Privacy policy

This policy explains how Halvenor Realty (“Halvenor”, “we”, “us”) handles personal data when you use our website, contact an agent, book a viewing, create an account or subscribe to our newsletter. It applies to visitors in the European Economic Area (EEA), the United Kingdom, Canada and the United States, and includes specific sections for California residents.

Who is the controller

The controller of your personal data is Halvenor Realty, 27 Larkfield Place, London EC2A 3XX, United Kingdom. Our offices in New York and Toronto act as joint controllers for data relating to their clients. You can reach our privacy team at privacy@halvenor.example. Where required, we have appointed representatives in the EEA and the United Kingdom, whose details are available on request.

What we collect

We collect the information you give us, such as your name, email address, telephone number, message, property preferences, budget, mortgage and employment details if you request a mortgage pre-qualification, and documents you upload. We also collect information automatically, including device and browser data, pages viewed, approximate location from your IP address and cookie identifiers, as described in our cookie policy.

We may receive information from third parties, such as referral partners, portals through which you enquire about a listing, identity verification providers and public registers.

• Identity and contact data: name, email, phone, address, preferred language
• Enquiry and preference data: properties saved, searches, viewings, messages
• Financial data you choose to share: income, deposit, mortgage preferences
• Technical data: IP address, device, browser, pages visited, referral source
• Marketing preferences and consent records

Why we use your data and our lawful bases

Under the GDPR and UK GDPR we must have a lawful basis for each use of your data. We rely on the following bases.

• Contract: to respond to your enquiry, arrange viewings, provide valuations and manage tenancies or sales you instruct us on
• Legitimate interests: to operate and improve the site, prevent fraud and abuse, analyse aggregated usage and send service messages, after balancing our interests against your rights
• Consent: for marketing emails, optional cookies and sharing your details with named partners such as mortgage advisers; you can withdraw consent at any time
• Legal obligation: for anti-money-laundering checks, tax records and responding to lawful requests from authorities

Who we share data with

We share data with service providers that process it on our instructions, including hosting, email delivery, customer-relationship software, analytics and identity checks. We share enquiry details with the agent responsible for the property, and, where you ask us to, with lawyers, lenders and surveyors. We may disclose data to authorities where required by law, and to a buyer if our business is sold. We do not sell personal data for money.

California residents: in the past twelve months we have not sold personal information. We may “share” limited identifiers and internet activity with advertising partners for cross-context behavioural advertising only if you have opted in to advertising cookies; see section 9 and our Do Not Sell or Share page.

International transfers

Halvenor operates in the UK, EEA, Canada and the US, and our providers may process data in other countries. When we transfer personal data out of the EEA or UK to a country that has not been found adequate, we use the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, and we carry out transfer risk assessments. You can request a copy of the safeguards by contacting us.

How long we keep data

We keep enquiry records for up to three years after the last contact unless you become a client. Sales and tenancy files are retained for seven years to meet tax and anti-money-laundering requirements. Marketing consent records are kept for as long as the consent is valid and for two years afterwards. Server logs are kept for 90 days. We delete or anonymise data when it is no longer needed.

Your rights under GDPR and UK GDPR

If you are in the EEA or UK you have the right to access your data, to have inaccurate data corrected, to have data erased, to restrict or object to processing, to data portability and to withdraw consent. You also have the right not to be subject to solely automated decisions with legal effects; we do not make such decisions. To exercise any right, use the form on our Do Not Sell or Share page or email privacy@halvenor.example. We respond within one month.

You may complain to your data protection authority, such as the Information Commissioner’s Office in the UK, the Irish Data Protection Commission, the CNIL in France or your local authority. We would appreciate the chance to resolve your concern first.

Your rights in California (CCPA and CPRA)

California residents have the right to know what personal information we collect, use, disclose and share; to delete it; to correct inaccurate information; to opt out of the sale or sharing of personal information; to limit the use of sensitive personal information; and not to be discriminated against for exercising these rights. We collect the categories of information listed in section 2 and use them for the business purposes described in section 3.

You can submit a request through the privacy request form or by emailing privacy@halvenor.example. We will verify your identity by matching information you provide with what we hold, and you may use an authorised agent. We respond within 45 days, extendable once by a further 45 days.

Cookies and similar technologies

We use necessary cookies to operate the site and, only with your consent, analytics, preference and advertising cookies. We honour the Global Privacy Control signal as a request to opt out of sale or sharing. Details are in our cookie policy.

Children

Our services are not directed at anyone under 16, and we do not knowingly collect their data. If you believe a child has given us personal data, contact us and we will delete it.

Security

We protect data with encryption in transit, access controls, staff training and regular testing. No system is completely secure, and if a breach affects you we will notify you and the authorities as required by law.

Changes and contact

We will post changes to this policy on this page and, for material changes, tell you by email. Questions can be sent to privacy@halvenor.example or by post to Privacy Team, Halvenor Realty, 27 Larkfield Place, London EC2A 3XX.