Privacy Policy

OUR PRIVACY POLICY

When you use TwentyFirst Living services, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we collect it and what we do with it.

This is important; we hope you will take time to read it carefully and to share it with anyone else connected to your property.

PERSONAL INFORMATION

Personal information is information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details.

INFORMATION THAT WE COLLECT

We collect information to provide better services to our customers and all our website users. We may collect and process the following personal information about you:

Contact Your name, postal address, email address, phone number

Personal details Age, gender, financial details, lifestyle and social circumstances

Transactional Bank and / or card details, how you use your product, details about payments to and from your accounts with us

Contractual Details about the products or services we provide to you

Consent and preferences Permissions, consents or preferences that you give us, including things like opt-in to our newsletters

Open data and public records Information about you that is openly available

Documentary data Details about you available in documents like: your passport, your driver licence, National Insurance number or any other ID

Location IP address, geographical location

Technical Details on the devices and technology you use

Special types of data The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

Health data

Racial or ethnic origin

Religious, political or philosophical beliefs

Trade union membership

Genetic and bio-metric data

Lifestyle information, including data related to sex life or sexual orientation

Criminal records of convictions and offences

Allegations of criminal offences

Other information Any other personal information that you choose to share with us

HOW WE USE INFORMATION THAT WE COLLECT

We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones and to protect TwentyFirst Living and our customers. We also use this information to: Offer you personalised offers and services Tell you about changes to our services and products. Comply with any applicable legal or regulatory requirements Run our business in an efficient and proper way Carry out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business Provide you with marketing information about services and products we offer which may be of interest to you We may also use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our products and services. Please see our cookie policy for information on how we use cookies.

INFORMATION THAT WE SHARE

We do not share personal information with companies, organisations and individuals outside of TwentyFirst Living unless one of the following circumstances applies:

You give us your consent to do so.

In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.

If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

In order to enforce or apply the terms of any contract with you.

If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

To protect you and TwentyFirst Living from financial crime, TwentyFirst Living may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to me (an identity search). This will not affect your credit rating. If this fails, TwentyFirst Living may need to approach you to obtain documentary evidence of identity.

If you make a claim, we’ll share your information (where necessary) with other insurance companies to prevent fraudulent claims.

TRANSFERRING YOUR DATA OUTSIDE THE EEA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") to third-party suppliers, delegates or agents. We’ll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

We will only send your data outside of the European Economic Area (‘EEA’) to:

Follow your instructions

Comply with a legal duty

Work with our suppliers who help us to run our business

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:

Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website

Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website

Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

HOW LONG WE KEEP YOUR DATA

We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.

YOUR RIGHTS

You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s Office website. If you wish to exercise any these rights, please get in touch with your customer services team.

ID 1 - The right to be informed

ID 2 - The right of access

ID 3 - The right to rectification

ID 4 - The right to erasure

ID 5 - The right to restrict processing

ID 6 - The right to data portability

ID 7 - The right to object

ID 8 - Rights in relation to automated decision making and profiling

CHANGES

This policy was updated in May 2019. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or through other communication systems

THIRD PARTY WEBSITES

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

UPDATING INFORMATION

Please let us know if the personal information that we hold about you needs to be corrected or updated.

CONTACTS AND COMPLAINTS

If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with your usual TwentyFirst Living contact. Alternatively, you can also use the Contact Us section of our website.

If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team, Information Commissioner's Office, Wycliffe House Water Lane, Wilmslow SK9 5AF

OUR DETAILS

We are registered in England under registration number 10090816, and our registered office is at 1 Barrier Point Road, London, United Kingdom, E16 2SB.

We are registered in Spain under registration number 18067791, and our registered office is at Calle Duero, 9, Of. 4, 35600 Puerto del Rosario, Fuerteventura.