PRIVACY AND COOKIES POLICY

Part A – Privacy Policy

Introduction and Purpose

Beech Holdings Investments Limited (company number 12597964) of 60 Oxford Street, Manchester, M1 5EE and our group of companies are committed to protecting and respecting the privacy and security of personal information. Our affiliated companies, trading entities and subsidiaries include (amongst others) Manchester Apartments Limited (company number 12599656), APTSM Limited (company number 09628875), Stephen Beech trading as Beech Properties, Manchester Property Development Holdings Limited (company number 9328893), Beech Construction Partnership Limited trading as Beech Design & Build (company number 06989319) and BH Estate Agents Ltd (company number 13544239) (Beech Holdings Investments Limited together with each company within its group whether detailed above or otherwise shall together be referred to as the Beech Holdings Group for the purpose of this privacy policy).

This privacy policy is issued on behalf of the Beech Holdings Group so where we mention “we”, “us” or “our” in this policy, we are referring to the relevant company in the Beech Holdings Group responsible for processing your data. This policy describes how we collect, use and look after your personal information.

We are a “data controller” which means that we are responsible for deciding how we hold and use your personal information. We are required under UK data protection laws to notify you of the information contained in this policy and we adhere to guidelines published in the Data Protection Act 2018 and the UK General Data Protection Regulation.

This notice applies to current and former tenants and leaseholders, current and former investors, subscribers, those third parties intending to become tenants and investors, prospective, current and former buyers and sellers to whom we provide estate agency services, visitors to our websites, and those who have used or registered for any of our products and/or services.

By registering, applying for or investing in any of our products and/or services, or by visiting any of our websites (Site) including mapartments.co.uk, beechholdings.co.uk, beechproperties.co.uk and beechdesignandbuild.co.uk and any of our Site landing pages, you are accepting and consenting to the practices described in this policy. Please note however that our Sites may include plug-ins, applications and/or links to websites of third parties who are not part of the Beech Holdings Group. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our Sites, we encourage you to read the privacy policy of every website you visit.

Information we collect about you

For your information, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data. We will collect, process the following data about you:

1. Information that is given to us (either by you or another party acting on your behalf for example, your solicitor)

This is information about you that we obtain from your applications for accommodation, investment, buying or selling, by filling in forms on our Site (including online booking and online query forms), by completing a paper-based application form (which we enter into our computer system), completing an application or enquiry form on our touch screen systems, corresponding with us by phone, e-mail, post, WhatsApp, Live Chat, website, Facebook adverts and other social media platforms or otherwise, or if you provide information to us through a third party.

It includes information you provide when you register to use any of our services, including any services on our Site, ask a question on our Site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey and when you report a problem with our Site.

The information you (or another party acting on your behalf) give us may include:

• identity and contact data, including your full name (and any previous names you might have had), address (including residential status and previous addresses), e-mail address, phone number, date of birth, marital status, national insurance number, nationality, next of kin, name of university or college where you are studying (if applicable), personal identification (including passport, driving licence, visa/immigration document and proof of address);
• transaction data, including your property address (or prospective property address), term, rent, deposit, utility and service responsibilities; guarantor identity, contact and financial data, the employment status and income information of you and/or your guarantors (if any), the address(es), contact details (including email, phone) of the employer(s) and/ or accountant(s), payroll numbers, length of employment, salary information and any other income received. Should you engage with any of our products and/or services, we may also hold such transaction data that you provide to us, or that we learn of, during our dealings with you.
• financial data, including your bank account details including branch name, address, name of account holder, account number, sort code, international bank identifier number, any other financial information including credit history, and financial and lease information relating to the investment product or service. Should you engage with any of our products and/or services, we may also hold such financial data that you provide to us, or that we learn of, during the term of our dealings with you.
• marketing and communication data, including your preferences in receiving marketing from us and our third parties, and your communication preferences.

Personal data is kept in files or within our secure IT systems.

Other than the information we gather about your nationality, we do not collect, store and/or use any other ‘special categories’ of personal information about you.

1. Information we collect about you.

With regard to each of your visits to our Site we will automatically collect the following information:

• technical information, which may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform;
• information about your visit to our Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our help team number.
• usage data, including information about how you use our website(s), products and services.
• images are being recorded on some of our premises for crime prevention and the safety of both the public and our property by means of CCTV and you may appear in some of these images if you visit any of our premises.
• if you contact us using the telephone numbers listed on our Site, we may record calls for training and monitoring purposes and so will have a record of all of the information you provide to us on such calls.
• Information we receive from other sources

We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and solicitors) and may receive personal data about you from various of these third parties and public sources. We will process and store such information in accordance with this privacy policy at all times.

How we use your personal information

We will only use personal information when the law allows us to. The law says that we must identify a lawful basis for each use of personal data. We rely on a number of lawful bases, including:

1. Where we have obtained freely given, specific, informed and unambiguous consent from you to use your personal information in certain ways, for example in marketing communications.

2. Where we need to perform a contract that we are about to enter into, or have entered into, with you.

3. Where we need to comply with a legal obligation.

4. Where we need to use personal information to pursue our legitimate interests (or those of a third party) and we believe that using personal information in that way is not overridden by the interests or fundamental rights of the person to whom the information relates.

We use information held about you in the following ways:

Information given to us (either by you or another party acting on your behalf). We may use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to enable us to supply you with the services and information which you have requested and/or engaged us to provide;
• to help manage your tenancy, lease, investment, sale or purchase;
• to carry out due diligence on any prospective tenant, leaseholder, investor purchaser or seller, including whether there is any money judgements against them, or any history of bankruptcy or insolvency;
• to analyse the information we collect so that we can administer, support, improve and develop our business and the services we offer;
• to contact you in order to send you details of any changes to our services, products or supplies which might affect you;
• to provide you with information about other goods and/or services we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods and/or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know when you submit the relevant data (which could be on our online booking form, comment/query form or any other form on which you submit information to us on the Site);
• to ensure that content from our Site is presented in the most effective manner for you and for your device;

• to provide relevant marketing communications to you via email, text, post, online or telephone;

• to make suggestions and recommendations to you about goods and/or services that may interest you;

• to communicate with you on third party social media platforms;

• to monitor the effectiveness of our marketing communications and your responses to it/them;

• if you contact us via a phone number listed on our Site, to record these for training and monitoring purposes and to identify the digital source for attribution and improvements in our digital marketing delivery; and
• for all other purposes consistent with the proper performance of our operations and business.

Information we collect about you. We will use this information:

• to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our service (when these are available from time to time), when you choose to do so;
• as part of our efforts to keep our Site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.

Information we receive from other sources

• We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Communication & marketing

If you are an existing customer, you have joined our mailing list or submitted an enquiry to us, you may occasionally receive our marketing communications where you have not opted out of receiving that marketing as we like to keep you updated you on our latest services, news and special offers via e-mail and telephone. You have the right to withdraw this consent or amend your marketing preferences at any time by contacting [email protected].

Disclosure of your personal information

You agree that we have the right to share your personal information with:

• Any member of the Beech Holdings Group, including any subsidiary of any company within the Beech Holdings Group, it’s ultimate holding company and/or any company associated or otherwise connected to the Beech Holdings Group.
• Selected third parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with you; analytics and search engine providers that assist us in the improvement and optimisation of our Site; credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you (which may be as part of a tenancy application).

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If the Beech Holdings Group or any of its associated companies, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our online booking terms and other agreements; or to protect the rights, property, or safety of the Beech Holdings Group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

All third parties are required to take appropriate security measures to protect your personal information in accordance with the law.

For tenancy, leaseholder, purchaser and seller applications and/or agreements:

• To carry out due diligence on you as a prospective tenant, leaseholder, purchaser or seller and any guarantor of theirs, including but not limited to the carrying out of affordability checks, due diligence checks and the obtaining of references from relevant third parties, whose data you have provided.
• To determine if there are any money judgements against you, as the prospective tenant, purchaser and/or guarantor, or to determine if you or they have a history of bankruptcy or insolvency.
• If you are unable to make payments under your tenancy, your information may be disclosed to any relevant party assisting in the recovery of this debt or the tracing of you as a tenant/guarantor; and
• In the creation, renewal or termination of the tenancy or ownership of a Beech Holdings Group property, your information may be disclosed to any relevant local authority, tenancy deposit scheme administrator, service/utility provider, factor, facilities manager or any other relevant person or organisation in connection with this.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to me/us without your consent

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the UK and European Economic Area ("EEA"). Where information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this policy.

For personal information processed through any of our Sites (include online bookings), this may be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of any of our services online booking, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will ensure a similar degree of protection is afforded to your personal data 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; or

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not 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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How we keep your data secure

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those people who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

How long we will keep your information

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information) or as set out in any relevant contract we have with you.

We will hold your data for up to 7 years after the expiry of the tenancy agreement, lease or, investment or completion of the purchase or sale.

For failed applications, we will hold your data for up to one year.

For enquiries, we will hold your data for up to two years from the date on which the enquiry is sent.

For CCTV images, we will hold recorded images for up to one month from the date of recording and downloaded images for up to two years from the date of download.

For call recordings, we will hold these for up to three months from the date of the recording.

Changes to your data

It is important that the personal information is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us. If your personal information changes, please let us know by emailing [email protected].

Your rights

You have the right at any time to:

Ask for a copy of the information about you held by us in our records

Require us to correct any inaccuracies in your information

Make a request to us to delete what personal data of yours we hold

Ask us not to process your personal data for marketing purposes.

We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].

If you wish to unsubscribe from any of our emails please let us know.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.

Access to information

The UK’s data protection laws give you the right to access information held about you. Your right of access can be exercised in accordance with these laws.

Email disclaimer

Security warning
As email is not a 100% secure communications medium, we advise you understand and observe this lack of security when emailing us.

Confidential and Privilege
This email and any attachments may be confidential and legally privileged and are sent solely for the attention of the addressee(s).

If you have received this email in error, please delete it from your system: its use, disclosure or copying is unauthorised. Statements and opinions expressed in this email may not represent those of Beech Holdings Investments Limited and our affiliated companies, trading entities and subsidiaries.

Viruses
Although we have taken measures to ensure this website and any links contained within it are virus free, we advise you to take your own steps where necessary to ensure that they are actually virus free.

Part B – Cookies Policy

What are cookies and what do they do?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or other device if you agree. Cookies contain information that is transferred to your device's hard drive when you visit our Site.

Cookies are used to:

help us provide you with a good experience when you use our Site by enabling you to navigate around our Site easily and effectively;

perform certain functions within our Site, such as displaying certain content to you and allowing you to move through the various pages of our Site as intended;

enable us to improve our Site;

provide information to us to analyse the behaviour patterns of people who visit our Site, for example, how many visitors view a particular page; and

• deliver relevant advertisements to you (both on our Site and on third party sites), if you agree to these types of cookies.

Please note that the information set out in our cookies policy applies to our Site only and not other websites to which our Site links.

Our use of cookies

This policy sets out the type of cookies we may use, their purpose and how long these will remain on your device for.

There are various types of cookies, and each of these are used for different purposes as follows:

1. Strictly necessary cookies. These are required for the operation and function of our Site and include, for example, cookies that enable you to log into the secure areas of our Site.
2. Analytical/performance cookies. These allow us to recognise and count the number of users using our Site at any one time and to see how users move around our Site when using it. We use the information gathered from these cookies to help us improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
3. Functionality cookies. These allow us to recognise you when you return to our Site. This enables us to personalise our content for you and remember your preferences.

4. Targeting cookies. These record your visit to our Site, the pages you have visited on our Site and the links you have followed. We may use this information to make our Site and the advertising displayed on it more relevant to your interests, for example, by tailoring specific advertisements to you on third party websites after you leave our Site.

Cookies are either first party or third party. First party cookies are set by us and third party cookies are set by a third party. Third party cookies are generally used to enable third parties to present content to you on our Site, for you to share content via a third party website (such as Facebook) or to assist third parties in understanding your browsing behaviour.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that there may also be other third party cookies which are stored on your device when you visit our Site over which we have no control. To check which cookies are stored on your device, we recommend using your browser settings (please see the links below for further information in respect of this).

How to manage cookies

Option 1: Managing cookies using your browser

You can manage which cookies you choose to accept and reject by adjusting your browsing settings. You will be able to remove and disable any cookies at any time through the settings in your internet browser but please note that you will need to do this on each browser you use. The method of doing this is different for each browser. For more information, please refer to the relevant support information using the links provided below:

• Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
• Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/
• General Information: http://www.aboutcookies.org.uk/managing-cookies

You can also remove existing cookies stored on your browser/device by using the same method.

Please note that disabling any necessary cookies and certain functional cookies may mean you are unable to access or use our Site properly.

Option 2: Managing cookies via our management tool

We will only collect and store cookies, other than necessary cookies, on your device with your consent. When you first navigate to our Site, you will be presented with a notification on our homepage which notifies you that our Site uses cookies and enables you to manage your cookie preferences. You can also change your preferences at any time by selecting the link to our cookie management tool, which is available as a link on our Site at all times.

Changes to our privacy and cookies policies

We may update our privacy policy and/or cookies policy to reflect changes to way we do things. Any changes we make to our privacy and/or cookies policies in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy and/or cookies policies.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Email: [email protected].

If you have any concerns about the use of your information, we would ask that you contact us to resolve the matter in the first instance using the email address set out above.

If you think your data rights have been breach, you also have the right to complain to the Information Commissioner’s Office (ICO). You can contact the ICO at:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

If you are unsure you can speak to one of our expert property consultants and they can refer you to a recommended mortgage broker who can provide the best option for you based on your budget and circumstances.

Here at Beech Holdings, we pride ourselves on the strong yield that our property investments offer investors, with the average investment offering 7% yields.