- Home
- Privacy policy and notice
We are ShineRocks Limited
with registered number 7093810 and address 4 Russell Parade, Russell Hill Road, Purley, Surrey, CR8 2LE.
Our Data Protection Lead can be contacted at paul@shinerocks.co.uk. 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 General Data Protection Regulation (EU) 2016/679 ("Data Protection
Legislation"). 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 paul@shinerocks.co.uk;
- 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outlined in this policy, or where you have withdrawn consent;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 paul@shinerocks.co.uk 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 paul@shinerocks.co.uk.
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,
ShineRocks Limited, at the time they collected your data and within their own
privacy
notices/standards. For a list of Data Controllers that we process personal data for, the
section below
'Third Party Interests'.
- If we have received your personal data as part of a business to business relationship,
the Data Controller
is your employer.
What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a 'lawful basis' for the use of personal
data. The lawful bases
are :
- a) 'your consent';
- b) 'performance of a contract';
- c) 'compliance with a legal obligation';
- d) 'protection of your, or anothers' vital interests';
- e) 'public interest/official authority'; and
- f) 'our legitimate interests'.
What are our '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
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).
We may collect, use, store and transfer different kinds of personal data about you which we
have grouped together
follows:
Identity Data includes first name, maiden name, last name, username or similar identifier,
marital status, title,
date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of
products and services you
have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and
version, time zone
setting and location, browser plug-in types and versions, operating system and platform and
other technology on
the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your
interests, preferences,
feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties
and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data
in law as this data
does not directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we treat the
combined data as
personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details
about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union
membership, information about your health and genetic and biometric data). Nor do we collect
any information
about criminal convictions and offences.
Reference |
What categories of information about you do we process? |
Why are we processing your data? |
Where did we get your personal data from? |
B2B Marketing |
- Identity Data
- Contact Data
|
Direct marketing to former, current and prospective clients. This processing
is conducted
lawfully on the basis of 'our legitimate interests'.
|
Directly obtained or by referral from existing clients/partners/suppliers.
|
Analytics |
- Technical Data
- Usage Data
|
To understand how you use our website, how you reached us and how long you
spend on our website,
in order to analyse our performance and improve our service. This processing
is conducted
lawfully on the basis of 'our legitimate interests'.
|
Directly obtained or indirectly obtained through a client's website (notice
given at the point
of collection).
|
Fraud Prevention |
- Identity Data
- Transaction Data
|
To combat fraud, we share information of clients who instruct the payment
issuer to cancel
payments to us without first informing us of why and/or allowing us the
opportunity to issue a
refund with credit reference agencies. This processing is conducted lawfully
on the basis of
'protection of your, or another's vital interests'.
|
Directly obtained or indirectly obtained through a client's website (notice
given at the point
of collection).
|
Contact Submission |
- Identity Data
- Contact Data
|
When you send us information about you by posting on a forum or blog, we
will store this
information in order to make it available for viewing on the website. You
consent is obtained at
the time of posting and via reference to this notice. This processing is
conducted lawfully on
the basis of 'your consent'.
|
Directly obtained or indirectly obtained through a client's website (notice
given at the point
of collection).
|
Phone Calls |
- Identity Data
- Contact Data
|
We might record calls for training and/or auditing purposes. We also collect
Calling Line
Identification information. This is used to help improve the efficiency and
accountability of
our customer services. This processing is conducted lawfully on the basis of
'our legitimate
interests'.
|
Directly obtained.
|
Email and Web Contact |
- Identity Data
- Contact Data
|
If you contact us through our website or by email, we will use the
information you send in order
to respond to your enquiry or complaint. This information will be kept in
order to improve our
service to you overall. This processing is conducted lawfully on the basis
of 'our legitimate
interests'.
|
Directly obtained or indirectly obtained through our website (notice given
at the point of
collection).
|
Consumer Marketing |
- Identity Data
- Contact Data
- Transaction Data
- Marketing and Communications Data
|
If you make a purchase with us, we will add your contact information to our
marketing list and
send you information we think you might be interested in. This processing is
conducted lawfully
on the basis of 'our legitimate interests'.
|
Directly obtained.
|
What happens if I refuse to give ShineRocks Limited my personal data?
The information about you that we have collected for the performance of our contracts is
required in order for us
to successfully fulfil our obligations to you. If you choose not to provide the personal
data requested, we will
not be able to enter into a contract with you to provide the benefits we offer. If we are
already processing
your personal information under a contract, you must end our contractual relationship
(as/where permitted) in
order to exercise some of your rights.
We process some personal information as part of a contractual relationship with a Data
Controller. Any requests
to restrict this type of processing should be forwarded to the Data Controller; they will be
responsible for
discussing your concerns and making any decisions.
What are ShineRocks Limited's '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. If you
would like to find out
more about our legitimate interests, please contact paul@shinerocks.co.uk.
What profiling or automated decision making do we perform?
ShineRocks Limited does not
perform any profiling or automated decision making based on your personal data.
How long will your personal data be kept?
ShineRocks Limited holds
different categories of personal data for different periods of time. Wherever possible, we
will endeavour to
minimise the amount of personal data that we hold and the length of time for which it is
held.
- If 'consent' is the basis for our lawful processing of your data, we will retain your
data so long as both
the purpose for which it was collected, and your consent, are still valid. We review the
status of your
consent every twelve (12) months and treat non-response to our requests for renewal of
consent as if they
were your request to withdraw consent. Occasionally, we might identify a legitimate
interest in retaining
some of your personal data that has been obtained by consent. If we do, we will inform
you that we intend to
retain it under these conditions and identify the interest specifically.
- Identity, Contact and Transaction Data are held indefinitely (subject to object by the
individual, or
individuals having left our clients' business) in order to provide a superior service to
returning
customers.
- If we process your data on the basis of 'legitimate interests', we will retain your data
for so long as
the purpose for which it is processed remains active. We review the status of our
legitimate interests every
twelve (12) months and will update this notice whenever we determine that either a
legitimate interest no
longer exists or that a new one has been found.
- All categories of personal data that are held by us because they are essential for the
performance of a
contract, will be held for a period of six years, as determined by reference to the
Limitations Act 1980,
for the purposes of exercising or defending legal claims.
Who else will receive your personal data?
ShineRocks Limited passes
your data to the third parties listed in the section 'Third Party Interests' below, for the
purposes of
providing our services to you, and for no other purpose.
Does your data leave the EU?
ShineRocks Limited uses
overseas web and IT providers. Details of what data is sent where, and the safeguards in
place, are included in
the section 'Third Party Processors' below.
Third Party Interests
Data Controllers
Name of Third Party Controller |
What processing are we performing for them? |
If applicable - who is their representative within the EU?
|
HMRC, regulatory authorities or other authorities |
We are joint Controller with these authorities who require reporting of
processing in some
situations |
N/A |
Postal/Courier Providers |
Where these providers act as Data Controller, we are joint Controller with
them for the purposes
of sending you physical documents. |
N/A |
Our Data Processors
Name of Third Party Processor |
Purposes for Carrying out Processing |
Greenwood Property Solutions |
EPC provider |
Nicky Burrows |
Interior design |
A A R Developments Ltd |
General builder |
Metropix |
Floor Plans |
Acuity Professional |
Accountants |
Property Jungle |
Website provider |
London & Country |
Mortgages & Insurances |
Vertical Leap |
SEO |
Digital Munkey |
Digital Marketing |
The Guild of Property Professionals |
Business to business organisation |
Vebra |
Software |
Who can you complain to?
In addition to sending us your complaints directly to paul@shinerocks.co.uk, you can send complaints to our supervisory authority. As ShineRocks Limited
predominantly handles the personal data of UK nationals, our supervisory authority is 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.