In this Privacy Notice the terms, 'we', 'us' and 'our' are references to David Frost Estate Agents Limited (Frost’s), company number 02685937, having a registered address of 2nd Floor, Gateway 2, Holgate Park Drive, York, England, YO26 4GB. Frost’s is part of the LSL group of companies of which the ultimate parent company is LSL Property Services plc (LSL Group). Frost’s is also an Introducer Appointed Representative of PRIMIS Mortgage Network a trading name of First Complete Limited (Our Network).
This Privacy Notice sets out the basis on which any personal data we collect from you through our website (https://www.frosts.co.uk) (Our Site), or that you provide to us through Our Site or via other methods you may communicate with us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it, including:
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
By accessing, browsing or otherwise using Our Site you confirm that you have read and agree to this Privacy Notice. If you do not agree with any part of this Privacy Notice, you should not use Our Site or use our services.
We reserve the right to change the contents of Our Site, including this Privacy Notice at any time, by posting such changes on Our Site. It is your responsibility to familiarise yourself with the Privacy Notice regularly to ensure that you are aware of any changes. Your continued use of Our Site following the posting of any such changes will constitute your acceptance of the revised Privacy Notice.
This Privacy Notice was last updated on 3 December 2018. Please contact us using the details below should you require any clarification regarding how we may have processed your data prior to this date.
We may collect personal information from you in connection with your use of Our Site, including such personal information as:
We may also collect information from you in connection with a service or product provided to you by us, including personal information such as:
We may collect personal information from you which is of a sensitive nature when you voluntarily choose to provide such information to us. Where we do so we treat this information in accordance with the additional protection it is given under data protection laws.
Your information will be used by us in connection with the following purposes:
Providing You with Services:
Marketing of Our Services to You:
Responding to Your queries:
Improving Our Site:
Legal and Regulatory Obligations:
This section of the Privacy Notice is only relevant to the extent that we are providing you with mortgage, protection and/or insurance advice.
Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you in relation to your mortgage, protection and/or insurance products, where those products are regulated by the FCA. In the course of doing so, Our Network will process your information, including your Special Data and Criminal Disclosures.
In the course of handling your information and your Special Data/Criminal Disclosures, Our Network will:
Your information and your Special Data/Criminal Disclosures will be retained by Our Network either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable Our Network to fulfil its legal and regulatory obligations.
The majority of the personal information which we collect will have been voluntarily provided by you, however we may also obtain your personal data from other sources including:
The personal information that you provide will be retained by us in accordance with applicable laws and our internal Retention Policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our Retention Policy is available on request.
The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff or to any member of the LSL Group for the purposes set out in this Privacy Notice or for other purposes approved by you. We may also provide your personal information to other companies within the LSL Group for the purposes of administering our business or where services are provided by one LSL Group company to another pursuant to an intra-company services agreement.
We may also disclose your information to the third parties listed below for the following purposes:
These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.
We use the information you provide us with to keep you informed about products or services which we provide and which we believe you may be interested in. Where we conduct marketing we do so in accordance with applicable laws.
Where you contact us through the 'contact' page of Our Site, or make an enquiry in branch or on the phone, we will use the details you have supplied to us to provide you with our general property marketing by email unless you choose to 'opt-out' of these communications. If you do 'opt-out' then we will not send you information relating to our general property marketing by email.
We may however contact you in future by phone where we reasonably believe (on the basis of services that we are providing to you) that there are additional, different services which you may be interested in. This may be, for example to offer you an introduction to mortgage and protection services when we are assisting you with your search for a property, or to introduce you to property insurance services at the point at which you have exchanged contracts for the purchase of a house or agreed a tenancy, or to offer you conveyancing services. We rely on legitimate interests as a lawful basis for processing your information to conduct this above marketing and we ensure you always have the right to opt-out of receiving marketing communications from us. If you wish to never receive any form of marketing communication from us you can let us know by contacting us (using the details provided below).
We do not pass on your information to other companies for their own marketing purposes without your express consent, but from time to time we may tell you about services offered by other entities within the LSL Group and ask whether you would like to be provided with marketing by these entities.
If, at any time, you prefer not to receive further communications from us (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every message that is sent to you by us or by contacting us.
Our Site may contain links to other websites. We accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by our Privacy Notice.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.
You can request copies of your personal information within our custody and control and details of how we use that information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You can request an electronic copy of your personal data be sent to you, or to another organisation should you wish. You also have a right to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', unless we have a legal justification for doing so. If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint.
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in the following limited circumstances:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
You can ask us to restrict the processing of your personal information, but only where:
We can continue to use your personal information following a request for restriction, where:
You can ask us to provide your personal information to you in a structured, commonly used, machine?readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the UK.
We may redact data transfer agreements to protect commercial terms.
You have a right to lodge a complaint with your local supervisory authority (the contact details for which are set out in the Complaints section of this Privacy Notice) if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned above, please contact our Data Protection Officer by:
Post: Data Protection Officer, Newcastle House, Albany Court, Newcastle Business Park, NE4 7YB; or
Telephone: 0191 233 4600.
If you have any concerns or complaints as to how we have handled your personal data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.