Privacy Policy
BACKGROUND:
Property118 Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website,
www.property118.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site
. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| “Account” |
means an account required to access and/or use certain areas and features of Our Site; |
| “Cookie” |
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below; |
| “Cookie Law” |
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
| “personal data” |
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and |
| “We/Us/Our” |
Means Property118 Ltd , a limited company registered in England under company number 10295964, whose registered address is 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB. |
- Information About Us
- Our Site is owned and operated by Property118 Ltd, a limited company registered in England under company number 10295964, whose registered address is 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB.
- Our VAT number is 990 0332 34.
- Our Data Protection Officer is Neil Patterson, and can be contacted by email at npatterson@property118.com, by telephone on 01603 489118, or by post at 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB.
- What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
- Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see section 13 on Our use of Cookies and similar technologies):
- Name;
- Date of birth;
- Address and post code;
- Business/company name and trading status;
- Number of properties owned;
- Accountants details;
- Contact information such as email addresses and telephone numbers;
- Proof of residence and ID;
- Financial information such as income and tax status;
- Landlords insurance renewal dates;
- Property Portfolio details such as value and mortgage outstanding;
- How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- Providing and managing your access to Our Site;
- Supplying our products and or services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring our products and or services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by the unsubscribe link at the bottom of all emails;
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
- Provide information to our partner service and product suppliers at your request.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and or telephone with information, news and offers on our products and or We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Member profile information is collected with your consent and can be amended or deleted at any time by you;
- Anti-Money Laundering information and tax consultancy records are to be kept as required by law for up to seven years.
- How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to Us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Do We Share Your Data?
- We may share your data with other partner companies in for the purpose of supplying products or services you have requested.
- We may sometimes contract with third parties to supply products and services to you on Our behalf. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- What Happens If Our Business Changes Hands?
- We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
- How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, we aim to give you strong controls on Our use of your data for direct marketing purposes including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.
- Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- You may restrict Our use of Cookies. For more information, see section 13.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at info@property118.com, or using the contact details below in section 14.
- Our Use of Cookies
- Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Before Cookies are placed on your computer or device, you will be shown a cookie prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- The following first party Cookies may be placed on your computer or device:
| Name of Cookie |
Purpose |
Strictly Necessary |
| JSESSIONID |
Used only to collect performance data, with any identifiable data obfuscated |
No |
| __cfduid |
This cookie is strictly necessary for Cloudflare's security features and cannot be turned off. |
Yes |
- Our Site uses analytics services provided by Google Analytics and Facebook. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products AND/OR services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
- The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
- The analytics service(s) used by Our Site use(s) the following Cookies:
| Name of Cookie |
First / Third Party |
Provider |
Purpose |
| __utma, __utmb, __utmc, __utmt, __utmz |
First |
Google |
Helps to understand how their visitors engage with our website |
| _fbp |
First |
Facebook |
Helps to understand how their visitors engage with our website |
- In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@property118.com, by telephone on 01603 489118, or by post at 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
- Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
Mark Alexander - Founder of Property118
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Sign Up11:08 AM, 18th November 2013, About 11 years ago
Interesting breakthrough
Have you ever heard of the "Wayback Machine"?
It is a system which periodically takes backup copies of websites which anybody can access in years to come. I've found a Wayback Machine copy of the West Brom website dated Jan 2008 - take a look >>> http://web.archive.org/web/20070701010120/http://www.westbrom.co.uk/westbrom/mortgages.category?id=26
.
Tony the hairdresser
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Sign Up11:31 AM, 18th November 2013, About 11 years ago
Am I being unreasonable*******or do I have a right to be annoyed that one of my brokers far from being sympathetic and helpful is actually doing their best to annoy me!
This morning I have asked for any documentation they may have had in relation to my 2 x West Brom mortgages they had arranged for me. eg promotianal material relating to the product etc that Justin had asked for.
In total they have probably arranged 6 btl mortgages for me.
See what you think i have enclosed their response below.
'We do charge for copies of the documents to be issued as per the attached Data Protection Document.
On payment of the £20 fee (£10 per File / Property), I will be more than happy to provide you with any documentation that you require.'
Initially they were my first contact after recieving my first letter from West Brom
Their reaction
'oh I'm sorry, we can arrange a remortgage for you..oh and we charge £250 per mortgage'
Grrrrrrr
Thankfully I found this forum
I have to say I have another broker I deal with and he couldn't be more opposite.
Rant Over!!
Mark Alexander - Founder of Property118
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Sign Up11:35 AM, 18th November 2013, About 11 years ago
Reply to the comment left by "Marie McGarvey" at "17/11/2013 - 23:48":
Hi Marie
Thanks for your feedack.
I have created a new article regarding my complaint to the ASA and will add this to the To-Do list in the main article above this thread.
I will also include the article in The Mail in the media section. There's not much point asking people to add comments to news articles after the event as they are old news by then. Most people read the articles and the comments within a day or so of publication. Therefore, it's imprtnant for us to continue to get in quick, as soon as a new article is posted.
Thanks for the encouraging feedback 🙂
.
Dean
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Sign Up11:38 AM, 18th November 2013, About 11 years ago
I have received today a letter from The Treasury. Same answer everyone seems to be getting. We don't get involved with the Commercial decisions of a company.
Again missing the point. So I have replied and told them so. I have also mentioned that I am aware this is the standard answer to us all. I said they need to look at the points being raised not answering points that are not raised and that we will all keep writing to them until they do. So to save them time answer our queries.
Therefore if you have had or get this standard answer, please write back and ask them to reply to the points raised.
Thanks
Addicted to fighting the WBBS
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Sign Up11:45 AM, 18th November 2013, About 11 years ago
Reply to the comment left by "Mark Alexander" at "18/11/2013 - 11:08":
Mark - a great find. So, since at least Jan 2008 until the present day, they have been peddling the key benefit of a tracker mortgage (i.e. the certainty......)
Apart from all of the other obvious comments I can make about this, which I know you will already know, perhaps the ASA et al should force lenders to elaborate on their standard disclaimer from here on in, as below:
YOUR HOME MAY BE REPOSSESSED IF YOU DO NOT KEEP UP REPAYMENTS ON YOUR MORTGAGE to NOW also include, ALSO IF YOU DO NOT AGREE TO ANY CLAUSE OR MISLEADING T&C WE HAVE DONE OUR VERY BEST TO HIDE FROM YOU IN THE SALES PROCESS AND WE WILL SEND YOU IN MISCELANEOUS HANDBOOKS THAT ARE NOT REFERRED TO IN ANY SALES OR PROMOTIONAL OR PRE-CONTRACT COMMUNICATION IN TAKING OUR YOUR MORTGAGE. PS, IF WE CAN TRY AND HIDE BEHIND ANY LAPSES IN CONSUMER PROTECTION, WE WILL DO SO AND TARGET ANY CUSTOMERS WITH ENFORCING THESE T&C'S ONLY TO PROFESSIONAL LANDLORDS
Tony the hairdresser
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Sign Up11:46 AM, 18th November 2013, About 11 years ago
To prove the point I have just made regarding the difference in attitudes between the two brokers I have just recieved this email containnig a link below from my other broker;
'Morning Tony
There was no promotional material as such, for your information I have attached on the following link a list of all available mortgages when you took out yours around May 2007.
https://dl.dropboxusercontent.com/u/54199393/Moneyfacts%20May%202007%20BTLs.pdf
Good Luck!'
Does anyone on the forum think this will help??
George Top
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Sign Up11:47 AM, 18th November 2013, About 11 years ago
I've done all on Mark's list to keep the momentum going to raise awareness, and continue the action moving forward - including contacting my MP, solicitor, broker, registered a complaint with the WBBS (still waiting for the data protection request to come back), ASA and FOS (waiting for Justin's letter to give them further information when sending back the completed complaint form that arrived from them last week). Sounds like we have a few new members joining the action this week so that's great:-)
M Jones
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Sign Up14:44 PM, 18th November 2013, About 11 years ago
For the avoidance of doubt - further to the recent change to 1.9% from 2%...
The WBBS states - "If market conditions improve and it is prudent to do so, we will reduce this additional charge further".
The WBBS didn't quite have the courage to add in the same letter what will happen if market conditions worsen so here it is straight from the horses mouth;
"... we have confirmed that, if market conditions improve and it is prudent to do so, we will look to reduce the additional charge further; however, if market conditions worsen we may look to adjust it accordingly".
Mark Alexander - Founder of Property118
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Sign Up15:06 PM, 18th November 2013, About 11 years ago
RESPONSE FROM THE ASA
"Dear Mr Alexander
YOUR COMPLAINT ABOUT WEST BROMWICH BUILDING SOCIETY
Thank you for contacting the ASA.
We have assessed the ad and your complaint and it would appear to be a matter beyond the scope of our Code. The “technical” aspects of most non-broadcast financial advertising are subject to statutory control by the Financial Conduct Authority (FCA). For that reason, we pass complaints about technical claims in ads for savings bonds to the FCA and that is what I’ve done with your complaint.
Please note that the FSA do not report their findings or contact consumers directly, but please rest assured take any necessary action. I have attached a copy of the referral acknowledgement which gives more information. You might also find their website, http://www.fca.org.uk, useful if you haven’t already come across this.
You may be interested to know that the ASA does have the power to investigate complaints about financial advertising on radio and TV. (We also investigate non-technical aspects, such as offence, in advertising in any medium.)
Thank you for taking the time to share your concerns.
Kind regards
Emma Fuller
Complaints Executive
Direct line 020 7492 2232"
My response to Emma
Dear Emma
Thank you for your reply but this is no good to me whatsoever.
The FCA only regulate consumer financial services.
The advertisement I have referred you to relates to “Tracker Mortgages” for buy to let landlords which fall outside the scope of the FSA.
The advertisement is clearly misleading given the circumstances. So far as evidence goes this is a “smoking gun”.
Since making my initial complaint I have gathered further evidence of the West Brom’s misleading financial promotions for their tracker rate mortgages which appeared on their website back in January 2008. This evidence was obtained via the “Wayback Machine” – see >>> http://web.archive.org/web/20070701010120/http://www.westbrom.co.uk/westbrom/mortgages.category?id=26
My understanding is that you are responsible for investigating misleading advertisements. My particular complaint has about as much relevance to the FCA as it does to Battersea Dogs Home, i.e. none whatsoever!
I look forward to your reply.
Tony the hairdresser
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Sign Up15:08 PM, 18th November 2013, About 11 years ago
I recieved this link this morning fom one of my brokers; with the following message;
' for your information I have attached on the following link a list of all available mortgages when you took out yours around May 2007.
https://dl.dropboxusercontent.com/u/54199393/Moneyfacts%20May%202007%20BTLs.pdf
DOES ANYONE THINK IT IS OF ANY USE?