Privacy Policy
Introduction
This is the privacy policy for Ralph Rose Property Group Limited (collectively referred to as “Ralph Rose”, “we”, “us” or “our” in this policy), our sites such as ralphroseproperty.com and our associated apps (“our sites”). Some of our other sites and services have their own policies, which will be relevant to you when you are using those sites and services.
Our values guide everything that we do – including our approach and how we use personal data. We are strongly committed to keeping your personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any Ralph Rose service which uses personal data to the deletion of that data.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
• Information about your rights, the choices available to you, and our obligations in the UK, European Union and elsewhere.
• Transparency about how we collect and use your personal data, including when and how it is shared.
• Information on how we protect your personal data.
• Information on how we will facilitate your rights and respond to your questions.
About this privacy policy
This privacy policy explains how we collect, use, share, and transfer your personal data when you use the services provided on our sites or interact with us. This privacy policy also explains your data privacy rights.
Personal data is any information about you by which you can be identified or be identifiable. This can include information such as:
• Your name, date of birth, gender, email address, postal address, phone number, mobile number or financial details, such as payment cards you use for reserving, selling, letting or renting a property.
• Information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based).
• Information relating to how you use and interact with our sites and services.
When we refer to “personal data” in this policy, we are also referencing “personal information,”.
Sometimes our sites may contain links to sites and services that are not part of the Ralph Rose family of offerings.
Who we are
Ralph Rose Property Group Ltd, 91 Wimpole Street, London, W1G 0EF is the data controller in respect of your personal data that you share with us. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “Contact us for information about how we use your personal data” section below.
The types of personal data we collect about you
We collect your personal data when you visit our sites, subscribe for newsletters or services, enquire with Ralph Rose, or reserve, let, rent or sell a property. We will only collect your personal data in line with applicable laws. We collect your personal data in the following ways:
• Directly from you, e.g. when you sign up or enquire online or on the phone, register for products or services, including by signing up for newsletters, webinars including through the Ralph Rose website
• Personal data we generate about you, e.g. personal data we use to authenticate you, or personal data we generate about you from your IP address or your preferences.
• Personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts and/or payment service providers (e.g. Paypal).
The types of data we may collect include: identity data; contact data; financial data; details of your dependents; transaction data (including, for example, details of your property requirements); IP address; website usage data; marketing and communication preference data; call recordings; information in your application form and CV; proof of right to work; employment history; criminal convictions and offences.
“Sensitive Personal Information” includes information about your racial or ethnic origin, or religious beliefs, physical or mental health or condition, sexual life or orientation, or information about criminal convictions. In certain circumstances, you may also provide us with such Sensitive Personal Information, for example if you have disability related requirements.
When you register or enquire with Ralph Rose on ralphroseproperty.com, we collect:
• Your name.
• Your email address.
• Phone number.
• Mobile phone number.
• Other details such as your contact number and residential or billing address
Personal data we generate about you
When you register, enquire online or sign up for a newsletter, we assign you a unique ID number. We use this to manage your preferences, for example, the newsletters you have subscribed to. When you register for an account we use your unique ID to recognise you when you are signed in to our services.
When you use our sites we may also use cookies or similar technologies to collect extra data, including:
• Your IP address – a numerical code to identify your device, together with the country, region or city where you are based.
• Your geolocation data – your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment.
• Information on how you interact with our services.
• Your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites.
• Details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content.
We will not collect special categories of data from you – such as personal data concerning your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that type of personal data to us.
How we collect personal data
We collect personal data when you:
• Direct interactions (personal data you disclose when you fill in forms, surveys, or correspond with us by post, phone, email, live chat, web, social or otherwise; through the job application process; or through property portals when you enquire about our services).
• Indirect interactions (personal data you disclose to third parties such as payment service providers, data brokers or aggregators (e.g. TwentyCi, Rightmove, Zoopla (based inside the UK/EU), or Facebook (based outside the EU); or which is available through publicly available sources or registers such as Companies House, the Electoral Register, Government or Police Databases).
• Aggregated data (personal data, usually anonymised or aggregated to groupings, from systems such as our website, CRM or phone systems; or service providers such as credit check or profiling companies).
Information You Provide Directly
This category includes the personal data that you provide directly to us through various methods such as:
Completing forms or surveys on our website or via our social media platforms.
Communication with us via post, phone, email, live chat, or similar channels.
During the job application process if you choose to apply for a career with us.
Interacting with property portals to enquire about the services we offer.
Information Received from Third Parties
Personal data that we may receive indirectly from third-party sources includes:
Information shared with payment service providers, data intermediaries, or property data aggregators such as TwentyCi, Rightmove, and Zoopla within the UK/EU, and entities like Facebook when outside the EU.
Data available through public registers or databases, like Companies House, the Electoral Register, or government and law enforcement databases.
Aggregated and Anonymised Data
We also collect data that is aggregated or anonymised which means it does not directly identify you. This can include:
Usage data from our website, customer relationship management (CRM) systems, or telecommunication systems.
Information from service providers, including those performing credit checks or creating user profiles, that is used in a non-identifiable way for analysis or demographic grouping.
We also collect personal data through cookies and other similar technologies. Please refer to our cookie policy for more details on how we use cookies.
How we use your personal data
We use personal data collected through our site only when we have a valid reason and the legal grounds to do so.
We determine the legal grounds based on the purposes for which we have collected your personal data.
Legal grounds for using your personal data. The legal ground may be one of the following:
• Consent: Often we will use your personal data because we have asked for your consent, which you can withdraw at any time.
• Performance of a contract with you (or in order to take steps prior to entering into a contract with you): We will use your personal data if we need to in order to perform a contract with you.
• Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
• Our legitimate interests: We may process your personal data where it is necessary for our legitimate interests in a way that might be expected as part of running Ralph Rose and in a way which does not materially impact your rights and freedoms. For example, it is in our legitimate interests for us to understand our customers and clients, promote our services and ways to support us, and operate our business.
We gather your personal information for a variety of reasons: to manage transactions like purchases, rentals, sales, or leases associated with properties through Ralph Rose or our clients; to communicate with you about services and promotions we believe may be relevant to you regarding property transactions; during your employment application process with us; and when it is required to fulfil our legal duties. This includes adherence to laws and regulations applicable to money laundering, estate and letting agencies, and any relevant codes of practice, or whenever lawful processing is permitted.
Additionally, we process your personal data to support and enhance our operations, develop our offerings, improve efficiency, manage client relationships, train our staff, and uphold customer service excellence.
This can involve network security, monitoring, auditing, call recording in compliance with the Investigatory Powers Act 2016 (informing callers of recording for quality and training purposes), compliance training, identity verification, fraud prevention, assessing risks, facilitating utility changes, performing due diligence, marketing (sharing an encoded email address with third parties like Facebook and Google to tailor ads for you on their platforms), analytics, debt collection, optimising and personalising advertising, delivering targeted marketing materials, content management for our digital platforms, ensuring optimal website presentation, providing customer assistance, communicating changes in our services, list management for suppressing contacts, profiling, utilising cloud storage services, integrating new business acquisitions, and managing referrals.
In certain situations, to safeguard our right to a commission and prevent disputes, we may disclose your name to other agents, landlords, or sellers.
We process your personal details for the following purposes:
To register you as a new applicant, vendor, or landlord.Legal Ground: This processing is necessary for the legitimate interests of our business.
To carry out the services for which you have engaged us, including:
The collection and administration of rent on behalf of landlords, and the forwarding of such payments to them.
The recovery of debts owed to our firm.
Legal Grounds:
a. This is necessary for the performance of a contract to which you are party.
b. It is necessary for our legitimate interests, namely the recovery of debts.
To tailor the content and adverts on our website to you, and to gauge the impact of the advertising we deliver to you. Legal Ground: This processing is necessary for our legitimate interests, which include analysing how our customers use our services, developing them, driving business growth, and shaping our marketing strategy.
To make personalised recommendations for properties or services that we believe might interest you. Legal Ground: This is necessary for the legitimate interests of developing our services and growing our enterprise.
We also rely on the legitimate interests below to use your personal data:
• For internal administrative purposes related to our services – such as our accounting and records.
• To inform you of any changes to our services, such as updates to our terms and conditions.
• To enable you to share our content with others using social media or email.
• When we respond to your queries and to resolve complaints.
• To troubleshoot technical issues on our sites and their functionalities.
• When we de-identify or anonymise personal data.
• For security and fraud prevention, and to ensure that our sites are safe and secure and used in line with our terms of use.
• To contact you directly via social media or email if you send us emails or engage with the Ralph Rose on social media or contact us.
Where we rely on cookies to collect any personal data please see our cookie policy for more information and how to manage your cookie choices through our “Privacy Settings” link on our sites in the footer of every page.
Where personal data has been de-identified or anonymised, it will not be used in order to re-identify individuals.
Sharing Your Personal Data
We may disclose your personal data to reputable third parties outside the Ralph Rose Group, such as: parties with whom we hold contractual relationships for the execution or assistance in property transactions; IT and systems administration service providers; services for verifying compliance with anti-money laundering regulations; tenancy deposit schemes (or alternatives such as deposit replacement services); utility switching firms; utility providers; trade contractors; survey and valuation companies; Energy Performance Certificate (EPC) providers; inventory clerks; managing agents; property auction houses and providers of auction legal packs; local councils and law enforcement; Government bodies (e.g., HM Land Registry); property developers; third-party data services that aid us in segmenting and understanding our audience for more tailored and effective communication; advertisers and advertising networks (including social media platforms) for the purpose of serving relevant Ralph Rose adverts to you on the basis that you are a user of that platform and a contact of Ralph Rose; professional advisors including solicitors, bankers, auditors who offer consulting, banking, legal, insurance, and accounting services, as well as insurers; credit reference or debt collection agencies; other estate agents where a sub-agency agreement exists and they have brought forward a potential buyer/seller/landlord/tenant for your property; the other party involved in your property transaction; property portals through which you have engaged our services; and other entities should we decide to sell, transfer, or merge parts of our business or assets.
Marketing Preferences
We aim to empower you with regard to the use of your personal data, especially in the context of marketing and adverts. To this end, we’ve put in place certain measures to help you control your information:
Personalised Offers from Us
Based on your Identity, Contact, Technical, Usage, and Profile Data, we may infer your preferences to determine what offers or information could be relevant to you. This enables us to tailor our marketing to suit your needs and interests. If you’ve requested information from us or signed up on our website and have not opted out, you may occasionally receive curated marketing content from us.
Marketing from Other Organisations
We may share your information within our group of companies for marketing purposes. Not external companies for marketing, but only if you have not opted in for such sharing.
How to Opt-Out
Should you no longer wish to receive marketing communications from us, you can opt out at any time. This can be done by clicking the opt-out link in any marketing communication you receive, or by contacting our Data Protection Officer through the contact information provided in our privacy policy. Do note, however, that opting out of marketing communications does not apply to personal data provided to us as a result of a transaction or service request.
Use of Cookies
You have the ability to configure your browser to reject all or some cookies, or to alert you when cookies are being sent. Bear in mind that blocking cookies may affect the functionality of this website. For details on the cookies we use, please consult our cookie policy.
Use of Data for New Purposes
We will use your personal data only for the reasons it was initially collected, unless we reasonably determine we need to use it for another, compatible reason. If you wish to understand how the new processing aligns with the original purpose, please reach out to our Data Protection Officer. Should we need to use your personal data for a new, unrelated purpose, we will inform you and clarify the lawful basis for such processing. Please be aware that we may process your personal data without your awareness or consent, in line with the aforementioned guidelines, if required or permitted by law.
Data Protection
We are dedicated to safeguarding your personal information with a robust combination of technical and organisational measures. For instance, access to your personal information is strictly limited to individuals and third parties who have a legitimate need to access it, all bound by a duty to keep the information confidential. We proactively conduct surveillance on outbound email communications to protect sensitive and personal information, which aids us in the early detection of any potential data breaches. In the event of a data breach, we will report to the Information Commissioner’s Office as required by law. Should the breach be of a significant nature, we may also consider it necessary to inform you directly.
Data Retention
Our policy is to hold your personal information while you are engaged with our services or in communication with us, plus a minimum of ten years thereafter to comply with legal, regulatory, and financial reporting requirements. Should there be a necessity to extend the retention period of your data, we will weigh this need against the potential risks of such continued storage. We may opt to anonymise your personal data, detaching it from your identity, allowing us to utilise the anonymised information indefinitely without specific time constraints. Normally, we maintain recordings of telephone calls for six months, although this period may be extended if necessary for ongoing inquiries or legal claims.
In the event you submit a job application with us, should your application not be successful, we will preserve your personal data for six months following our decision to demonstrate fair recruitment practices. Furthermore, we will keep your details on file for an additional eighteen months for consideration in future openings at our company. If you would rather we not retain your details for potential future vacancies, you are welcome to let us know at info@ralphrose.com.
Your Rights Under Data Protection Law
Under the law, you are entitled to a suite of rights regarding the protection and handling of your personal data, including:
Right of Access: You can request a copy of the personal data we process about you. This includes information about:
• Our processing purposes.
• The categories of personal data concerned.
• The recipients to whom the personal data have been or will be disclosed.
• How long we intend to store your data or the criteria to determine that period.
Right to Object: You are entitled to object to our processing of your personal data, which you can exercise by:
• Advising a Ralph Rose operator during a call.
• Selecting the appropriate options on our data collection forms.
• Adjusting preferences.
• Emailing info@ralphrose.com.
Right to Rectification: You have the right to correct any inaccurate personal data we hold about you.
Right to Erasure: You can request the deletion of your personal data from our records.
Right to Restrict Automated Decision-Making: You can request not to be subject to decisions based purely on automated processing.
Right to Data Portability: If feasible technically, you can ask for your personal data to be transferred to a third party in a structured, commonly used, and machine-readable format.
Note that we will continue to communicate with you regarding the services you have requested or to inform you of changes to our terms, even if you opt out of marketing communications.
These rights are subject to specific conditions and exemptions, and we may not be able to fulfill your request in certain circumstances. We will inform you if that is the case. Generally, we aim to respond to your request within one month, but the response time could be longer for complex or multiple requests.
To ensure the security of your data, we may request additional information to verify your identity before proceeding with any request.
Typically, there is no charge to exercise your rights. However, we may impose a reasonable fee or refuse to act on a request if it is unfounded, repetitive, or excessive.
Right to Withdraw Consent for Marketing
You can withdraw your consent to receive marketing communications at any time by:
Updating your preferences.
Clicking the opt-out link in any marketing message.
Contacting us at info@ralphrose.com.
Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal. We will continue to process your data for the purpose of fulfilling our contract and for legal and regulatory reasons.
Sharing Your Data for Third-Party Marketing
We will only share your personal data with external companies for direct marketing purposes if we have your explicit, opt-in consent.
If you decide you no longer wish to receive third-party marketing, you can opt out using the instructions provided in their communications, or by reviewing their privacy policies on how to unsubscribe.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@ralphroseproperty.com. Alternatively, write to us at Data Protection Officer, Ralph Rose Property Group Limited, 91 Wimpole Street, Marylebone, London, W1G 0EF.
Anti-Money Laundering Commitment
At Ralph Rose, we conduct our operations with the utmost transparency, adhering to the stringent legal and regulatory frameworks that govern our industry. We recognise the potential vulnerability of the property sector to the illicit intentions of organised crime for money laundering. Our proactive stance involves rigorous compliance with the authorities and the prompt reporting of any dubious transactions to the National Crime Agency.
In our earnest efforts to thwart such malpractices, we rigorously follow all Anti-Money Laundering legislation, including but not limited to the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010, and the Terrorism Act 2000.
This policy is universally applicable to all parties we engage with, from sellers and purchasers to landlords and renters. We are obliged to secure and preserve evidence of our clients’ identities for at least seven years and, where necessary, validate the legitimacy of property ownership and the trajectory of funds. Should we fail to verify these details, we regret that we must refrain from proceeding with any services. An electronic identity verification, which might encompass a credit check, is a component of our due diligence process.
For details on acceptable forms of ID, please follow the provided link.
Our adherence to the Money Laundering Regulations 2017 is monitored by HM Revenue & Customs. For discussions regarding our Anti-Money Laundering policies, do get in touch at info@ralphroseproperty.com.
Limitation of Liability
By using our website, you accept full responsibility for its application and the data you derive from it, with all implicit or explicit guarantees, conditions, and stipulations being dismissed, save as law permits.
Except for our accountability for causing death or injury through our negligence, we, along with all contributors to this website, disclaim all responsibility for any losses or damages you may incur—directly or indirectly—in connection with the use, the inability to use, or your reliance on the content within this website.
While we are dedicated to maintaining the quality and ongoing availability of our website, we do not guarantee its continuous operation or accessibility.
If any clause within our terms and conditions is rendered unenforceable, this will not affect the validity and enforceability of the remaining clauses.
These terms and conditions are subject to English law, without impinging on your statutory consumer rights.
Ralph Rose Property Group Ltd is a registered entity in England and Wales (company number 15402699), with our headquarters at 91 Wimpole Street, London W1G 0EF.
