Privacy Policy | Dion Homes

Dion Homes privacy policy

This Privacy Policy is for Dion Homes, part of DION DEVELOPMENTS LTD. We take our legal responsibilities for your data very seriously.

Your personal data will not be supplied to third parties outside the Dion Homes for the purpose of marketing and sales without your consent. You can also object to further direct marketing from us at any time.

This is the privacy policy for Dion Homes prospective customers expressing an interest in our products or services and/or who are on our marketing database but are not existing customers (who we call “prospects”). It sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us when you are a prospect. It is important that you read this policy in full to understand what information we hold about you, how we may use it and what rights you have in relation to your data.

We may need to update this policy to reflect any changes to the law, our business or data processing practices from time to time. Please check this policy regularly to ensure you are familiar with its terms.

This privacy notice does not cover data collected where you follow links to other websites. We encourage you to read the privacy statements on the other websites that you visit, when you follow these links.

Who are we

We are DION DEVELOPMENTS LTD a private limited company incorporated in England and Wales with company number 11360038. Our registered address is 62 Roxborough Avenue, Isleworth, United Kingdom, TW7 5HJ.

In this policy we refer to ourselves as “we”, “us”, “our” and “Dion Homes”.

Dion Homes is a “data controller”. This means that we are responsible for deciding how we hold and use personal information we have collected from you.

If you have any questions, or want more details about how we use your personal information, you can contact our Data Protection Lead as follows:

The Data Protection lead

DION DEVELOPMENTS LTD
62 Roxborough Avenue,
Isleworth, United Kingdom,
TW7 5HJ

itops@dionhomes.co.uk

What personal information we may hold about you

We may collect the following personal information from you:

your name
your title
your address
your contact telephone number(s)
your contact email address(es)
any personal information that you disclose to us in letters, requests for information, emails and/or telephone conversations between us.
Profile and usage data: we gather this data from devices, such as computers and mobile phones that you use to connect to our website using cookies and other internet tracking software. Please see our cookie policy for more information about this.

As well as personal information (such as your name, address, telephone number) we may collect sensitive personal information (also known as special categories of data), about your health, such as any health conditions that mean you have specific accessibility requirements.

We use this data to ensure that our products and services are suitable for your needs and are delivered appropriately. We will apply additional security and confidentiality measures when processing your sensitive personal information.

We will ask for your specific informed consent at the time of collecting sensitive data for a particular purpose. Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.

We may collect information from you in the following ways:

Information provided by you

When you use our website to request brochures or for us to contact you by telephone, post and/or email about our products, developments and offers.
When you take part in our social media organic or paid campaigns.
When you talk to us on the phone or face to face when you visit one of our show homes and request brochures or for us to contact you by telephone, post and/or email about our products, developments and offers.
When you fill in one of our forms.
When you contact us by email or by letter.
If you take part in our competitions or promotions

Information we collect

From the following third parties that you have agreed to refer your personal information to us so that we can send you information about our products, developments and offers, or so that we can contact you by telephone, post and/or email about our products, developments and offers:
- “online property portals” such as Zoopla and Rightmove;
- Social media campaigns such as Facebook, Instagram, Linkedin, Twitter and Pinterest
- estate agents;
- mortgage brokers
- government purchase assistance scheme providers, such as Homes England
- other property companies including registered providers of social housing

If you choose not to give personal information

If you choose not to give us your personal information, it may mean that we cannot provide our products or services to you (or further information about them).

Unless we have your consent, we will only collect the personal information that we need to be able to provide a product or service to you. When we ask you for information, we will make it clear why we need it. Any data collection that is optional will be made clear at the point of collection.

If you provide any personal information relating to another person, normally a joint buyer or someone who is living with you, we assume that you do so with their full knowledge and consent.

Our purpose for collecting and processing your personal data

Data Protection law says that we can use your personal information only if we have a lawful basis for doing so. This means that we can only process your personal data if we have one (or more) of these reasons:

To fulfil a contract we have with you (or to take steps at your request prior to entering a contract)
To comply with a legal obligation
When it is in our legitimate interest
When you consent to it
To protect your vital interests e.g. in cases of life or death, or
When we are exercising a statutory function or official task in the public interest, although this will only apply in exceptional situations.

A legitimate interest is when we (or someone else) have a business or commercial reason to use your information. However, such use of your personal data must not have an unduly negative or unfair impact on your privacy or prejudice your rights and freedoms.

Here is a list of all the ways that we may use your personal information when you are a prospect, and which of the lawful reasons we rely on to do so.

Purpose	Lawful basis
To provide you with information about our products and services, including purchase assistance schemes:	Our legitimate interests to provide you with information about our products and services that we think you may want or need, or that may be of interest to you
To notify you about changes to our a products and services:	Our legitimate interests to develop and manage our brand, products and services and to continue to provide you with information that we think you may want or need, or that may be of interest to you.
To provide you with information about new developments and house types which may meet your needs:	Our legitimate interests to develop and manage our brand, products and services and to continue to provide you with information that we think you may want or need, or that may be of interest to you.
To provide you with information about government purchase assistance schemes, such as Help to Buy, and government policies that relate to home ownership:	Our legitimate interests to provide you with information about products and services that we think you may want or need, or that may be of interest to you. There may also be a legal obligation for us to process the information.
To carry out marketing analysis about our products and services and your marketing requirements:	Our legitimate interests to ensure we are sending you information we think you may want or need, or that may be of interest to you.
To inform you of competitions and promotions we are running about our products and services:	Our legitimate interests to provide you with information about products and services that we think you may want or need, or that may be of interest to you.
To carry out market research:	Our legitimate interests to understand how we are performing so we can meet our mission statement and objectives. There may also be a legal obligation for us to process the information or to demonstrate that we are fulfilling our obligations.
To monitor telephone calls between us for authentication, security, quality and training purposes.	Our legitimate interests to help us to monitor our performance and to improve our products and services
Capture CCTV footage for security, quality and training purposes.	Our legitimate interests around health and safety and crime prevention and detection.
To process a complaint received from you:	Our legitimate interests to manage our relationship with you. We may also need to fulfil our legal and contractual duties or fulfilling your requests prior to entering a contract.
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit:	Our legitimate interests in managing our business efficiently, complying with laws or regulations that apply to us. Fulfilling our contractual duties or fulfilling your requests prior to entering a contract.

Marketing

We will use your personal information to tell you about our products and services. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us and data we collect from third parties we work with (with your knowledge or reasonable awareness). We use this to identify and inform us of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’ (as described above).

We rely on our legitimate interests to send you postal marketing communications (from time to time). You can ask us to stop sending you marketing materials by contacting us at any time using the contact details above

Before sending electronic marketing communications, we will follow the law and guidance where this requires us to seek your consent. You can withdraw your consent to receive further electronic marketing at any time. Please just contact us using the contact details above, or follow the ‘unsubscribe’ instructions on our marketing communications.

We may ask you to confirm or update your choices from time to time and if there are changes in the law, regulation, or the structure of our business.

Dion Homes will never sell your personal data to third party organisations for marketing purposes.

Who we share your personal information with

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.

When sharing information we will comply with all aspects of data protection law.

When we need to share personal data with clients, contractors and third party suppliers, our relationships with them are governed by contracts which impose strict data sharing and confidentiality requirements.

Where sharing is in our legitimate business interests, we may share your information without seeking your consent first. This may be with:

Other organisations in the Dion Homes who are providing services to us or on our behalf.
Third parties providing services on our behalf. For example, the mailing company who distributes our marketing materials; or a research company carrying out a customer satisfaction survey on our behalf or property portals such as Zoopla.
We may also share information when required by law for example where ordered by the Court; where necessary in connection with us receiving professional advice; or to protect an individual’s vital interests.

We may also share your personal information if the structure of Dion Homes changes in the future. We may choose to sell, transfer, or merge parts of our company, or our assets; or we may seek to acquire other companies or merge with them. During any such restructuring of our company, we may share your information with other parties. We’ll only do this if those parties agree to keep your data safe and private.

Sending data outside of the UK or EEA

We will only send your data outside of the UK or European Economic Area (‘EEA’) to:

Follow your instructions,
Comply with a legal duty, or
If legally permitted to do so although if we do transfer information outside of the UK or EEA in these circumstances we will make sure that it is protected in the same way as if it was being used in the UK or EEA. If so, we’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient that means they must protect it to the same standards as in the EEA.

How long we keep your personal information

We will keep your personal information for as long as you remain an active prospect on our marketing database and/or we have products and services we believe are relevant or of interest to you.

We may keep your information for up to 15 months after the last time you contacted us or responded to contact from us for one of these reasons:

To respond to any questions or complaints or to resolve any follow up issues between us, or
To show that we treated you fairly and lawfully in compliance with data protection law.

We may keep your data for longer than 15 months if we cannot delete it for legal or regulatory reasons or need to do so to deal with future legal claims or we have a legitimate need to do so. If we do, we will make sure that your privacy is protected and only use it for those purposes.

We have a document retention schedule which sets out how long we keep different types of information for. This is based on legal requirements and good industry practice.

We will apply appropriate technical and organisational measures to ensure your personal information is secure.

To help us ensure the security and confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).

Your rights

Dion Homes is committed to upholding your data privacy rights.

The right to be informed

We will be open and transparent about how and why we use your personal information. This will be set out in our privacy notices.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your personal information. This is known as a ‘subject access request’ (SAR).

We will provide a copy of your information free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in providing your information.

Where your request is manifestly unfounded or excessive we can refuse to respond. If we refuse to respond to your request, we will let you know why.

We have one month to provide you with the information you’ve requested (although we will try to provide this to you as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your request, explaining why an extension is necessary.

We will provide you with a copy of the personal information that we hold about you. This will not generally include information about your property such as repair logs or details of contractor visits as this is unlikely to constitute your ‘personal information’.

Please be clear if you are seeking property or repairs related information, as a SAR is unlikely to fulfil your information requirements.

The right to rectification

You can ask us to rectify your personal data if it is inaccurate or incomplete by contacting us using the contact details above. If you do, we will take reasonable steps to check its accuracy and correct it.

We will comply with your request free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in complying with your request.

Where your request is manifestly unfounded or excessive we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

We have one month to comply with your request (although we will try to do this as promptly as possible). We may extend this period by a further two months if your request is complex or we have received a number of requests from you. If this is the case, we will inform you within one month of the receipt of your written request, explaining why an extension is necessary.

Where we have shared the personal data in question to others, we will contact each recipient and inform them of the rectification of your personal data, unless this proves impossible or involves disproportionate effort.

Please help us to keep our records accurate by keeping us informed of any changes in your personal information.

The right to erasure

The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing.

This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data, for example, to comply with a legal obligation. Our response will also be guided by the provisions of our retention schedule.

Where your request is manifestly unfounded or excessive we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

Where we have shared the personal data in question with others, we will contact each recipient and inform them of the erasure of your personal data, unless this proves impossible or involves disproportionate effort.

The right to restrict processing

In some circumstances you can ask us to restrict the use of your personal information. This is not an absolute right and only applies if:

You disagree with the accuracy of your personal information
It has been used unlawfully but you don’t want us to delete it
It’s not relevant any more, but you want us to keep it for use in legal claims
You have already asked us to stop using your data but you are waiting for us to tell you if we can keep on using it
If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
We will comply with your request free of charge. However, we can charge a ‘reasonable fee’ if your request is manifestly unfounded or excessive, particularly if it is repetitive. Our fee will be based on administrative costs incurred by us in complying with your request.

Where your request is manifestly unfounded or excessive we can refuse to comply with your request.

If we refuse to comply with your request, we will let you know why.

If we restrict the processing of your personal information, we are permitted to store the personal data but we won’t use it.

Where we have shared the personal data in question to others, we will contact each recipient and inform them of the restriction of the personal data, unless this proves impossible or involves disproportionate effort.

The right to data portability

Data portability allows you to obtain and reuse your personal data for your own purposes across different services. You can ask us to move, copy or transfer your personal data from one IT environment to another by contacting us on the contact details above.

The right to data portability is not an absolute right and only applies to personal information you have provided to us:

where our processing is based on your consent or for the performance of a contract; and
when our processing is carried out by automated means.

We will provide your information free of charge.

If you request it, we will transmit your data directly to another organisation, but only if this is technically feasible. We are not required to adopt or maintain processing systems that are technically compatible with other organisations.

The right to object

You can object to our processing of your personal data where that processing is based on legitimate interests and, in those cases, we will stop processing your personal data unless:

we can demonstrate a compelling legitimate grounds for continuing the processing, which override your interests, rights and freedoms; or
the processing is needed for the establishment, exercise or defence of legal claims.

If you object to our processing of your personal data for direct marketing purposes, we will immediately stop processing your personal data for that purpose although will keep your stop request on our records so as to respect your wishes.

Rights in relation to automated decision making and profiling

You can ask us to review any decisions that are determined by automated means (making a decision about you solely by automated means without any human involvement). You can also object to our use of your personal data for profiling (automated processing of personal data to evaluate certain things about you).

How to complain

If you are unhappy with why or how we have used your personal information or want to exercise your rights above, please contact our data protection lead using the contact details above.

If we cannot deal with your issue and you want to raise a complaint about our processing of your data, you can contact the Information Commissioner using the following contact details:

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

Tel: 0303 123 1113
www.ico.org.uk

Last updated 17.02.23