Introduction and Who We Are
The website (www.anynest.co.uk) (“the website”) is owned and maintained by Safe Haven London (Shared Ownership) Limited whose registered office is 3 Bunhill Row, London, England EC1Y 8YZ. Safe Haven London (Shared Ownership) Limited is a company limited by guarantee in England and Wales (No. 13320060). For the purpose of this Privacy Notice and the website, Safe Haven London (Shared Ownership) Limited is trading under the brand name AnyNest (“AnyNest”) so all references in the Privacy Notice to AnyNest is a reference to the legal entity Safe Haven London (Shared Ownership) Limited, a company limited by guarantee in England and Wales (No. 13320060). Safe Haven London (Shared Ownership) Limited is the controller and is responsible for your personal data.
In this Privacy Notice all references to “AnyNest”, “we”, “us” and “our” mean Safe Haven London (Shared Ownership) Limited and “you” means the user of the website.
In this Privacy Notice the following terms have the meaning set out below:
“Data Protection Legislation” means unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as may be amended by the proposed Regulation on Privacy and Electronic Communications).
“GDPR” means the General Data Protection Regulation ((EU) 2016/679).
“Personal Data” has the meaning given to that term in the GDPR.
“Process” has the meaning given to that term in the GDPR and “Processed” and “Processing” shall be construed accordingly.
This Privacy Notice tells you about the information we collect from you (including any Personal Data), what we ask others to tell us about you and what we do with your information and who we share it with.
At AnyNest we treat your information (including your Personal Data) with the highest standards of security and confidentiality, in accordance with Data Protection Legislation. We are committed to protecting your privacy and recognise our responsibility to hold your information securely and confidentially.
This website is not intended for children.
It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy statements and is not intended to override them.
What information we collect and how we use it
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
We will collect Personal Data and other information when you register an interest with us, request to be added to our mailing list, contact us with questions, apply to AnyNest or carry out transactions with us once you have purchased a home through AnyNest. You may also provide information to us directly (including Personal Data) verbally and in writing including by email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, financial adviser/mortgage broker, accountant or bookkeeper (if you are self-employed) and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner We consider a completed application as your consent to obtain this information. With regards to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
It is possible for you to visit our website without telling us who you are or revealing any Personal Data about yourself. As you browse through our website, our web server collects information about your visit, not about you personally.
We use the information collected under clause 2.3 above to gather and monitor useage statistics including but not limited to:
- The number of people who visit our website;
- The number of new/repeat visitors;
- The date and time of visits;
- The number of pages viewed;
- The time spent on the website; and
- The most popular sections of our website.
The information collected under clause 2.3 is anonymous and no attempt will be made by us to identify visitors. The information can help us to ensure our website is user friendly and convenient for visitors. We are able to and do use this information for:
- research and management information purposes;
- to help us improve our services;
- to help us administer and maintain our website;
- to help us improve the effectiveness and efficiency of our business;
- to help improve or modify the way our managers make decisions; and
- to help us determine and monitor how we look after public funds.
Collecting & Using your Personal Data
Where it is necessary to provide you with any service you request (for example, if you subscribe to receiving email updates or newsletters from us, you register an interest in making an application with us, or if you use our contact form to send us a query) we will ask you for your Personal Data so that we can provide you with a response and the information you request. If you are submitting Personal Data to us which belongs to or relates to another person you confirm that you have their consent to provide us with their information.
This Personal Data may include: your name; title; gender; nationality; address; phone number and/or your email address; your civil/marital status; employment and renumeration information (including salary/bonus schemes/overtime/sick pay/other benefits); your employment history; your bank account details; tax information; loans and credit commitments; personal credit history; sources of income and expenditure; family circumstances and details of dependents; details any of your pre-existing Mortgage/Loans/Financial and Insurance products and the terms and conditions relating to these; your health information and your personal and family health history. This list is not exhaustive and will depend on the nature of your requests to us and any application you may make.
If you decide to complete an application to AnyNest, we will ask you (and anyone applying with you) to supply Personal Data and information, including identity details, contact details, details of your income and outgoings, your financial history, your employment status, a landlord reference and any dependants you might have. If you are employed we may ask you to give us information from your employer. If you are self-employed we may ask you to give us information from your accountant or any person who deals with your accounts. We use the information you provide (and the information provided by any other applicants) along with information provided by a credit reference agency to assess whether the AnyNest scheme is suitable for you. If we think it is, we will also use the information to work out what level of rent and mortgage payments we think you can afford. We may also use the information you supply:
- for research and management information purposes;
- to help us improve our services to you and other customers;
- to help us improve the effectiveness and efficiency of our business;
- to help improve or modify how our managers make decisions;
- to help us determine and monitor how we look after public funds; and
- to help us administer and maintain our website.
If you are successful in your application we will use the information you give us as well as the information on the mortgage product you have selected to administer the equity sharing lease between you & us and also in connection with the purchase of further shares in the property.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us, email any changes to firstname.lastname@example.org.
Storing and Sharing your Personal Data
Personal Data we collect from the Register Your Interest page on the website will be stored in a Mailchimp data-base [https://mailchimp.com/legal/privacy/]. The rest of the information we receive via the Contact Us screens will be stored on the website.
AnyNest may also share your Personal Data with the third parties set out in clauses 10 and 11 and also if we have a good faith belief that such action is necessary to: (i) protect and defend the rights or property of AnyNest; (ii) enforce this Privacy Notice or the websites’ terms and conditions of use agreement; (iii) protect the interests of other users of the website or any other person; or (v) operate or conduct maintenance and repair of the website or equipment.
AnyNest may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In the course of handling your Personal Data, we will:
- record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and contractors within AnyNest and only when it is necessary to provide our service to you and to perform any contract we have with you and any administration tasks associated with or incidental to that service or contract; and
- submit your Personal Data to the entities set out in clauses 10 and 11 below, both in paper form and online via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that may raise.
Protection of Personal Data
Taking into account the risks involved in the processing and nature of Personal Data and to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction and while maintaining data accuracy, AnyNest has put in place appropriate physical, electronic, and managerial security policies and procedures to safeguard the Personal Data it collects from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we do our best to protect the Personal Data we cannot and do not guarantee the security of your Personal Data.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Consequences of Failure to Provide Information
Where we need to and we cannot collect the necessary Information from you, it will make it impossible for us to respond to your queries, add you to our mailing list and provide you with information on our products, future updates and the purposes as outlined above. It will also make it impossible for us to process any application you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
The Lawful Grounds for Processing your Information
If we Process any of your Personal Data we will only do so for lawful reasons as permitted by Data Protection Legislation. These are:
- Contract: the processing is needed because you have applied to us and if successful you will have a contract with us and in order to perform a contract we have together;
- Legal obligation: this is so that we can comply with certain laws and regulatory requirements;
- Consent: when you have consented to us processing your information;
- Legitimate Interests: this means that the processing is in our legitimate interests. We will not prejudice your rights when processing your information for our legitimate interests and you have a right to opt out of our processing on this basis at any time.
- Criminal Law Enforcement: including for the detection and/or prevention of criminal activity or where it is necessary for the assessment of risk or prevention of fraud.
The Purpose of Processing your Personal Data and the associated Lawful Bases
- We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so.
- Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Why we process your information
The grounds we rely on to do this
To send you information regarding our products and future updates, future information evenings and events.
To understand how people interact with our websites, carry out and determine the effectiveness of advertising/marketing campaigns and to help us run promotional campaigns.
To add you to a mailing list
To give you information on your application
To comply with legal and regulatory requirements
To process and administer your application
To verify your identity
Assess potential customers to determine whether we can proceed with your application and on what terms
Disclose data to any of the persons or organisations as set out in clauses 10 and 11 below
Legal obligation, Contract, Legitimate Interests and Criminal Law Enforcement
To share member’s rental payments with the Experian Rental Exchange
Contract and legitimate interests
Identify and prevent fraud and enhance the security of our network and systems.
Comply with legal requirements relating to Anti-Money Laundering compliance
Legal obligation and Criminal Law Enforcement
Understand how people interact with our websites
Carry out and determine the effectiveness of advertising, and of marketing campaigns
Run promotional campaigns
Carry out analysis of customers to assess risk, model, and plan strategy & growth
Legal obligation, Consent, Legitimate Interests and Criminal Law Enforcement
We may monitor, record and keep any calls you make to us and any emails you send us via this website for the purposes of responding to your request.
Where you have subscribed to our email update service or mailing list, you may unsubscribe at any time. A quick link facility for unsubscribing is included in each email update. To view our Marketing Privacy Statement on how we process Personal Data for our mailing lists please see www.anynest.co.uk/marketing-privacy-policy
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Criminal Convictions and Offences
AnyNest may hold, use, disclose and process Personal Data relating to criminal conviction and offences where it is necessary for the assessment of risk or prevention of fraud.
Who We Share your Information with:
In order to provide our services and comply with legal obligations imposed on us we may share your Information with:
- Our outsourced service provider Northern Ireland Co-Ownership Housing Association Limited (Co-Ownership) which provides processing services for us: for example answering queries and requests for information (by phone, email, social media or other methods), processing applications to AnyNest (including carrying out credit checks) and acting in the administration and management of the equity sharing lease between us.
- Service providers who provide services to us (such as Google Analytics and Mailchimp);
- Legal, financial, valuation & other professional advisors;
- Insurance Product Providers / Conveyancers;
- Outsourced processing companies for example merchant payment suppliers, payment services providers and valuation software;
- The lender you have a mortgage with and its agents and/or your landlord;
- Your employer and/or your accountant (if you are self-employed);
- Your financial adviser/mortgage broker;
- Debt tracing agencies;
- IT Maintenance personnel;
- The Financial Conduct Authority and any successor body;
- Our auditors, accountants and HMRC; and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. This sharing of your Personal Data does not entitle such third parties to send you marketing or promotional messages. It is shared to ensure we can adequately fulfil our responsibilities to you and the services you request of us, and as otherwise set out in this Privacy Notice.
Sharing your information and Personal Data with a Credit Reference Agency
If you make an application we will also share information you supply (including Personal Data) on your application with Experian, or another credit reference agency, and searches may be undertaken to validate your identity, your credit history and your criminal records and to assess whether the AnyNest scheme is suitable for you. The Credit Reference Agencies/Criminal Records Bureau may check the details supplied against any databases (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. We may also use information gained from conducting the credit search to identify the most suitable lender for your circumstances. A record of the search will be retained, but will not affect future credit. By ticking the check box below you are agreeing to this Privacy Notice and to a search being undertaken in this way.
If your application is successful, AnyNest will report your rental payment information to with Experian’s Rental Exchange. This will allow you to establish or build credit history and will help you to access financial products and services and prove your identity. In the event that you do not pay your rent on time, your credit report may be negatively impacted.
Your track record with AnyNest will enable Experian to will use the information supplied to them in the future to assist other landlords and organisations to:
- Assess and manage any new tenancy agreements you may enter into;
- Assess your financial standing to provide you with suitable products and services;
- Manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
- Contact you in relation to any accounts you may have and recovering debts that you may owe;
- Verifying your identity, age and address, to help other organisations make decisions about the services they offer;
- Help to prevent crime, fraud and money laundering;
- Screen marketing offers to make sure they are appropriate to your circumstances;
- For Experian to undertake statistical analysis, analytics and profiling; and
- For Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage
We will continue to exchange information about you with Experian while you have a relationship with us. We will also inform Experian when that relationship has ended and if you have outstanding rental arrears Experian will record this outstanding debt. This information may be supplied to other organisations by Experian [https://www.experian.com/privacy/]
How Long will we keep your Information?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for or for which you gave it to us, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, or such other longer period of retention required by the Data Protection Legislation or other applicable law or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For more information please contact our Data Protection Officer as detailed below.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Unless we deem otherwise as a result of this clause, for legal and best practice reasons, we keep your information for 6years after the date on which your contract with us ends.
In some circumstances you can ask us to delete your Personal Data. Please see the “Your Rights” clause (clause 18) below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Transfer of Information
We will not transfer your Personal Data outside of the European Economic Area (“EEA”).
Information relating to AnyNest clients
If you register an interest on our website about becoming a client or making an application, details of how we process your Personal Data and who we share it with will also be contained in the relevant application forms and literature we send you. We ask that you read these carefully as they may contain different information to what we have set out in this Privacy Notice.
Accessing your Information:
You have the right to obtain a copy of your Personal Data which is under our control and to ask us to further explain how we use Your Personal Data. If you would like a copy of your information, please write to our Data Protection Officer as detailed below. Your request will be dealt with as quickly as possible and in any event you will not have to wait for more than a month for us to respond. If at that stage we are unable to provide the data you require (due to the complexity or number of requests) we can extend the period to provide the data by a further two months but shall explain the reason why.
Correcting or Erasing your Information and/or Restricting its Use:
You have the right to have your information corrected free of charge by contacting our Data Protection Officer as detailed below. You can also require us to restrict or stop using your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request).
Automated Decision Making:
An Automated Decision is a significant decision affecting you that is made using your Personal Data solely by automatic means, where no humans are involved in the decision-making process. We do not and will not make automated decisions affecting you based on profiling. An indicative conclusion may be reached on the basis of Personal Data you have provided, but a member of our team will always review this.
Portability of your Personal Data
You can ask us to send an electronic copy of your Personal Data to another organisation should you wish.
You may revoke or change the basis of any consent you may have provided to us (including in respect of marketing communications) at any time with future effect. An informal email or message via our email address email@example.com making this request is sufficient. The data processed before we receive your request may still be legally processed.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Who controls your Personal Data and how can you contact them?
AnyNest controls your Personal Data. Any questions or concerns you have can be addressed to our Data Protection Officer, at firstname.lastname@example.org Tel. 01372 860835 or by email at email@example.com In the interest of customer service and to ensure the accuracy of our records, calls may be recorded and monitored).
Your Right to Make a Complaint
If you are unhappy about the way we handle your Personal Data please contact our Data Protection Officer and we will do our best to address your concerns swiftly and resolve any issues you have.
If you have a concern about an organisation’s information rights practices, you can report it to the Information Commissioners Office (“ICO”) helpline on 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
In order to maintain the highest levels of service, telephone calls made to our offices are dealt with through a call routing system and may be recorded. A statement that calls may be recorded for business or training purposes is played on connection of each incoming call. Please also note that telephone calls may be answered by our outsourced service provider Co-Ownership.
On every page of the website you will see buttons for social media sites such as Twitter or Facebook. You should be aware that if you click on any of these buttons, these external third party sites will be registering that action and may use your information. In some cases these sites will be registering the fact that you are visiting our site and the specific pages you are on. This might happen even if you don’t click on the button if you are logged into their services. You should check the respective policies of such sites to see how exactly they use your information and to find out how to opt-out or delete such information.
- Analytics – The website uses analytical data provided by Google Analytics. You can find out more about the types of analytical data and how that data is processed by visiting https://www.google.com/policies/privacy/partners/
- Do Not Track Signals – AnyNest does not respond to Do Not Track signals
We reserve the right at any time to revise this Privacy Notice without notice. The revised version will be made available on the website. Therefore, please regularly review the Privacy Notice posted on this website.
Law and Jurisdiction
This website, any content contained therein, any usage of and the operation of our website are governed by and construed in accordance with the laws of England and Wales. The Courts of England and Wales have exclusive jurisdiction over all claims or disputes arising in relation to, out of or in connection with this Privacy Notice and/or the website.
Changes to this Privacy Notice
We keep our Privacy Notice under regular review. This Privacy Notice was last updated in March 2021.
You have the right to cancel your application at any point prior to signing and exchanging contracts for the purchase of the property. You must notify us as soon as possible if you are longer able to proceed with the application. You will need to notify us in writing to firstname.lastname@example.org. Please note that AnyNest is not liable for any fees, expenses, legal costs or other associated costs that you may have incurred during the processing of your application.
The application fee covers the cost of processing your application and this fee is strictly non-refundable.
Once the valuation has been instructed by AnyNest, the property fee is non-refundable.
If the property declined due to the inspection report, there is no refund of the property fee due.
If you have any questions or comments about this Privacy Notice please email us at AnyNest@Co-ownership.org.
30 June 2021