Privacy Policy - Sophie Hathaway

Sophie Hathaway Ltd is committed to protecting and respecting your privacy. This privacy policy explains how we collect, use, store, and share your personal data when you use our residential estate agency services, visit our website www.sophiehathawayltd.com, or interact with us.

We are registered as a data controller with the Information Commissioner’s Office (ICO) under registration number ZC141085.

1. Contact Details

If you have any questions about this privacy policy or our data protection practices, please contact us:

Full Name of Legal Entity: Sophie Hathaway Ltd
Email Address: sophie@sophiehathawayltd.com
Postal Address: Beechey House, 87 Church Street, Crowthorne, Berkshire, RG45 7AW

2. The Personal Data We Collect

We collect, use, store, and transfer different kinds of personal data about you, categorized as follows:

Identity Data: First name, maiden name, last name, username, marital status, title, date of birth, gender, and copies of your passport, driving licence, or other government-issued ID.
Contact Data: Billing address, residential address, email address, and telephone numbers.
Financial Data: Bank statements, proof of funds, mortgage agreements in principle, source of wealth details, and payment card details.
Transaction Data: Details about payments to and from you, and details of properties you have bought, sold, or viewed through us.
Property Data: Photos, floorplans, land registry documents, title deeds, and structural or maintenance records of your property.
Viewing Data: Logs of dates, times, and attendees of physical or virtual property viewings.

3. How We Use Your Personal Data and Our Legal Basis

We will only use your personal data when the law allows us to. Most commonly, we use your data under the following legal bases:

Performance of a Contract

To register you as a new client (buyer or seller).
To market your property and negotiate property sales.
To manage our relationship with you, including notifying you about changes to our terms or privacy policy.

Legal Obligation

To comply with Money Laundering Regulations, which require us to verify your identity and financial source of wealth before a transaction occurs.
To prevent and detect fraud or other criminal activities.

Legitimate Interests

To vet potential buyers and ensure they are financially qualified before passing offers to a seller.
To ensure safety and security by keeping a log of individuals attending physical property viewings.
To administer and protect our business and website (including troubleshooting, data analysis, and system testing).

4. Disclosures of Your Personal Data

To facilitate a residential property sale, we must share your data with specific third parties in the property chain:

The Counterparty to the Transaction: We share relevant buyer details with the seller, and vice versa, during offer negotiations and sales progression.
Legal Representatives: Solicitors, conveyancers, and licensed conveyancers acting for you, your buyer, or your seller.
Financial Professionals: Mortgage brokers, independent financial advisors, and lenders involved in securing property finance.
Property Professionals: Surveyors, Energy Performance Certificate (EPC) assessors, and professional photographers.
Anti-Money Laundering (AML) Providers: Electronic identity verification and credit reference agencies to perform mandatory background checks.
Regulators and Authorities: HM Revenue & Customs (HMRC), the National Crime Agency (NCA), the ICO, and law enforcement agencies if required by law.

5. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.

AML and ID Records: Legally, we must keep copies of your identity documents and financial checks for a minimum of 5 years from the date our business relationship ends.
Sales and Transaction Files: We retain property sales files, contract records, and correspondence for 6 years after completion to protect against potential breach of contract claims.

6. Your Legal Rights

Under data protection laws, you have rights in relation to your personal data, including the right to:

Request access to your personal data (a “data subject access request”).
Request correction of any incomplete or inaccurate data we hold about you.
Request erasure of your personal data (where we do not have a overriding legal obligation, like AML laws, to keep it).
Object to processing of your personal data where we are relying on a legitimate interest.
Request restriction of processing your personal data.
Withdraw consent at any time if we are relying on consent to process your data.

If you wish to exercise any of these rights, please contact us using the details provided in Section 1.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us first.