Privacy Policy

Privacy Notice provided by Cleaver Property Management Ltd

Relating to

Contracted Clients (Management Companies)



This privacy notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during our contracted management of your Management Company and after our contract ends. We are required to notify you of this information under the General Data Protection Regulation.


Please ensure that you read this notice (sometimes referred to as a “privacy notice” and any other similar notice we may provide to you from time to time when we collect or process personal information about you. This privacy notice contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

1. WHO WE ARE

Cleaver Property Management Limited trading as Cleaver Property Management Limited (CPM Ltd), collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as “controller” of that personal information for the purposes of those laws.

In this privacy notice, references to “we” or “us” means Cleaver Property Management Limited.

2. DATA PROTECTION PRINCIPLES

We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR data protection policy.

3. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED BY US

In the course of “issuing and collecting Service Charges & Ground Rents”, “debt collection of Service Charges & Ground Rents”, “Leaseholders requesting information”, “contacting Contractors”, “maintenance of Common Parts” , “Solicitors for Sale Enquiries/Notices of Transfer”, “Card Processing”, “Bank Account details” and “Tenant contact information”, we collect the following personal information when provided to us:
  • Name, Contact Details, Address, Property Address, Home and Mobile Telephone Numbers, E-Mail Address, Mortgage Details and Bank Details. Family Name(s)/Contact Details, Address, Home and Mobile Telephone Numbers, Email Address.
    Leaseholder Name, Contact Details, Address, Mobile Telephone Number and Email Address.
    Mortgage Details and Credit/Debit Details and Tenant Name(s), Contact Details, Address, Mobile Telephone Number and E-mail Address.
The provision of Name, Contact Details, Address, Property Address, Home and Mobile Telephone Numbers, E-Mail Address (refer above) is required from you to enable us to perform our contract as Managing Agents appointed for and on behalf of your Management Company. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

4. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES

We also obtain personal information from other sources as follows:
  • Mortgage Details from Solicitors (provided by Solicitors on Completion of Sale)
  • Credit/Debit Card Details from Individuals (provided by owners, tenants on payment of Service Charge/Ground Rent)

5. HOW WE USE YOUR PERSONAL INFORMATION

We will typically collect and use this information for the following purposes:
  • For the performance of a Contract we have with your Management Company and pursuant to which we are appointed as Managing Agent.
We seek to ensure that our information, collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.

6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share the following categories of personal data
  • Name, Address, Home and Mobile Telephone Numbers, E-Mail
This personal information may be shared with the following categories of recipients:
  • Freeholder, Solicitors, Debt Collection Agency, Insurance Broker, Contractors, Focus Software, MailBigFile, Microsoft and 1&1
Some of those third-party recipients may be based outside the European Economic Area – for further information, including on how we safeguard your personal data when this occurs, see “Transfer of your information out of the EEA”.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

7. WHERE YOUR PERSONAL INFORMATION MAY BE HELD

Information may be held at our offices and those of our group companies, and third-party agencies, service providers, representatives and agents as described above.

We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.

Or, for example, a set number of years after a data subject ceases to be a lessee in that development.

8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT

We will hold your Name, Address and Contact Details for a period of 6 plus 1 Years.

9. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION

We rely on Contract and Legitimate Interests as the lawful basis on which we collect and use your personal data.

Our Legitimate Interests are to enable the day to day Management of your Management Company.

10. TRANSFER OF YOUR INFORMATION OUT OF THE EEA

We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
  • Microsoft 365 / USA in order to download our data for retrieval or maintenance. Microsoft has extensive expertise in protecting data, championing privacy and complying with complex regulations and currently complies with both EU-US Privacy Shield and EU Model Clauses.
  • The MailBigFile Business/Ireland, The MailBigFile Pro/USA or The MailBigFile Free Service/USA in order to zip file large data files to send by E-Mail. MailBigFile protects all personal data using an industry standard Advanced Encryption Standard (AES-256) encryption algorithm to encrypt data in transfer and at rest. All servers are protected by fully managed AWS firewalls. Server software is updated daily to ensure we have all the security latest patches. Only key technical staff have direct access to servers.

  • Dropbox/USA and around the world in order to share large amounts of data by E-mail. Dropbox provide the Service, they store, process and transmit information in the USA and locations around the world – including outside of the United Kingdom. Information may also be stored locally on the devices we use to access these Services. EU-US Privacy Policy and Swiss-US Privacy Policy Shield – when transferring data from the European Union, the European Economic Area and Switzerland, Dropbox relies on a variety of legal mechanisms, including contracts with our users. Dropbox complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union, the European Economic Area and Switzerland to the United States. You can find out more about Dropbox Privacy Shield at https://www.privacyshield.gov Dropbox is overseen by the US Federal Trade Commission. JAMS is the US based independent organization responsible for reviewing and resolving complaints about Dropbox Privacy Shield compliance – free of charge. Submit any such complaints directly to privacyshield@dropbox.com. If you are not satisfied with Dropbox response please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield.

  • DocuSign, an American company with the HQ in San Francisco, California. It allows us to manage agreements electronically. DocuSign offers eSignature, a way to sign electronically on different devices. Signatures processed by DocuSign are compliant with the US ESIGN Act and the European Union's eIDAS regulation, including EU Advanced and EU Qualified Signatures.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst European Commission has not given a formal decision that USA/China provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to relevant safeguards as permitted under the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

If you would like further information, please contact our Data Protection Officer (see “How to contact us” below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

11. YOUR RIGHTS

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
  • Fair processing of information and transparency over how we use your personal information
  • Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure of personal information concerning you in certain situations
  • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • Object at any time to processing of personal information concerning you for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • Object in certain other situations to our continued processing of your personal information
  • Otherwise restrict our processing of your personal information in certain circumstances
  • Claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, 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:
  • E-mail us on GDPR@cleaverproperty.co.uk or
  • Telephone us on 0118 9787182 or
  • Write to us at Cleaver Property Management Ltd, GDPR, Unit 4 Anvil Court, Denmark Street, Wokingham, Berkshire, RG40 2BB
  • Let us have enough information to identify you (full name, address and property address)
  • Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill) and
  • Let us know the information to which your request relates, including any account reference number(s) if you have them

12. KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you any applicable regulator or a suspected data security breach where we are legally required to do so.

13. HOW TO COMPLAIN

We hope that we can resolve any query or concern you 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).

14. CHANGES TO THIS PRIVACY NOTICE

This privacy notice was published on 1st May 2018 and last updated on the 5th May 2021.

15. DO YOU NEED EXTRA HELP?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).