a potential contract with you at your request
• Our legitimate interest in marketing similar goods and service
• If we complete a transaction or enter into a contract – our legal obligations (for example under the Finances Act 2008)

The consequences for you if we are unable to process this data would be:

• Website analytics – none
• Data entered into forms on our website – we will not be able to provide you with the information about properties or services you are interested in or information about similar properties and services.

Retention

Data collected for purposes of website analytics is retained for 26 months.

Data collected for marketing purposes may be retained for up to 7 years unless you request we delete it earlier.

If you enter into a contractual arrangement or complete a financial transaction with us we may retain information for up to 7 years to meet our legal obligations (for example under the Finances Act 2008).

All information you provide to us is stored on our secure servers. 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 to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

USES MADE OF THE INFORMATION

You have the following rights with regard to your personal data:

• Access – you may request we provide you with the data we hold
• Rectification – you may request we correct any inaccurate data
• Erasure – you may request we erase your data
• Restriction – you may request we process your data only for specified purposes.
• Objection – you may object to us processing your data
• Portability – you may request we provide you or a nominated party with your data in an electronically readable format

You can exercise your rights at any time by contacting us at [email protected].

You also have the right to lodge a complaint with the Information Commissioner’s Office or any other European Supervisory Authority.

We provide unsubscribe buttons on all our marketing communications by which you may remove yourself from our marketing list. We also provide check-boxes on the forms on our website by which you may control the purposes for which we process your data.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected].