Privacy Policy & Notice

We are David Conway & Co. Ltd with registered number 5444145 and address 269 Northolt Road South Harrow Middlesex HA2 8HS. Our Data Protection Lead can be contacted at info@davidconway.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.

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 info@davidconway.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cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;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 info@davidconway.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 info@davidconway.co.uk.

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, David Conway & Co. Ltd, 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.

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 another’s vital interests';
e) 'public interest/official authority'; and
f) '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.

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).
Online Payment Processing	Identity Data Contact Data Transaction Data	We require certain information about you in order to instruct our payments processor to take payment from you and transfer it to us. To ensure security, we do not ever process your payment information and will transfer you to the payment processors website at the time of payment. None of our staff or contractors ever have access to this information. This processing is conducted lawfully on the basis of 'performance of a contract'.	Directly obtained.
Direct Debits	Identity Data Contact Data Financial Data Transaction Data	To setup a direct debit between your bank and ours, we pass your details to our bank and keep a copy for our records. This activity is conducted under the Direct Debit Guarantee Scheme. This processing is conducted lawfully on the basis of 'performance of a contract'.	Directly obtained.
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.

Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we may use cookies:

to record whether you have accepted the use of cookies on our web site. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you.
to allow essential parts of our web site to operate for you.
to operate our content management system.
to operate the online notification form - the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.
to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.
to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.
to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.
to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube's privacy-enhanced mode.

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.

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 info@davidconway.co.uk.

David Conway & Co. Ltd does not perform any profiling or automated decision making based on your personal data.

David Conway & Co. Ltd 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 individual’s having left our client’s 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.

David Conway & Co. Ltd 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.

David Conway & Co. Ltd 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.

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
Payment Processors	We are joint Controller with these service providers who simply pass payments you make through their services directly to us based on a transaction. These transactions are subject to the provider’s privacy notices/policies.	N/A for European based services – please contact info@davidconway.co.uk if you would like to find out about a specific representative.
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
Google Analytics	Website Hosts and analytics platform providers including but limited to:
BriefYourMarket	Website Hosts and analytics platform providers including but limited to:
Iam-Sold	Software and System Providers including but not limited to:
Xero	Software and System Providers including but not limited to:
Sage	Software and System Providers including but not limited to:
Reapit Software	Software and System Providers including but not limited to:
BriefYourMarket	Software and System Providers including but not limited to:
Elihan Group	Property Maintenance Contractors
4SiteElectrical	Electricians
Affinity Property Maintenance	Property Maintenance Firm
DAS	Rent Guarantee Insurer
HomeSearch	Property Portal
Scottish Power	Energy Supplier
Residential People	Property Portal
Top Maintenance	Handyman
Affinity Property Services	Handyman
Goodlord	Referencing Company and Insurer
HomeShift	Utility Update Provider
Boomin	Property Portal
Brightbee	Use of cookies and pixels in order to target potential clients with online marketing relevant to them
Agent Canvassing	Canvassing system
HM Land Registry	Land registry titles
Fredrick George	Property Management Company
Twitter	Customer review site
All Agents	Customer review site
Google+	Customer review site
Facebook	Customer review site
Trustis	Customer review site
Blinc	Tenant referencing and deposit replacement scheme
Department for Work and Pensions	Where Universal Credit is paid to the tenant
Local Authorities	Informing of new tenant/owner occupation
Home Office	Verifying Tenants Immigration Status
Copyman	Photocopy Servicing
ValPal	Online Valuation Tool
Yomdel	Website Live Chat
K&S Signs	Sign Erector
Keystar Locksmith	Locksmith
Countrywide	Surveyors
Bennett & Son	Roofing Company
Y & Y Management Ltd	Estate Management Company
Wenlock & Taylor	Fencing Company
Wenlock & Taylor	Estate Management Company
W E Black	Estate Management Company
Utility Warehouse Member Services	Utility Provider
Urban Construction	Gas Engineer
Trinity Estates	Estate Management Company
Tom Ford Ltd	Domestic Appliance Repair
Three Rivers Property Investments Ltd	Estate Management Company
Switch2 Energy Limited	Utility Provider
Woodwards	Surveyor Company
Spark Energy	Utility Provider
Southern Electric	Utility Provider
Scottish & Southern	Utility Provider
Scanda Windows	Window Supplier
SAV Systems	Heat Interface Unit Provider/Service
Sainsbury's Energy	Utility Provider
Robin Hood Energy	Utility Provider
Robert Wells Locksmith	Locksmiths
Red Rock Estate & Property Management	Estate Management Company
Ramki Heating	Gas Engineer
Pro-Maintain Ltd	Property Maintenance Company
Premier Waste	Waste Disposal
Ovo Energy	Utility Provider
Orbit Property Management Ltd	Estate Management Company
Mechanical Engineering Ltd	Gas engineer
MCM Property Management Ltd	Estate Management Company
Mayfords	Estate Management Company
AAM Maintenance	Property Maintenance Company
London Property Licensing	Property Licensing Company
Hillingdon Council	Local Council
Lets Match	Property Management Company
Leete Estate Management	Estate Management Company
Keystar Locksmiths	Locksmiths
K & T Services	Gas Engineer
Kenwoods	Timber and Damp Specialist
JB Ward & Son	Timber and Damp Specialist
Ian Gibbs Management	Estate Management Company
Relocation Agent Network	Relocation Company
Heronsgate Management Ltd	Estate Management Company
Heat Interface Team	Heat interface unit supplier and service company
FW Lettings	Property Management Company
Furniture4Lets	Furniture Supplier
First Utility Ltd	Utility Provider
ESS VENTILATION LLP	Ventilation System Provider and Service
EDF Energy	Utility Provider
Ebico Ltd	Utility Provider
E.Surv	Surveyors
Double Glazing Doctor	Double glazing specialist
DK Locksmith Services	Locksmiths
David Phillips Furniture	Furniture Provider
Dash Maintenance	Property maintenance company
Dan's Carpets & Flooring	Carpet Fitters
D & R Drain Services Ltd	Drain Specialists
CPH Plumbing Ltd	Gas engineers
Countrywide	Surveyors
Colleys	Surveyors
Clever Energy Ltd	Utility Provider
Clearview Homes Ltd	Property Developer
Catalyst Housing	Property Developer
Carpet Rite	Carpet Fitters
Carpet Link	Carpet Fitters
Capital Repairs Ltd	Appliance Repairs and Suppliers
Connells Asset Management	Asset Management Company
Barnes Brothers Fencing	Fencing Company
Various Estate Agents	Estate Agencies whom we may contact in connection to sales chains
Various Solicitors	Solicitors whom we may recommend and whom purchasers and vendors may be using for the sale/purchase of their property.
AVS Electrical Contractors	Electricians
Aprino Property Services	Cleaning Company
Aardvark Pest Control Services	Pest Control Company
Leasehold Property Management Ltd	Management Company
Monster Cleaning	Cleaning Company
Brent Council	Local Council
Hertsmere Council	Local Council
Ealing Council	Local Council
Harrow Council	Local Council
Scottish & Southern	Utility Provider
Affinity Water	Utility Provider
Scottish Power	Utility Provider
E.On	Utility Provider
British Gas	Utility Provider
Niche Design	EPC Assessor Professional Photography
Royal Institute of Chartered Surveyors (RICS)	Accreditation Body
The Property Ombudsman	Property Ombudsman
Tenancy Deposit Scheme (TDS)	Tenancy Deposit Scheme
Van Mildert	Referencing Company
Landlord's Lawyer	Landlord's Legal advisor
Chase Debt	Debt Collection Agency
Paypal	Payment Processor
Worldpay	Payment Processor
Practical Mortgage Solutions	Financial Advisors
Finance Planning	Financial Advisors
City & County Property Services Ltd	Maintenance Company
Top Boiler	Gas Engineers
Inventories 247	Inventory Company and EPC Assessor
Probitus Inventory Services	Inventory Company
The Property Collection	Marketing Company
Smart Search	Anti-Money Laundering System
Adobe Sign	Electronic Document Signatures
Brief Your Market	Marketing
MoveIt	Referral System
Banner Associates	Accountancy
My Communications	Telephone Systems
Namesco	Hosting
Justhost	Hosting
Gumtree	Property Portal
On The Market	Property Portal
Rightmove	Property Portal
Zoopla	Property Portal
Jupix	CRM System
The Property Jungle	Website Hosting

In addition to sending us your complaints directly to info@davidconway.co.uk, you can send complaints to our supervisory authority. As David Conway & Co. Ltd 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.

What are your rights?

Who is the Data Controller?

What are the lawful bases for processing personal data?

What are our 'legitimate interests'?

About our processing of your data

Our use of Cookies

What happens if I refuse to give David Conway & Co. Ltd my personal data?

What are David Conway & Co. Ltd's 'legitimate interests'?

What profiling or automated decision making do we perform?

How long will your personal data be kept?

Who else will receive your personal data?

Does your data leave the EU?

Third Party Interests

Who can you complain to?

Contact Us

Follow Us

Get an instant online valuation