This Policy sets out who we are and how and why we collect, store, use and share your Personal Data which is data relating to an identified or identifiable individual. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint. Our use of your Personal Data is subject to your instructions, Data Protection Act 1998 (DPA) the EU General Data Protection Regulation (GDPR), other relevant UK and EU legislation and our professional duty of confidentiality.

Cheyne Aston Ltd (of which Luxury Lets is a subsidiary) is registered as a data controller with the Information Commissioner's office. We will always comply with the DPA and GDPR when dealing with your personal data. Further details on the DPA and GDPR can be found at the website for the Information Commissioner (o "http://www.ico.gov.uk").

This guidance covers Personal Data processed during the course of personal contact, visits to our website by Clients, contacts and other third parties but also during the course of a matter with a Client.

How and why we use your Personal Data

We have a legitimate interest in processing your data for certain reasons i.e.

1.     •Providing information about services

2.     •Providing and personalising our services

3.     •Dealing with your enquiries and requests

4.     •Following and progressing your instructions

5.     •Finalising your matters and retaining information for insurance cover

6.     •Keeping you informed of changes in the Law and government regulations which may be important to you

7.     •Requesting information in relation to any unpaid fees or disbursements

Personal Data processed in relation to our Clients

Personal Data we will or may collect in the course of advising and/or acting on your behalf and will depend on the nature of your contact and involvement with us, as some require interaction with external organisations such as:

1.     •Your name, address and telephone number Information to enable us to check and verify your identity, e.g. your date of birth or passport details Electronic contact details, e.g. your email address and mobile phone number.

2.     •Information relating to the matter in which you are seeking our advice.

3.     •Your financial details so far as relevant to your instructions, e.g. salary details in connection with

affordability checks for a lettings application; the source of your funds if you are instructing on a purchase transaction – this may include bank account details, transfer references, addresses, telephone numbers, email addresses etc.

4.     •If you make a payment through our online payment system, your name, address, email and telephone number will be retained. No personal financial information is retained on our website as this service is provided by a Third Party.

5.     •If you are an individual who has a business, information provided by you about your business and other individuals in connection with any services we may be called upon to provide to your business.

6.     •Your National Insurance and tax details including copy documents where necessary.

7.     •Your bank and/or building society details

8.     •Details of your professional online presence, e.g. LinkedIn profile, Facebook information, etc.

9.     •Details of your spouse/partner and dependants or other family members, e.g. if you instruct us to make

contact with a guarantor or your next of kin.

10.     •Your employment status and details including salary and benefits, e.g. if your reference checks require details of your contract of employment, employer contact details, or in which your employment status or income is relevant.

11.     •Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if your enquiry involves anything which requires disclosure of immigration details.

12.     •Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you are applying to book a room in a shared house where cultural clashes or differences may be relevant.

13.     •ID Verification: Personal identifying information, such as your hair or eye colour, vehicle registration details; a pre-agreed password or your parents' names, e.g. in order to accurately identify you with your Photo passport / Photo driving license, parking permit applications or at a meeting or viewing.

14.     •Medical records e.g. if any disability is relevant for access, special requirements, assistance or in connection with insurance purposes (which are usually handled via a Third Party representative).

This Personal Data is required from you to enable us to provide our service to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing services to you. In the event that you are not willing to supply requested information, we may be forced to terminate applications or instructions.

We collect most of this information from you. However, we may also collect information from publicly accessible sources, e.g. Companies House or HM Land Registry; directly from a third party, e.g. sanction screening providers from a third party with your consent, e.g.: bank or building society, another financial institution or advisor, past landlord/s, consultants and other professionals we may engage in relation to your matter or your employer and/or trade union, professional body or pension administrators; via our information technology systems, e.g. case management, document management and time recording systems; through our own website, relevant websites and applications;

Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV, communication systems and e-mail and through other processes we have in place e.g. telephone software reports, manual data entries such as guest books, application forms, maintenance reports, guest and reception logs.

How and why we may use your Personal Data

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.: to comply with our legal and regulatory obligations; for the performance of our contract with you or to take steps at your request before entering into a contract (ie in the case of a guarantor); for our legitimate interests or those of a third party; or you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your Personal Data for and our reasons for doing so:

What we use your Personal Data for:

   •     To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party:

1.     •To provide services to you for the performance of our contract with you or to take steps at your request before entering into a contract.

2.     •Conducting checks to identify our clients and verify their identity.

3.     •Screening for financial and other sanctions or embargoes.

4.     •Other processing necessary to comply with professional, legal and regulatory obligations that apply to

our business, e.g. under health and safety regulation or rules issued by our professional, local council

or other government regulator.

5.     •Making you aware of services that might be relevant and of interest to you.

6.     •Gathering and providing information required by or relating to audits, enquiries or investigations by

regulatory bodies. In particular, we are in some circumstances under a legal duty to disclose information to the National Crime Agency (NCA) or other enforcement agencies. If we make a disclosure we will usually not be able to tell you about it or the reasons for the disclosure.

7.     •Ensuring business policies are adhered to, e.g. policies covering security and internet use

8.     •Operational reasons, such as improving efficiency, training and quality control.

9.     •Ensuring the confidentiality of commercially sensitive information.

10.     •Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client

base, work type or other efficiency measures.

11.     •Preventing unauthorised access and modifications to systems.

12.     •To keep our central records up to date including updating and enhancing client records and manage

the firm's business.

13.     •External audits and quality checks, e.g. HMRC / SRA and the audit of our accounts.

14.     •For the performance of our contract with you or to take steps at your request before entering into a

contract .

15.     •Statutory returns and to deal with regulatory obligations.

16.

•Ensuring safe working practices, staff administration and assessments.

Marketing communications

We may use your Personal Data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services. We will seek consent from individuals.

Personal Data in relation to interaction with our website

We collect Personal Data offline from clients and online visitors to our website through the use of a contract form should you choose to complete it. This requests your name, telephone number and email address together with the nature of your enquiry; this is sent through to our company and no data is held other than with our company.

All Clients

We will always treat your Personal Data with the utmost respect and never sell or share it with other organisations for marketing purposes. You have the right to opt out of receiving marketing materials at any time by: contacting us by email to unsubscribe, or updating your marketing preferences to "team@cheyne-aston.com" with REMOVE in the subject box, or using the 'unsubscribe' link in emails. We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share Personal Data with:

1.     •professional advisers who we instruct on your behalf or refer you to, e.g. referencing agencies, solicitors, medical professionals, accountants, tax advisors,

2.     •other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House; our banks; credit reference agencies; our insurers and brokers; the Courts; external auditors; e.g. HMRC / SRA and the audit of our accounts.

3.     •external service providers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, document collation or analysis suppliers; We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers relating to ensure they can only use your Personal Data to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

4.     •We may also need to share some Personal Data with other parties such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see 'Who we share your Personal Data with'). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your Personal Data when this occurs, see below: 'Transferring your Personal Data out of the EEA'.

We will keep your Personal Data after we have finished advising or providing services to you. We will do so for one of these reasons: to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly; to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data and we will retain data in accordance with our Document Retention Policy, which may change from time to time. When it is no longer necessary to retain your Personal Data, we will delete or anonymise it.

Transferring your Personal Data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your Personal Data outside the European Economic Area (EEA), e.g.: if your and our service providers located outside the EEA; if you are based outside the EEA; where there is an international dimension to the service we are offering or the matter in which we are advising you. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all Personal Data will be secure.

You have the following rights, whether a client or a visitor to our website, which you can exercise free of charge:

1.     •The right to be provided with a copy of your Personal Data (the right of acces)

2.     •The right to require us to correct any mistakes in your Personal Data (as long as we are made aware of

any, in writing and on a signed and dated Declaration of Change by yoursef).

3.     •The right to require us to delete your Personal Data—in certain situations.

4.     •The right to require us to restrict processing of your Personal Data— in certain circumstances, e.g. if

you contest the accuracy of the data.

5.     •The right to receive the Personal Data you provided to us, in a structured, commonly used and

machine-readable format and/or transmit that data to a third party—in certain situations.

6.     •The right to object: —at any time to your Personal Data being processed for direct marketing (including

profiling); —in certain other situations to our continued processing of your Personal Data, e.g.

processing carried out for the purpose of our legitimate interests.

7.     •Not to be subject to automated individual decision-making. The right not to be subject to a decision

based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please:

8.     •email, call or write to us and let us have enough information to identify you (e.g. your full name, address and client or matter reference number, if applicable). Our contact details are: Cheyne Aston Ltd, Latter Cott Lane, Burley, Hampshire, BH24 4BB.

9.     •let us have proof of your identity and address (a copy of your current passport or driving licence and a recent utility or credit card bill); and let us know what right you want to exercise and the information to which your request relates.

Keeping your Personal Data secure

We have appropriate security measures to prevent Personal Data from being accidentally lost, or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at "https://ico.org.uk/concerns" or telephone: 0303 123 1113.