Privacy policy 

Horler & Associates Privacy Notice

 

Horler & Associates privacy notice provides information on how Horler & Associates and any of its subsidiaries, branches or representative offices and any 3rd party providers collect, use, secure, transfer and share your information.

 

Horler & Associates Registered Address is:

211 Clarence Road

Windsor

Berkshire

SL4 5AN

 

It serves most major lenders, investors, house builders, commercial businesses, corporations, local authorities, housing associations and the general public via the following business units / divisions. Full details can be found on our website http://www.horler.co.uk/. 

 

Surveying	Horler & Associates panel manage and undertake valuations for the majority of UK mortgage lenders.
Marketing	Markets Horler & Associates services via a suite of websites and other means
Retail	Sales & Lettings Services

1. Types of Information Collected.

 

Typically Horler & Associates collect the following where applicable:

 

First name	How many Dependants?	Personal Debt Details	Salary
Middle Name	Dependants Name	Personal Expenditure	Accountant Details
Surname	Dependants DOB	Existing Mortgage Details	Previous Employers Details
Previous Name	Primary ID	Existing Insurance Details	Employers Address
Date of Birth	Address ID	Email Address	Employers Phone Number
Present Address	Bank Statements	Phone Numbers	Health
Residential Status Credit Card	Statements	New Property Details	Ethnicity
Previous Addresses Mortgage	Statements	Solicitor details	Credit Card Details
Landlord Details	Proof of Deposit	Estate Agent Details	Bank Details
Nationality	Payslips	New Mortgage Details
NI Number	Self Employed Accounts	New Insurance Details
UK National	Gender	Marital Status

 

1.1. Methods of Collection

In the general conduct of business, Horler & Associates collects information relevant to the services being sought across the range of services it offers (listed previously) from:

yourself

next of kin

spouse / partner / family member

business associates

Employers

£trusted£ sources including:

Government / Land / Police registers

Credit / Default Agencies

Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)

Insurance Companies

Other Law firms

Health providers

Through consent to third parties disclosing information about you to us that they have collected

 

 

Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our branches or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers. 

 

In addition, you may choose to submit information directly to us via several methods, including: 

through Horler & Associates websites

In response to marketing or other communications

Through social media

By signing up for a Horler & Associates product or service

Through participation in an offer, program or promotion

In connection with an actual or potential business or employment relationship with us

 

You may also agree to third parties disclosing information about you to us that those third parties have collected. 

 

Our service providers and partners may collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets. 

 

We may use third-party web analytics services on our websites and mobile apps The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps. 

 

“Your Rights and Choices” section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected. 

 

1.2. Purposes of Collection

Generally, we will collect, use and hold your information for the purposes of:

Assessing applications for and providing Horler & Associates products / services

Conducting business, developing relationships with Horler & Associates and affiliates

Process payments / transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities

Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent/franchise quality, integrity, compliance and security of business processes

Create and manage any accounts, associated authentication criteria (id£s and passwords) you may have with Horler & Associates.

Provide, administer and communicate with you about Horler & Associates products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.

Compile business directories, including business contact information

Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.

Developing new products and services

Managing communications, assess effectiveness and optimisation of advertising

Functionality of our websites, mobile applications other digital assets

Evaluate your interest in employment and contact you regarding possible employment opportunities

Enforce Horler & Associates £Terms of Use£, other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Horler & Associates or its affiliates.

Comply with industry standards and Horler & Associates policies

 

 

Anti-Money Laundering

 

In addition to help you with a property related service we have to comply with certain regulations for example the £Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (referred to as £the Regulations).£ Horler & Associates and other subsidiaries are required to obtain certain information from you to comply with regulations. The information provided will only be used by Horler & Associates in relation to complying with the Regulations and will not be shared with any other party outside of the companies wholly owned by Horler & Associates unless we are required to do so under law. 

 

If you decide to enter in to a business relationship with Horler & Associates or any wholly owned subsidiary to comply with certain regulations. 

 

We will require two separate Identification documents one primary and one secondary document even if it appears on both lists. The information may be required at various stages of the process depending whether you are: 

 

Purchasing/Selling or Letting 

 

Primary documents – proof of ID

Valid Passport with MRZ

Valid full UK photo driving licence

Valid full UK Driving licence (Non photo, paper) issued before 1998

Valid EU/EEA/Switzerland photo driving licence.

Valid EU/EEA/Switzerland national Identity Card.

Valid UK Armed Forces ID Card.

Valid UK Biometric Residence Permit (copy of both sides.)

Valid Blue disabled drivers pass. (With photo)

Valid Freedom Pass

Valid Local Authority Bus pass.

Department for Works & Pensions letter confirming pension details including National Insurance Number dated within the last 12 months.

Secondary documents – proof of residence (home.)

Valid full UK photo driving licence.

Valid full UK Driving licence (Non photo, paper) issued before 1998

Local authority council tax bill (dated within the last 12 months).

UK Bank / Building societies statements/bills showing activity, dated within the last six mths. Including account number and sort code. (Internet printed acceptable.)

UK mortgage statement (dated within the last 12 months.) (Internet printed acceptable.)

Utility bill dated within the last 6 months including – Electricity bill (with MPAN

number), Landline, Gas, Satellite TV, Water. (Internet printed acceptable.) (Not mobile phone bills.)

Her Majesty£s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement (dated within the last 12 months) with National Insurance number.

Department for Works & Pensions letter confirming pension details and NI Number. (Dated within the last 12 months).

 

 

We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search will not affect your credit rating 

 

1.3. Lawful basis of processing 

 

Horler & Associates processes your information under the following 

 

Performance of a contract: where you enter into a contract with Horler & Associates and we need to process your information as part of this contract

Legitimate interests: some information is processed by Horler & Associates as part of its legitimate interests which include :Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications , profiling , direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller

Public interest: some information is processed in accordance public interest such as relocations

Consent : where we process information under consent we will seek you clear and unambiguous consent prior to processing your data

 

 

2. Information We Share 

 

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to: 

 

Landlords and landlord associates and sub processors

Vetted affiliates and partners / Financial Institutions / Insurance Companies for business

facilitation to provide required services, such as mortgages, insurance cover etc.

Formally contracted service providers to perform services on our behalf:

Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services

Helpdesk, Call Centres etc.

 

 

We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements 

 

Councils, health and care providers

Other Law firms

Credit agencies, Land Registry Office, Her Majesty£s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies

Additionally we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.

Perspective employers requesting references via your written consent

 

 

On websites, features can be accessed where we partner with other entities that are not affiliated with Horler & Associates. These include social networking etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features. 

 

Horler & Associates reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect / use your information. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information. 

 

2.1 How long do we keep information for 

 

We will keep information for a reasonable amount of time in order to perform the purposes listed above. 

 

We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However Horler & Associates reserves the right to keep information for longer if we feel that this is in the legitimate interests of Horler & Associates. 

 

2.2 International Data Transfers 

 

Horler & Associates may transfer the personal information collected about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g. via program specific privacy notice). 

 

2.3 Profiling 

 

For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential un-authorised activities, Horler & Associates engages profiling activities via direct use or anonymisation of sensitive personal information. 

 

2.3.1 Direct Profiling 

 

Direct profiling is engaged for the fair and lawful purposes, to provide Horler & Associates the ability to enforce Horler & Associates £Terms of Use£, legal reporting as may be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over Horler & Associates or its affiliates; including, but not limited to: 

 

Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.

Background checks for existing and new employees, clients, business partners, affiliates

Financial Viability analysis / reports

Business partner / client portfolio position, performance, risk positions

Anti-money laundering

Tax reporting

Credit defaulting / exposure

 

 

2.3.2 Indirect Profiling 

 

Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following: 

 

Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.

Compiling and communicating promotional and marketing information about products and services that Horler & Associates, affiliates and other organisations that we have affiliations with have and that may be of interest to you.

Conducting market research

Facilitating our internal business operations, including the fulfilment of any legal requirements.

 

 

2.4 Your Rights and Choices

 

Your rights regarding the sensitive / personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you. 

 

You will be sent a web access form to complete and login to access your data. 

 

2.5 Access and Correction 

 

You may have the right to: 

 

obtain confirmation that we hold personal information about you

request access to and receive information about the personal information we maintain about you

receive copies of the personal information we maintain about you

 

 

The right to access personal information may be limited in some circumstances by local law requirements. 

 

To exercise these rights, please contact us as set forth below. 

 

2.6 Update and correct inaccuracies in your personal information 

 

If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information you feel is incorrect or inaccurate 

 

If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint. We will provide you with access to information we hold about you: 

 

2.7 Object to the processing of your personal information 

 

If you would like to object to any processing of your information by Horler & Associates you can contact us outlining what processing of information you would like to object to. 

 

2.8 Have the information blocked, anonymised or deleted 

 

If you would like Horler & Associates to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted , blocked or anonymised. 

 

To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified in the £How To Contact Us£ section below. 

 

2.9 Opting out of processing 

 

You can opt out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However without cookies you may not be able to use all of the website features and/or online services. 

 

You can at any time tell us not to send you marketing communications by

 

e-mailing lettings@horler.co.uk for all lettings enquiries and post@horler.co.uk for all sales enquiries.

unsubscribing via the £unsubscribe link£ within the marketing e-mails you receive from us,

or

contacting Horler & Associates as indicated below.

 

 

2.10 Withdrawal of consent 

 

If we obtain your information by consent you have the right to withdraw any consent you previously provided to us. 

 

If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information. 

 

Horler & Associates will apply your preferences going forward. Doing so will mean that you cannot take advantage of certain Horler & Associates and affiliate products, services and promotions. 

 

The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately. 

 

3 How to Contact Us / Complaints and Feedback 

 

If you: 

 

make a complaint about a breach of your personal information, applicable privacy laws / principles or a concern about Horler & Associates privacy practices

would like access and/or update information or preferences you provided to us,

 

 

You also may e-mail us at: 

 

lettings@horler.co.uk for all lettings enquiries

Or write to us at:

Horler & Associates

211 Clarence Road

Windsor

Berkshire

SL4 5AN 

 

 

post@horler.co.uk for all sales enquiries

or write to us at

Horler & Associates

242 Dedworth Road

Windsor

Berkshire

SL4 4JW 

 

 

If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us via the details in the “How To Contact Us” section below. 

 

To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time. If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can. 

 

3.1 How We Protect Personal Information 

 

The security of your personal information is very important and Horler & Associates is committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. 

 

Horler & Associates stores personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently deidentify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it. 

 

4 Updating this privacy statement 

 

We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.