Privacy Policy

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of
our website visitors and service users; in other words, where we determine the purposes and
means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when
you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to Leasehold Management Services Limited. For more information about us,
see Section 12.

2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and
specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data
may include your IP address, geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation paths, as well as information
about the timing, frequency and pattern of your service use. The source of the usage data is our
analytics tracking system. This usage data may be processed for the purposes of analysing the
use of the website and services. The legal basis for this processing is our
legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your personal data that are provided in the course of the use of our services
(“service data“). The service data may include your title, your full name, your company or trust name, your property address, your contact telephone numbers, your email address and you emergency contact name and telephone number. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis for this processing is
our legitimate interests, namely the proper administration of our website and
business.
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or
services (“enquiry data“). The enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The legal basis for this processing is
consent.
2.5 We may process information contained in or relating to any communication that you send to us
(“correspondence data“). The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The correspondence
data may be processed for the purposes of communicating with you and record-keeping. The
legal basis for this processing is our legitimate interests, namely the proper administration of
our website and business and communications with users.
2.6 We may process any of your personal data identified in this policy where necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the legal
rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this
Section 2, we may also process any of your personal data where such processing is necessary
for compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our
subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably
necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as
reasonably necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, obtaining professional advice, or the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose
your personal data where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital interests of another
natural person. We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.

4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help
ensure that we comply with our legal obligations in relation to the retention and deletion of
personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) Usage data will be retained for a minimum period of 2 years following the date in which we first are provided with this data.
(b) Service data will be retained for a minimum period of 2 years following the date in which we first are provided with this data.
(c) Enquiry data will be retained for a minimum period of 2 years following the date in which we first are provided with this data.
(c) Correspondance data will be retained for a minimum period of 2 years following the date in which we first are provided with this data.
4.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural person.

5. Amendments
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.

6. Your rights
6.1 You may instruct us to provide you with any personal information we hold about you; provision of
such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept
a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility
bill showing your current address).
6.2 We may withhold personal information that you request to the extent permitted by law.
6.3 You may instruct us at any time not to process your personal information for marketing
purposes.
6.4 In practice, you will usually either expressly agree in advance to our use of your personal
information for marketing purposes, or we will provide you with an opportunity to opt out of the
use of your personal information for marketing purposes.

7. Our details
7.1 This website is owned and operated by Leasehold Management Services Limited.
7.2 We are registered in England and Wales under registration number 03848366, and our registered office is at 16 Manor Courtyard, Hughenden Avenue, High Wycombe, Buckinghamshire, HP13 5RE.
7.3 Our principal place of business is at 16 Manor Courtyard, Hughenden Avenue, High Wycombe, Buckinghamshire, HP13 5RE.
7.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.

8. Data protection officer
8.1 Our data protection officer’s contact details are: Jon Buller, 01494 464333.