PRIVACY POLICY

Millerson is a data controller and is responsible for your personal data (collectively referred to as “Millerson”, “we”, “us” or “our” in this privacy statement). This means that we are responsible for deciding how we hold and use personal information about you.

The Millerson privacy notice provides information on how Millerson and any of its representatives or branches both sales and lettings and 3rd party providers collect, use secure, transfer and share your information. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Millerson operate 4 Sales offices and 2 Lettings branches throughout Cornwall and West Devon.

Millerson has its Head Office at:

Millerson, Head Office, Comprigney House, Comprigney Hill, Truro, TR1 3EF

PropertyManagement	Millerson specialise in property management providing leasehold propertymanagement services
Marketing	Millerson markets via a suite of websites and other means including socialmedia
Retail	Sales and Letting Services from branches covering Cornwall
Commercial	One department covering all aspects of the commercial market whetherletting, selling or business transfers

1. Types Of Information Collected.

Typically Millerson will collect:

1. First Name	2. Middle Name	3. Surname	4. Previous Name
5. Date of Birth	6. Present Address	7. Residential Status	8. Previous Address
9. Landlord Details	10. Nationality	11. NI Number	12. UK National
13. Doctors Details	14. How Many Dependants	15. Dependants Names	16. Dependants Date of Births
17. Primary ID*	18. Address ID*	19. Bank Statements*	20.Credit Card Statements*
21. Mortgage Statements*	22. Proof of Deposit	23. Payslips*	24. Self Employed Accounts*
25. Employers Name	26. Gender	27. Personal/Secure Loan Details	28. Personal Debit Details
29. Personal Expenditure	30. Existing Mortgage Details	31. Existing Insurance Details	32. Email Address
33. Phone Numbers	34. New Property Details	35. Solicitor Details	36. Estate or Letting Agent Details
37. New Mortgage Details	38. New Insurance Details	39.New Insurance Details	40. Criminal Offences/Convictions

41. IP Address	42. Cookies	43. Marital Status	44. Salary
45. Accountant Details	46. Previous Employers Details	47. Employers Address	48. Employers Phone Number
49. Health	50. Ethnicity	51. Credit Card Details	52. Bank Details
53. Non resident landlord approval numbers received from HMRC	54. Credit search/Credit score details

1.1 Method of Collection

In the general conduct of business, Millerson collects information relevant to the services being sought across the range of services listed above 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, 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 Millerson and affiliates’ websites

• In response to marketing or other communications
• Through Social Media
• By signing up to a Millerson 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 parties have collected. Our service providers and us collect certain information by using automated means, such as cookies and web beacons when you interact with our advertisements, mobile applications or visit our website pages and other digital assets. The information we collect in this manner may include IP address, Browser type, Operating System, Referring URL’s and information on actions taken or interaction with our digital assets.

We may use third party web analytics 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 Policy 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 purpose of:

• Assessing applications for and providing Millerson products/services
• Conducting business, developing relationships with Millerson and affiliates
• Processing payments/transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities
• Protecting against and preventing fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent quality, integrity, compliance and security of business processes
• Create and manage accounts, associated authentication criteria (ID’s and passwords) you
• may have with Millerson
• Provide, administer and communicate with you about Millerson products and services, offers, programs and promotions, their issuers, acquirers and partners.
• Compile business directories, including business contact information
• Operate, monitor, evaluate and improve our products, services, websites, mobile applications or other digital assets and business
• Developing new products and services
• Managing communications, assess effectiveness and optimisation of advertising
• Functionality of our website, mobile applications and other digital assets
• Evaluate your interest in employment and contact you regarding possible employment opportunities
• Enforce Millerson "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 Millerson or its affiliates.
• Comply with industry standards and Millerson Standards.

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 or Funds(Information on the Payer) Regulations 2017{ Referred to as "The Regulations")." Millerson SW LLP is required to obtain certain information from you to comply with regulations. The information provided will only be used by Millerson in relation to comply with the regulations and will not be shared with any other party outside the company unless we are required to do so under law. If you decide to enter in to a business relationship with Millerson 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 Purchasing, Selling or Letting or Renting

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 Residences Permit(Copy of Both sides)
• Valid Blue disabled drivers pass(With photo)
• Valid Freedom Pass
• Valid Local Authority Bus Pass
• Department for Works and 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 6 months. 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 account number) Landline, Gas, Satellite TV, Water. (Internet printed acceptable) (Not mobile phone bills)
• Her Majesty’s Revenue and Customs{HRMC) 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

Millerson processes your information under the following

• Performance of contract: Where you enter into a contract with Millerson and we need to process your information as part of this contract.
• Legitimate interests: Some information is processed by Millerson as part of its legitimate interests which includes: 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 with public interest such as relocations.
• Consent: Where we process information under consent we will seek your 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:

• Vetted affiliates and partners / Financial Institutions / Insurance Companies for business facilitation to provide required services such ass mortgages, insurance cover etc.
• Formally contracted service providers to perform services on our behalf: Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services ( Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
• 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 {HRMC), Financial
• Conduct Authority (FCA) and other regulatory bodies.
• Additionally, we may share information about you, if legally required, to prevent harm or financial / reputation or 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 Millerson. These include social networking, geo-location tools 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.

Millerson reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business assets, with reasonable efforts for the acquirer protect/use your information consistent with our Global Privacy Notice. You can exercise your rights to contact the acquiring entity with the 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 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 our last contact with you. However, Millerson reserves the right to keep the information for longer if we feel that this is in the legitimate interests of Millerson.

2.2 Profiling

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

2.3.2 Indirect Profiling

Indirect profiling via anonymization or 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 advertising 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 Millerson, affiliates and other organisations that we have affiliations with having and that may be of interest to you.
• Conducting 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.

2.5 Access and Correction

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

2.6 Update and Correct Inaccuracies In Your Personal Information

If you feel 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 access to the 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 Millerson 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 Millerson 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 the website features and/or online services.

Millerson operate a cookie policy. Some of our service providers and partners may collect information about your online activities over time and across third party websites to customise and target our adverts. You can at any time tell us not to send you marketing communications by

• Email to privacy@millerson.com
• Unsubscribing via the "unsubscribe link" within the marketing emails you receive from us or
• Contact Millerson 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 us.

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

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

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 Millerson privacy practices
• Would like to access and/or update information or preferences you provided to us please email us at:

privacy@millerson.com
or write to us at:
Paul Le Bas
Millerson, Head Office, Comprigney House, Comprigney Hill
Truro, TR1 3EF
Phone Number: 01872 225 995

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 as stated above in the "How To Contact Us" section. 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 Millerson 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. We use SSL encryption on a number of our websites from which we can transfer certain personal information.

Millerson 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 de-identify 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.

Date of Creation April 2018

PLB – MS – 18/4/2018 Privacy Statement V.1