Privacy & Cookie Policy
Privacy & Cookie Policy
The Ned|Lon Ltd. is committed to ensuring that your personal data, information and privacy are protected and kept securely. Your privacy is important for us. Therefore, please be assured that we take all necessary measures to ensure the security and confidentiality of your privacy, personal data and information. The usage and processing of your personal data, information and cookies is governed and regulated by this Privacy & Cookie Policy (hereinafter the “Policy”).
On this site, “The Ned|Lon Ltd.”, “our” and “we” each individually and collectively refer to The Ned|Lon Ltd. and their respective business partners, service providers, and other 3rd persons that assist our clients with the requested service, which may from time to time collect and use your personal data and information in accordance with this Policy. In addition, “you” or “your” refers to any real person generally whose personal information we process.
It is essential that you carefully read this Policy, together with any other policies, notices or other forms of written documents that is provided to you during the collection or processing of your personal data. In this direction, please review this Policy and submit any questions regarding this Policy to the e-mail address thenedlon@gmail.com.
This Policy covers the application of personal data processing activities in relation to the individual persons who are external to The Ned|Lon Ltd. Please note that this Policy is not intended to form part of any contract and cannot be interpreted as to be a part of a contract. The Ned|Lon Ltd. reserves the right to unilaterally revise and update this Policy.
The Ned|Lon Ltd. is a limited company with the registered office at the address 151 West Green Road, London, England, N15 5EA established in the United Kingdom and in accordance with the laws of the United Kingdom.
Please be informed that The Ned|Lon Ltd. acts in full conformity with the Guide to the UK General Data Protection Regulation (hereinafter the “UK GDPR”) and the Data Protection Act 2018 (hereinafter the “DPA 2018”) which is an act regulated and entered into force within the UK Public General Acts. Feel free to submit your queries to the e-mail address thenedlon@gmail.com in relation to the actions we take in order to fully comply with the UK GDPR and DPA 2018 during the processing and usage of your personal data & information. UK GDPR and the DPA 2018 shall be collectively referred to as “Data Regulation” for the purposes of this Policy.
1. Overview
Our usage of your personal data & the principles of processing shall be governed by this Policy. According to the UK GDPR, controller is defined as “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.”
In this vein, within the Data Regulation, The Ned|Lon Ltd. is a controller of the personal data that it collects, uses and processes about & from you. We will treat and handle your personal data in confidentiality according to the Data Regulation and in accordance with the relevant applicable data protection legislation. Your personal data will only be shared with others in line with the principles and procedures set forth in this Policy.
This Privacy Notice explains the following for you to understand & be informed of the way your personal data is used & processed;
Definition of personal data,
Types of personal data collected,
Usage and processing of your personal data,
Principles for processing your personal data,
Duration of keeping (storing) your personal data,
Measures taken to ensure the security of your personal data,
Legal principles for overseas transfers of your personal data,
Your rights in relation to your personal data,
Procedures for submitting complaints and contacting us,
Usage of cookies.
We believe that it is of utmost importance for you to be fully informed and aware of the data protection principles followed by The Ned|Lon Ltd. Therefore, we would like to kindly state that this Policy will be updated in case if any change occurs regarding the usage & processing of your personal data.
2. Definition of Personal Data
Personal data is a legal term which is defined and regulated under the Data Regulation.
According to UK GDPR;
“‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
As indicated in the provision, the term “personal data” has a wide scope and covers any information about an “identified or identifiable natural person” or the “data subject.” In this context, only the information related to an identified or identifiable natural person falls within the scope of the term personal data and therefore enjoys the protection regulated under the Data Regulation. In other words, only the information related to an individual can be classified as personal data.
In line with the legal definitions provided under the Data Regulation, personal data refers to any information that tells us something about you and helps us identify you. Therefore, a fixed & limited list for personal data cannot technically be made. Please further note that you are deemed “data subject” under the Data Regulation and you have the authority to enjoy all the rights granted to you by law regarding your personal data.
If a particular information falls within the scope of the legal definitions provided under the Data Regulation, that information is deemed personal data. This could include information such as name, surname, contact details, date of birth, bank account details, social media accounts or any information about you which would allow identification.
In addition to the above explanations, it must be noted that various categories of personal data enjoy a higher level of protection since those categories are sensitive in nature and requires a stricter protection regime. Such categories of personal data are called “special categories of personal data.”
Special categories of personal data are;
race,
ethnic origin,
political opinions,
religious or philosophical beliefs,
trade union membership,
genetic data,
biometric data (for the purpose of uniquely identifying a natural person),
health data,
sex life,
sexual orientation.
In a nutshell, special categories of personal data are more sensitive and we need to have further justifications for processing this types of personal data.
Personal data in relation to criminal convictions & offences are not listed under the special categories of personal data, however, these information require a higher level of protection as well.
3. Types of Personal Data Collected
The Ned|Lon Ltd. collects and processes your personal data as per the conditions stipulated under the Data Legislation. As part of your right to be informed about your personal data, we would kindly like to indicate the types personal data collected by The Ned|Lon Ltd.
We will collect your full name and contact details (such as phone number, email address, postal address (if required) and relevant information necessary to meet your needs) from you whenever you engage with us via the forms in our website. These information are submitted by you as the data subject to The Ned|Lon Ltd. with your freewill. You are in no obligation to share these information with us and there is no prerequisite to do so to visit our website. Additionally, there are necessary indications below the aforementioned forms. In line with the Data Regulation, the personal data collected, processed and shared before entering into a contract (pre-contractual phase) and collected, processed and shared after entering into a contractual relationship to meet the obligations thereof (contractual phase) are both covered under the “contract” as the valid lawful basis.
In addition, if we are providing a service to you, or on your behalf as an intermediary, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill). In such a scenario, the valid lawful basis for the collection and processing of personal data will be “legal obligation” since in this case, we will collect, process and share your personal data for the fulfilment of our legal obligations arising from applicable legal regulations. Please note that The Ned|Lon Ltd. is exclusively an intermediary in relation to its services, including but not limited to renting & letting services. We take the necessary actions in order to find you the right contractors and make the necessary arrangements for the requested services solely as an intermediary. Therefore, The Ned|Lon Ltd. shall not be deemed as a real estate agent or any other agency entity that requires certification or license.
We will also confirm whether you have any relatives or close connections working with us so that we can consider potential conflict of interests and if identified how to manage these, in accordance with The Bribery Act 2010, as well as our statutory and regulatory obligations.
Each and every one of our services have different requirements and scopes, therefore, there are some differences between the collected personal data depending on the service provided. However, in any scenario, we are collecting the information limited to the extent that is “necessary” for providing you the requested service. Depending on the service that we provide to you (or on your behalf) we may also collect additional personal data as explained in detail below.
Renting & Letting
If you are engaging our services for the purposes of finding and securing a short-term rental or long term letting a property through us on your arrival, we will collect and process your personal data as stipulated below:
We will collect a contact telephone number to get in touch with you to organise viewings and update you on any offers received or rental applications for your property. Thus, by engaging in a business relationship with The Ned|Lon Ltd. for renting & letting services, you accept that the relevant services are engaged for the purposes of acting on your behalf to source, locate, find and/or liaise with relevant 3rd parties to assist you in securing a rental/letting property. We will further collect your bank account details to arrange onward payment of rent or rent deposits if required as part of the terms of engagement, hence the contractual relationship. Once again please note that The Ned|Lon Ltd. is not a real estate agent. The Ned|Lon Ltd. is solely an intermediary for finding you the right contractors within your needs. Thus, the The Ned|Lon Ltd. shall not collect rent and rental deposits for itself and the aforementioned payments shall be finally made to the estate owners. This payment can be made directly to the estate owner or through The Ned|Lon Ltd. However, please note that The Ned|Lon Ltd. shall not be entitled to payments other than intermediary fees and expenses, since it is not a real estate agent.
You further accept that The Ned|Lon Ltd. may be required to share information for the intended purpose & for providing you the agreed services as part of the contractual relationship entered into. Therefore, the aforementioned personal data will be collected, processed and shared on the basis of “contract” as the valid lawful basis in accordance with the Data Regulation.
Please further note that when you engage with The Ned|Lon Ltd., we may collect information required to identify you and any additional documentation required which will be passed onto the relevant 3rd party in order to meet anti-money laundering and counter terrorist financing requirements as required by the Financial Action Task Force Recommendations (“FATF Recommendations”), United Kingdom’s anti-money laundering and counter terrorist financing legislation and relevant regulations (collectively the “AML Regulations”). Please be assured that these additional documents will only be collected for legal requirements and will be limited to fulfilling these requirements. In this sense, please note that the United Kingdom is a member-state of the Financial Action Task Force. FATF Recommendations provide a wide scope for the procedures and principles to ensure the prevention of money laundering & terrorist financing activities. These procedures & principles most of the times require the identification of an entity and the natural persons who are in charge. Furthermore, identification of natural persons associated with an entity may be legally required by AML Regulations. Therefore, if the counter-party is an entity (such as a company, trust, charity, foundation etc.), we may need to obtain personal information of the beneficiaries of the entity and those in a position of control and the ultimate beneficial owner. This will include, but is not limited to, identity and address documents. We may also need to collect information of other individuals who have an interest in the property who are not considered to be our customers. In such a scenario, the valid lawful basis for the collection and processing of personal data will be “legal obligation” since in this case, we will collect, process and share your personal data for the fulfilment of our legal obligations.
Moreover, please note that where we are working alongside third parties such as lettings agents or landlords. We may need to share these documents on the basis of contractual relationship to perform the contract as agreed upon.
In addition to the above-mentioned criteria, if you wish to engage our services or enquire with us or sign up for our monthly newsletter and/or provide us with information regarding your criteria to assist us in reaching to suitable 3rd parties to locate a rental/letting property for you, we will collect personal data relating to any specific access requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property and/or the rental on your behalf.
Information we may need to collect shall include but will not be limited to:
Specific access requirements so that we can find a property that is suitable for your needs (basis of “contract”),
Your bank / building / similar account details if this is necessary (basis of “contract”),
If you are an overseas person who is not a British Born National, we may need to collect details of your biometric residence card, your immigration status document and/or your birth certificate to carry out our required checks, if required (basis of “contract” and/or “legal obligation”),
We may also need to collect specific identity documents from you for the purpose of preventing and detecting crime, fraud, terrorist financing or money laundering activities as per AML Regulations and secondary legislation (basis of “legal obligation”).
Other
If you subscribe to receive news or other market or relevant updates from us, then in addition to the above-mentioned, we may collect details about the type of content that you would like to receive.
4. Usage and Processing of your Personal Data
Under the Data Regulation, your personal data can only be processed if there is a legal basis (“valid lawful basis”) for doing so. In the same direction, at least one valid lawful basis must be found in order to share personal data. We rely on the following legal bases to process and share your personal data;
To carry out the activities before entering into a contract with you (pre-contractual phase),
To perform any contract we have entered into with you (contractual phase),
To comply with a legal obligation,
To carry out activities for which it is in The Ned|Lon Ltd.’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing that is necessary to improve our know-how regarding the real estate sector. This will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for you and our customers in the future.
- Processing that is necessary for us to operate the administrative and technical aspects of our business efficiently and effectively. This will include verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes (i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below).
In more limited circumstances we may process & share your personal data to perform a specific task in the public interest that is set out in law.
Other uses of your personal information
If we sell any part of our business and/or integrate it with another organisation (including but not limited to mergers, acquisitions, partnerships, joint ventures), your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this Policy. Please note that The Ned|Lon Ltd. will act in full conformity with its post-closing liabilities regarding your personal data.
We will share personal information with our regulators, auditors, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our legal obligations where required.
We will also share your personal information with third party service providers where we use third party service providers who process personal information on our behalf in order to provide services. This may include IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
We may share your personal information with any person working within or with The Ned|Lon Ltd. on a “need-to-know basis” to ensure we are able to perform our legal and contractual obligations towards you.
We will keep your personal information on our client management systems and use this to provide you with marketing information about similar services offered by The Ned|Lon Ltd. from time to time. You have the opportunity to opt out of receiving this information at any time.
What happens if you do not provide the information requested?
As stipulated in this Policy, we need some of your personal data within the legal bases indicated above mainly to perform our obligations within the services you have requested from us.
If you do not provide the information required, we will not be able to enter into contract or perform our contract with you and may not be able to wholly or partially provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
5. Principles for Processing Your Personal Data
The Ned|Lon Ltd. follows various principles while processing your personal data, namely;
Your personal data is processed lawfully, fairly and in a transparent manner (“lawfulness, fairness and transparency”).
Your personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“purpose limitation”).
Your personal data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”).
Your personal data is accurate and, where necessary, kept up to date. In this sense, every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”).
Your personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (“storage limitation”).
Your personal data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).
6. Duration of Keeping (Storing) Your Personal Data
The period for which we will keep your personal information will be dependent upon the type of service/s you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
7. Measures Taken to Ensure the Security of Your Personal Data
The security, privacy & confidentiality of your personal data & information is of utmost importance for us. In this vein, we take all necessary measures to prevent unauthorised access to your personal data, including but not limited to:
Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes and to fulfil the obligations as part of the contractual relationship.
Hard copy documentation is stored in locked cabinets with restricted access only to persons who are required to have access to your information for legitimate business purposes and to fulfil the obligations as part of the contractual relationship.
All data is hosted in data centres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
Access to personal information is restricted to The Ned|Lon Ltd. employees and workers or other persons working within or with the The Ned|Lon Ltd. on and limited to a “need-to-know basis.”
Training is provided to The Ned|Lon Ltd. employees and workers who need access to personal data.
The personal data collected is not shared by The Ned|Lon Ltd. with any 3rd parties other than those who we work with to perform our obligations and deliver the requested services; any request from irrelevant parties is rejected.
8. Legal Principles for Overseas Transfers of Your Personal Data
The Ned|Lon Ltd. operates in various countries, namely UK, Netherlands, Germany, Italy and Canada. We may transfer, store, or process your personal information in locations outside the UK and the European Economic Area (hereinafter the “EEA”). The UK has “adequacy regulations” regarding EEA countries. Simply, those countries are deemed to have sufficient level of protection for an individual’s rights and freedoms in relation to his/her personal data. Netherlands, Germany and Italy are involved in the EEA. Therefore, overseas transfers to these countries in which we operate and other countries, territories and international organisations covered by UK “adequacy regulations” are conducted on the basis of “adequacy regulations.” Please further note that we also operate in Canada. In line with UK adequacy regulations, there is a partial finding of adequacy and the personal data that is subject to Canada's Personal Information Protection and Electronic Documents Act (hereinafter the “PIPEDA”) is entitled for overseas transfers.
On the other hand, please note that where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information within the adequacy regulations and laws of the UK, we will ensure that appropriate safeguards are put in place and undertake necessary risk assessments.
Namely, we’ll use one of these safeguards:
Transfer the personal data to a country which is not covered by UK adequacy regulations with privacy laws that grant the same level of protection as the UK and/or EEA.
Put in place a contract incorporating standard contractual clauses (hereinafter the “SCCs”)with the recipient that means they must protect it to the same level and standards as the UK and EEA.
Transfer the personal data to a receiver overseas who has signed up to a code of conduct, approved by the Information Commissioner’s Office (hereinafter the “ICO”), an independent authority within the UK vested with the authority to uphold information rights in the public interest and to promote openness by public bodies and data privacy for individuals.
Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the UK and EEA.
9. Your Rights in relation to Your Personal Data
In accordance with the Data Regulation, data subjects have various rights regarding their personal data (referred to as “individual rights”). We would like to kindly inform you regarding your legal rights. You have a number of rights in relation to your personal data as follows. You have the rights to:
Be informed about the usage, collection and processing of your personal data (“right to be informed”),
Obtain access to your personal information that we hold and receive a copy, along with supplementary information via subject access requests (“right of access”),
Request that your personal information is rectified or completed if you believe it is incorrect, incomplete or inaccurate (“right to rectification”),
Request that we erase your personal information in the following circumstances (“right to erasure” or “right to be forgotten”):
- If The Ned|Lon Ltd. is continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected,
- If The Ned|Lon Ltd. is relying on consent as the legal basis for processing and you withdraw consent,
- If The Ned|Lon Ltd. is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing,
- If the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation),
- If it is necessary to delete the personal data to comply with a legal obligation.
Request us to restrict or suppress our data processing activities where you consider that (“right to restrict processing”):
- Personal data is inaccurate,
- Our processing of your personal data is unlawful,
- Where we no longer need the personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim (in such a scenario, you must submit necessary documents to us illustrating that there is indeed a current legal claim),
- Where you have raised a rightful objection to our use of your personal data.
Request a copy of certain personal data that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us which we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data (“right to data portability”)
Object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data (“right to object”), and
Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you (“rights related to automated decision making including profiling”).
If you would like to exercise any of your rights, please do not hesitate to contact us via the e-mail address thenedlon@gmail.com so that we can review your request take the necessary actions (if any) thereof.
Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies as set forth above.
10. Procedures for Submitting Complaints and Contacting Us
If you have any queries or complaints about the way we use your personal data, please contact us via the e-mail address thenedlon@gmail.com and we will try to resolve the issue. If we cannot settle the issue, you have the right to submit a complaint to the data protection authority in your country (the ICO in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting thenedlon@gmail.com.
If you have any questions, comments or requests regarding any aspect of this Policy, please do not hesitate to contact us by sending an email to thenedlon@gmail.com.
11. Usage of Cookies
In order to provide a better service to its visitors, most sites use cookies which are basically practical technologies that makes websites easier to use and to offer a pleasurable experience. Thus, cookies are essential in enhancing your online experience. A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the controllers of the website.
When visiting our website, a window pops-up on the screen which leads you to this Policy.
Please further note that you can always change your cookie preferences in your browser to block/disable cookies. Therefore, you are under no obligation to use cookies, however, please be informed that this may potentially impact your user experience negatively.
Our website uses functional and analytical cookies for the website to function smoothly & properly and to distinguish you from other users of our website. This helps us to provide you with a pleasurable experience when you browse our website and also allows us to improve our site.
We look forward to meet & work with you and hope that you’ll choose The Ned | Lon Ltd. to be with you throughout your journey!
Please do not hesitate to contact us if you have any questions!
As we always say, “Think less, stress less!”
Disclaimer
The information provided in this website is exclusively for general introductory information and publicity purposes. The Ned|Lon Ltd. makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, services, data, related images or related graphics contained herein. Therefore, any reliance you place on such information is strictly at your own discretion and The Ned|Lon Ltd. shall not be liable for such reliance and possible consequences. The Ned|Lon Ltd. accepts no liability regarding the usage of the website or the information, services, data, related images or related graphics contained herein.
The Ned|Lon Ltd. shall not be liable for any loss or damage including but not limited to, direct, indirect or consequential loss or damage, or any loss or damage whatsoever arising out of, or in connection with, the use of this website and the information, services, data, related images or related graphics contained herein.
Through this website, you are able to link and have access to other websites and/or databases which are not under the control of The Ned|Lon Ltd. We have no control over the nature, content, safety, security and availability of those sites. Therefore, The Ned|Lon Ltd. shall not be liable for any loss or damage including but not limited to, direct, indirect or consequential loss or damage, or any loss or damage whatsoever arising out of, or in connection with, the use of the aforementioned websites and/or databases. The usage of these websites and/or databases are strictly at your own discretion. The inclusion of any links does not imply a recommendation or endorse the information, services, data, related images or related graphics contained within them.
The Ned|Lon Ltd. makes the best effort to keep this website running smoothly and operating precisely. However, The Ned|Lon Ltd. takes no responsibility for, and shall not be liable for, this website being temporarily or permanently unavailable. Furthermore, The Ned|Lon Ltd. reserves the right to temporarily or permanently close the website to public access or delete the website. In this sense, The Ned|Lon Ltd. further reserves its rights to reuse, reproduce or remove the material & content included in this website.
All content in this website belongs to The NedLon Ltd. Copying, reproducing, printing or using the content without the prior written consent of The NedLon Ltd. is strictly forbidden. Moreover, any content submitted to or from this website becomes the property of The NedLon Ltd.
This website operates under the laws of England and Wales. Any dispute concerning or arising from this disclaimer shall be exclusively and definitively resolved by the courts of England and Wales.
By using this website, you agree to the above-mentioned disclaimer.