2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information: (a) information about your computer and about your visits to and use of this website; (b) information that you provide to us when registering with our website; (c) information that you provide when completing your profile on our website; (d) information that you provide to us for the purpose of subscribing to our email notifications, SMS marketing and/or newsletters; (e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services.
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
2.3 We collect information through Google Analytics. For information that Google may collect please see the Google Privacy & Terms at www.google.com/policies/privacy/partners/. If you do not want your data to be used by Google Analytics, please install the Google Analytics Opt-out Browser Add-on available from tools.google.com/dlpage/gaoptout.
2.4 Some data will be collected automatically by Our Site, through Google Analytics. Other data will only be collected if you voluntarily submit it by emailing us. Depending upon your use of Our Site, we may collect some or all of the following data: (a) IP address (automatically collected); (b) Domain details (automatically collected); (c) Web browser type and version (automatically collected); (d) Operating system (automatically collected); (e) A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected); (f) Geographic location.
2.5 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.
3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to: (a) administer our website and business; (b) personalise our website for you; (c) send you email notifications that you have specifically requested; (d) send you our email newsletter, if you have requested it; (e) send you SMS marketing, if you have requested it;
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information: (a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
4.5 We only use the data collected by Google Analytics to understand how our website is used.
4.6 Some of our external third parties are based outside the European Economic Area (“EEA”) so their processing of your personal data may involve a transfer of data outside the EEA.
4.7 Whenever we transfer your personal data out of the EEA, we 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 European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
4.8 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5. Retaining personal information
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
5.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
5.4 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.
6. Security of personal information
6.1 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.
6.2 However, the transmission of information via the internet is never 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.
6.3 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.
6.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 Under the Data Protection Legislation you may be entitled to the following rights:
(a) Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at Apollo House, Mercury Park, Wycombe Lane, Wooburn Green, Buckinghamshire, HP10 0HH, by using our website contact form, or by telephone on 01494 685930.
(b) You can ask us to rectify any inaccuracies in the personal information that we hold about you.
(c) To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
(d) To object to our processing of your personal data where we are relying on a legitimate interest (or that 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.
(e) To restrict our processing of your personal data (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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 (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
(g) Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
(h) To access information held about you. 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.
8.2 You can exercise any of the above rights at any time by contacting us at Apollo House, Mercury Park, Wycombe Lane, Wooburn Green, Buckinghamshire, HP10 0HH, by using our website contact form, or by telephone on 01494 685930.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.3 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.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.5 We use both session and persistent cookies on our website.
11.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
(a) we use session cookies on our website to enable the use of your account on the website, administer the website, prevent fraud and improve the security of the website and to personalise the website for each user;
(b) we use persistent cookies on our website to recognise a computer when a user visits the website and to analyse the use of the website.
11.8 When you first access our website, a cookie message will pop up in your browser asking you to confirm whether you consent to our use of non-essential cookies. By ticking the box, you are agreeing to our use of such cookies as set out in this policy
11.10 You can withdraw your consent to the use of non-essential cookies on our website at any time. Generally you can also restrict, block or delete the cookies which are set by any websites by changing your internet browser settings. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. If you delete cookies relating to this website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor next time you visit the site.
12. Our details
12.1 This website is owned and operated by Elivia Homes Limited.
12.2 We are registered in England and Wales under registration number 5011077, and our registered office is at Apollo House, Mercury Park, Wycombe Lane, Wooburn Green, Bucks, HP10 0HH.
12.3 You can contact us by writing to the business address given above, by using our website contact form, by using our website contact form or by telephone on 01494 685930.
Anti-Slavery and Human Trafficking Policy
Modern slavery is a crime resulting in abhorrent abuse of the human rights of vulnerable workers, including children. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.
Elivia Homes Group has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
Elivia Homes Group also expects the same high standards from all of its suppliers, contractors and other business partners and expects that its suppliers will in turn hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment.
In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour.
This policy applies to all individuals working for the Group.
Responsibility for the policy
The Board of Directors has overall responsibility for ensuring that this policy complies with the Group's legal and ethical obligations. The Managing Director has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of the Group's business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Group or under the Group's control. You are required to avoid any activity that might lead to a breach of this policy.
If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with the Group's Disclosures in the Public Interest Policy. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Group's business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Group's supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the Government's Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
The Group aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Group is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
The Group may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.