Privacy Policy

WHO ARE WE?

We are Stirlin Group Limited, which, for the purposes of this policy, includes Stirlin Developments
Limited and Lodge Lane Developments Limited, trading as Homes by Stirlin.
If you have any questions about this Policy, or about how we look after your data generally, please
contact us on 01522 682752 or email info@stirlin.com.

INTRODUCTION

Both Stirlin Developments Limited and Lodge Lane Developments Limited (‘we’ or ‘us’ etc), are
‘data controllers’. This means that, under the Data Protection Act 2018 (the Act) and the EU General
Data Protection Regulation (GDPR), we may control and process your personal data.
We take privacy very seriously. We are committed to keeping your data secure and processing it
fairly and lawfully. We ask that you read this policy very carefully because it contains important
information about how we process your personal data.

PERSONAL DATA WE MAY COLLECT ABOUT YOU

We collect personal data directly from you via our websites or when we meet with you at our
sales sites or offices and via other communications between us when you make enquiries with, or
purchase a property or unit from us.

This information includes:

• Your name, address and contact details (usually email address(es), postal address and phone
  number(s))
• Your communication preferences
• The type and price of any property or unit you are looking for
• Details about the home you currently live in and its sale status and any other property relevant
  to your enquiry
• records of written and verbal communications between us either electronic or written
  why and when you want to move
• some demographic information about you and members of your household including age range,
  household type and profession
• CCTV images if you attend one of our sites where CCTV is operational
• Information about professionals advising you, such as your solicitor, mortgage broker and lender

In addition, we may monitor your use of our website through the use of cookies and similar tracking
devices. For example, we may monitor how many times you visit, which pages you go to, traffic
data, location data and the originating domain name of a user’s internet service provider. This
information helps us to build a profile of our users. Some (but not all) of this data will be aggregated
or statistical, which means that we will not be able to identify you individually. Please see further the
section on ‘Use of cookies’ below.

If you start the process of wanting to purchase a property or unit from us, we may also collect the
following information from you:

• Details of any mortgage or financial assistance
• Information required to support any equity loan scheme, such as Help to Buy
• Any extras or upgrade preferences
• Privacy Notice
• Financial or payment information for the purposes of taking payment for any extras or upgrades (although we do not store your payment details)
• Details of your utility providers and meter readings, if you purchase one of our properties

PERSONAL DATA WE MAY COLLECT FROM THIRD PARTIES

We may also receive information about you from other sources, such as:

Your professional advisors, including mortgage brokers, solicitors, estate agents and financial
lenders

• Our own solicitors and professional advisors
• Information already in the public domain
• Other companies within our group and our strategic partner Loge Lane Developments Limited
• Third party providers such as Rightmove and Zoopla
• Our own external estate or sales agents

HOW WE USE YOUR PERSONAL DATA

We are required to have a legal basis for processing your personal information. These are most
commonly:

• to perform or take steps to enter into a contract with you
• to comply with a legal obligation
• where we have your explicit consent, freely given
• where it is necessary for our legitimate interests and these are not overridden by your rights
• and interests

When you make an enquiry, we will use the personal information for the following reasons:

• follow up your enquiry and provide further information you have requested about any properties
  or units you have showed an interest in
• determine which of our properties or units may suit your needs, based on the information you
  have provided
• to make you aware of new sales releases, offers, events, promotions and other marketing
  information subject to your consent
• to tailor our products, understand how you heard about us, improve our website and adapt our
  marketing channels

Where you reserved or purchased one of our properties or units, we may also use your personal
information to:

• assist you in the journey of tailoring and purchasing a home from us
• provide after-sales support in performance of our contract with you
• obtain customer feedback on your home and the purchasing process based on our legitimate
  interests
• inform you about further developments and news, with your consent

We will also use your personal information to comply with our legal obligations, for example to:

• establish your identity
• comply with money laundering and fraud legislation
• prove succession of title

We may use your information to tailor our marketing activity based on your interests and preferences.
We will not use your information to carry out any automated profiling that could have a legal effect
on you.

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with:

• Third parties who provide services to us, such as our solicitors and professional advisors,
  contractors, suppliers and fitters
• Providers of shared equity loans, such as Help to Buy
• Your professional advisors, such as solicitors, estate agents, IFA, mortgage brokers and financial
  lenders, subject to your consent
• We will pass your details to our warranty provider, such as Premier Guarantee or NHBC, so they
  can issue a warranty certificate and to utility companies so they may provide you with their
  services
• We will take meter readings on the day you complete the purchase and pass these to the
  relevant utility company
• Management companies relating to sites upon which you live

MARKETING AND OPTING OUT

We will not contact you for the purposes of direct marketing unless you have asked us to do so.
However, if you have asked us to do so and later your change your mind, you can opt-out at any
time with no hassle. To do this, just let us know. See further ‘Your rights’ below for details about how
to contact us.

KEEPING YOUR DATA SECURE

We will use technical and organisational measures to safeguard your personal data, for example:

• Access to our systems is controlled by password and username which are unique to the user;
• We store your electronic personal data on secure servers;
• We store your paper records in locked storage rooms;
• We train our staff in good records management;
• Payment details are encrypted

Non-sensitive details (your contact details and preferences for example) are transmitted normally
over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive
to protect your personal information, we cannot guarantee the security of any information you
transmit to us, and you do so at your own risk. Once we receive your information, we make our best
effort to ensure its security on our systems.

TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE

We may store your data temporarily on our cloud service operated by Google. We have taken
appropriate steps to satisfy ourselves that your data will be secure during this process; we have a
contractual relationship with Google that underpins this. As part of that security, Google may store
your data in one or more or its international data centres, meaning that your data may be stored
temporarily outside of the European Economic Area. If you have any concerns about this, please
contact us using the details below.

INFORMATION ABOUT OTHER INDIVIDUALS

If you give us information on behalf of someone else, such as members of your household, you
confirm that the other person has appointed you to act on his/her behalf and has agreed that you
can:

• Give consent on his/her behalf to the processing of his or her personal data
• Receive on his/her behalf any data protection notices

HOW LONG DO WE KEEP YOUR DATA FOR?

As a general rule, we will not keep your data for any longer than is necessary to complete tasks or
provide you with services. We have a separate policy setting out retention periods for specific types
of data. You can ask to see this policy by writing to us, using the contact details under the “Your
Rights” section below. You also have the right to ask us to delete your data (sometimes known as
‘the right to be forgotten’.)

COOKIES

A cookie is a small text file which is placed onto your computer (or other electronic device) when
you access our website. If you use our website, we may use cookies to:

Track your use of the site;

• Recognise you whenever you visit this website (this speeds up your access to the site as you do
  not have to log on each time);
• Obtain information about your preferences, online movements and use of the internet;
• Carry out research and statistical analysis to help improve our content, products and services
• and to help us better understand our visitor/customer requirements and interests
• Target our marketing and advertising campaigns more effectively
• Make your online experience more efficient and enjoyable

If you do not want to accept cookies, you can change your browser settings so that cookies are not
accepted. If you do this, please be aware that you may lose some of the functionality of this website.
For further information about cookies and how to disable them please go to: www.aboutcookies.
org or hwww.allaboutcookies.org

If you visit our website when your browser is set to accept cookies, we will interpret this as an
indication that you consent to the use of cookies. This includes cookies that are essential in order
to enable you to move around the site and use its features and cookies that are not essential but
gather information about your use of the site

YOUR RIGHTS

You have various rights under the Act and the GDPR, including the following rights:

• Right to object: If we are using your data because we deem it necessary for our legitimate
  interests to do so, and you do not agree, you have the right to object. We will respond to your
  request within 30 days (although we may be allowed to extend this period in certain cases).
  Generally, we will only disagree with you if certain limited conditions apply.
• Right to withdraw consent: Where we have obtained your consent to process your personal
  data for certain activities (for example, providing you with services), or consent to market to
  you, you may withdraw your consent at any time.
• Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm
  what information we hold about you at any time, and you may ask us to modify, update or
  delete such information. At this point we may comply with your request or, additionally do one
  of the following:
  – we may ask you to verify your identity, or ask for more information about your request; and
  – where we are legally permitted to do so, we may decline your request, but we will explain
  why if we do so.
• Right to erasure: In certain situations (for example, where we have processed your data
  unlawfully), you have the right to request us to “erase” your personal data. We will respond to
  your request within 30 days (although we may be allowed to extend this period in certain cases)
  and will only disagree with you if certain limited conditions apply.
• Right of data portability: If you wish, you have the right to transfer your data from us to another
  data controller. We will help with this – either by directly transferring your data for you, or by
  providing you with a copy in a commonly used machine-readable format.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a
  complaint with your local supervisory authority, details of which can be found below.

To exercise any of your rights concerning your information, please send an email to the following
address:

info@stirlin.com

Or write to us at the following postal address:
Stirlin Developments Ltd
11 Sadler Court
Lincoln
LN6 3RG

We may ask you to provide us with proof or your identity. Please do not be offended; this may
occur even if we know you. It is a requirement of the GDPR in some cases.

REVIEW

This Policy was last reviewed on 23.08.2018
We may change this privacy policy from time to time. You should check this policy occasionally to
ensure you are aware of the most recent version which will apply each time you access our website.

THE INFORMATION COMMISSIONER’S OFFICE

More information about privacy laws can be found at www.ico.org.uk
Details of your local supervisory authority: The Information Commissioner’s Office. You can contact
them in the following ways:

Phone: 0303 123 1113
Email: casework@ico.org.uk
Live chat, via the ICO website
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF