Privacy Policy

Vega Investments Limited is a registered company in England and Wales (referred to as Vega Properties “we” or “us” or “our”). We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.

Vega Properties is also registered on the information Commissioner's Register of Data Controllers.

Why do we collect your personal data?

We may collect and process your personal data for a number of reasons. These reasons include:

• so that we may comply with any legal obligation we have;
• in order to comply with our duties and exercising our rights under a contract with you;
• the pursuit of our legitimate interests (as set out below); or
• where you have consented to the processing.

This includes, but is not limited to, information you (or a joint purchaser and/or owner) provides:

• when you/they contact us in person, on our website, over the telephone, by e-mail or by post;
• at the time of reserving a property to purchase from us;
• at the time of purchasing options and extras from us;
• during the course of purchasing a property from us and/or selling a property to us in part exchange;
• when you apply for a job vacancy with us;
• when you instruct us to provide consultancy, design or project management services.

How we collect personal information

We will collect and store your personal information when you interact with our website. We may collect personal information in writing, by telephone, by e-mail and by online applications, including through registering on our website.

We collect personal information directly from the individual to whom it relates, except where that individual has consented to us collecting the personal information from a third party or the law otherwise permits us to do so.

When you visit our website, we may automatically collect information about your computer or device, including your IP address, information about your visit, your browsing history, and how you use the website. This information may be combined with other information you provide to us, as described above.

How we will share your data

We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.

We use trusted third-parties to provide the below services and business functions, however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

We may disclose your information to third parties if:

• we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• in order to apply or enforce our contracts with you; or
• to protect our rights, property, or our safety and/or the safety of our customers, or others.

We may also disclose your information to our suppliers and contractors to provide information to you on our behalf and/or in order to fulfil our contracts with you.

We will share your personal information with suppliers of services in respect of:

• any property you reserve from us;
• the sale of the property and/or the purchase of your existing property in part exchange;
• any property you instruct us to perform works on.

These third parties may include:

• estate and managing agents;
• financial and legal advisors;
• any relevant mortgage provider;
• the National House Building Council and similar organisations;
• utility and service providers; and
• local authorities.

We will share your information with relevant government agencies to assist you to participate in any government schemes in which you have indicated you wish to take part.

Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.

What personal information do we hold about you?

Personal information means any information relating to a person that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your:

• name;
• address;
• email address;
• phone number;
• IP address;
• location data;
• details of your budget;
• the size and type of property you are interested; and
• the source of your enquiry.

We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.

How we use your information

We will use your personal data, and may share your personal data with other parties acting on our behalf, for one or more of the following purposes:

• to respond to requests which you have submitted via our website and to deal with ongoing matters relating to such requests;
• to send you marketing information on our property developments;
• to send you information on future phases of our property developments;
• to keep you informed of any activities undertaken by us which we believe may be of interest to you;
• to offering our services to you in a personalised way;
• to conduct research about the use of our website;
• to assess, respond to and resolve a complaint you might make to us;
• to notify you about changes to our goods and services;
• for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business;
• for market research purposes and for developing and improving our products and services;
• to conduct investigations of suspicious or harmful activity; and
• to comply with our regulatory and legal obligations.

We do not sell your personal information to others.

If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.

Information for marketing purposes

Where you have consented to us using your personal data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Vega Properties and its business partners which may be of interest to you.

If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, then you can contact us through the further details section.

On occasion, we will use information you have given us directly, to tailor our communications with you about our future activities, in your preferred communication method or via social media. We will also use information about how you use our website or interact with our emails so we can make them more effective (please refer to the Cookie Policy for more details).

We will also, on occasion, use the information you provide us to target our digital and social media advertising effectively. This could include securely providing contact details such as your name and email address to digital advertising networks or social media companies such as Facebook, Google and Twitter. For example, we may use your information to enable us to display adverts to you, or to prospective customers who have similar characteristics to you. Any information we share with social media companies will be shared in an encrypted format and will not be used for their own purposes.

You may still see adverts relating to Vega Properties, even after you have asked us not to use your information for targeted digital advertising, because the social media site or advertising network may select you based on information they hold, such as your age and location, or websites you have visited, without using information that has been provided by us. You can control the kind of advertising which you see through the relevant social media sites directly.

How long will we keep your data?

We only ever retain personal information for as long as is necessary and we have retention policies in place to meet these obligations. We are required under some laws or regulations to retain your personal data for a set period of time. For example, the maximum legally obliged retention period for certain health and safety related matters is 40 years. Where there is no legal obligation, for example around direct marketing information, we will hold your data for 2 years, unless you opt out within this time.

Some specific areas include, but are not limited to:

• Health & Safety related matters – up to 40 years;
• property purchases and related matters – up to 15 years;
• direct marketing – up to 2 years;
• legitimate interests – in perpetuity so long as the reason for which is was processed remains active;
• other data will be held for up to 6 years in line with the statute of limitations

We review the status of your consent every 12 months and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent.

We review the status of our legitimate interests every 12 months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.

The purposes and reasons for processing your personal data

We take your privacy very seriously and will never disclose or share your personal data without your knowledge, unless we are required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Unless we notify you, we will not process your personal data outside of the European Economic Area (EEA), as it is currently defined.

Detailed below are examples of when we would collect, process and in some cases share, your personal data:

• to ensure that content from our website is presented in the most effective manner for you and for your computer/device;
• to verify your identity;
• to process job applications;
• to process and manage your purchase of a property from us and provide after sales services where applicable;
• to carry out our obligations arising from any contracts entered into between you and us, including, for example, your purchase of a property and/or options and extras from us and (if applicable) our purchase of your existing property in part exchange;
• to facilitate the provision of warranties with a property purchased from us;
• to monitor customer satisfaction (both on our own behalf and/or for the National House Building Council) including processing customer satisfaction surveys;
• to notify utility suppliers and local authorities about your new property and about any property we have purchased from you in part exchange;
• to provide you with information, products or services that you request from us;
• to notify you about changes to our services; and/or
• to contact you about new developments and house types which may meet your needs. If you have not yet reserved a property with us, we will contact you in this way only if you have consented to us using your personal data in this way and that you want to receive this information from us.

Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.

Grounds for processing

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:

• your consent;
• performance of a contract;
• compliance with a legal obligation;
• protection of your, or another's vital interests;
• public interest/official authority; and
• our legitimate interests.

Our legitimate interests

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Vega Properties, including:

• selling and supplying properties and associated services;
• protecting customers, employees and other individuals and maintaining their health, safety and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers;
• understanding our customers behaviour, activities, preferences and needs;
• improving existing products and service and developing new products and services;
• complying with our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries or disputes;
• protecting Vega Properties, its employees and customers, by taking appropriate legal action against third-parties who have committed criminal acts or are in breach of legal obligations to Vega Properties; and
• fulfilling our duties to our customers, employees, and other stakeholders.

What are your rights over your personal data?

You have the right to access any personal information that we process about you and to request information about:

• what personal data we hold about you;
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients to whom the personal data has/will be disclosed;
• how long we intend to store your personal data for;
• if we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

• Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information's accuracy. Requests for corrections or supplements to all other personal information should be made to us at matt@vegaproperties.co.uk. We will respond to your request to correct or supplement your personal information within a reasonable time period and, in any event, within any time period specified in relevant laws.
• Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
• Right to object to processing. You may, as permitted by law, request that we stop processing your personal information.
• Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
• Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority in the relevant country directly.

If you would like your personal data to be removed or the use to be amended, you have the right to request:

• your personal data to be erased (deleted) from our records;
• the use/processing of your personal data to be restricted in accordance with data protection laws;
• to opt out of any direct marketing from us (this can be done in a number of ways and will depend on the marketing you are receiving. Please see the marketing material for how to unsubscribe);
• to be informed about any automated decision-making that we use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure.

Our use of cookies

Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we may use cookies:

• to record whether you have accepted the use of cookies on our website. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you;
• to allow essential parts of our website to operate for you;
• to operate our content management system;
• to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser;
• to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser;
• to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited;
• to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser;
• to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically;
• to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically;
• to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTubes privacy-enhanced mode.

Further details, questions, or complaints

We hope we have provided you with plenty of information around the processing of your personal data that we undertake and the rights you have over it, however if you have any additional questions or would like more details around any of the points listed above, please contact us at our registered office:

Lodging a complaint

If you are not happy with this notice, believe we have processed your data in an unfair or unjust way or are non-compliant with the relevant data protection laws and you wish to raise a complaint, please contact us and we will carefully consider your complaint and respond to you. You also have the right to lodge a complaint with the supervisory authority (the Information Commissioners Office):

Who is the Data Controller?

• If we have collected your personal data directly from you for our own purposes, we are the Data Controller;
• if we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it;
• if we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it;
• if we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it;
• if your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us at the time they collected your data and within their own privacy notices/standards;
• if we have received your personal data as part of a business to business relationship, the Data Controller is your employer.