Privacy Policy & Notice – Hovepark Lettings

We are Hovepark Lettings with registered number 5847875 and address 56 Hamilton Street, Saltcoats KA21 5DS. Our Data Protection Lead can be contacted at enquiries@hovepark.com. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). The terms "Personal Data", "Special Categories of Personal Data", "Personal Data Breach", "Data Protection Officer", "Data Controller", "Data Processor", "Data Subject" and "process" (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. "Data Protection Lead" is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to withdraw consent at any time, by emailing enquiries@hovepark.com;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by contacting enquiries@hovepark.com with the subject line: "Subject Access Request". When you submit a 'subject access request', you will need to provide confirmation of your identity by including a photocopy of your driver's license or passport. This service is provided free of charge and our response will be made within thirty (30) days, unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section 'Who can you complain to?'.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at enquiries@hovepark.com.

Who is the Data Controller?

• If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
• If we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
• • If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, Hovepark Lettings, at the time they collected your data and within their own privacy notices/standards.

Lawful Bases for Processing

Under Data Protection Legislation, there must be a 'lawful basis' for the use of personal data. The lawful bases are:

• a) Consent;
• b) Performance of a contract;
• c) Compliance with a legal obligation;
• d) Protection of vital interests;
• e) Public interest/official authority; and
• f) Legitimate interests.

Legitimate Interests

Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.

About our processing of your data

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data (first name, last name, title, date of birth, etc.);
• Contact Data (address, email, phone);
• Financial Data (bank account, payment details);
• Transaction Data (payments to and from you, tenancy records);
• Technical Data (IP address, login data, browser type/version);
• Profile Data (preferences, feedback);
• Usage Data (how you use our services); and
• Marketing and Communications Data (preferences, consents).

We do not collect any Special Categories of Personal Data about you.

Typical Processing Purposes

• B2B marketing (Identity, Contact);
• Analytics (Technical, Usage);
• Fraud prevention (Identity, Transaction);
• Customer communications (Identity, Contact); and
• Contract and tenancy management (Identity, Contact, Financial, Transaction).

Data Sharing within Group Companies

Hovepark Lettings may share data with Hooper Grey Ltd or other related companies under the same beneficial ownership only where necessary for the lawful performance of our services, for example where Hovepark sources tenants and Hooper Grey manages the property. Such sharing is conducted under strict controls, limited access, and always in compliance with UK GDPR.

Third Parties

We routinely use third-party contractors and service providers (e.g. plumbers, electricians, IT providers, accountants, regulators). These providers change over time, so rather than listing each one individually, we maintain records internally and ensure contracts or instructions include GDPR compliance requirements.

How long will your personal data be kept?

We hold personal data only for as long as is necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements. Generally:

• Contractual data is kept for 6 years under the Limitations Act 1980.;
• Marketing and consent-based data is reviewed every 12 months.; and
• Identity and contact data is held indefinitely unless you request deletion, in order to provide service to returning tenants and landlords.

Updates to this Privacy Policy

This policy is reviewed periodically to reflect changes in law and business practice.

Who can you complain to?

In addition to sending us your complaints directly to enquiries@hovepark.com, you can send complaints to our supervisory authority, the Information Commissioner's Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting ico.org.uk.