This version of our Privacy Statement is live from 17/08/20. The content of this statement may change from time to time, so you may wish to check this page occasionally to ensure you are still happy to share your information with us.
It is important for individuals (members of the public, customers, clients, contractors, employees, agency workers) to have an appropriate source to consult about how their personal data and information is held.
This policy is intended to provide reassurance and knowledge of exactly how their information is held, processed, and shared, as well as to be published in the public domain via www.gen2.co.uk.
Gen² Property Ltd, a wholly owned subsidiary of Kent County Council, is committed to protecting and respecting any personal information that you share with us. This statement describes what types of information we collect from you as a data controller, and/or data processor on behalf of our clients. It describes how this information is used by us, how we may share it with others, how you can manage the information we hold, and how you can contact us regarding your information.
We do not use personal information from general enquiries for marketing purposes. We will never send you unsolicited ‘junk’ email or communications, nor share your details with other organisations that might. We will not sell your information to third parties.
By reading this policy online and continuing to use www.gen2.co.uk, users are agreeing to the following conditions as set out in this policy.
Gen² makes every effort to ensure that information on this website is accurate and up to date. However, we cannot accept responsibility for any loss or inconvenience caused by reliance on information on this site.
Gen² is committed to protecting and respecting your privacy. We will, as far as possible, safeguard the privacy of your data whilst providing a personalised and valuable service.
4.1 Information collected
The information we may collect includes some, or all, of the following:
- Name (including title);
- Phone number;
- Date of birth;
- Email address;
- The date and time you used our services, or contacted us regarding our services;
- The pages you visited on our website and how long you visited us for;
- Your IP address;
- The internet browser and devices you are using;
- The website address from which you accessed our website;
- Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), and company details (some of which we may obtain from an online or public business directories);
- Any information within correspondence you send to us;
- Where you act on behalf of a business, any information we collect as part of business marketing activity.
We may collect and hold the following information about you and your business / organisation:
- Information about your visit to our website, including details about your computer, your browser and how you use this website (please see the Cookie Usage section of this policy);
- Name, company name, e-mail address, phone number, and any details you may give us when contacting us via our Contact Form;
- Any information (name, company name, e-mail address, details of enquiry etc.) you send us via e-mail;
- Any personal details provided in your email or letters to us;
- Records of any services we or our partners provide for your company/business/organisation;
- If you contact us for any reason, we may retain copies of any letters, emails or online forms and may record telephone conversations with you;
5.0 Why and how we use your data
Gen² Property Ltd will only process information that is necessary for the purpose for which it has been collected. We do not collect information from publicly accessible sources, or purchase information from third parties. We will never send you unsolicited ‘junk’ email or communications, nor share your personal information with anyone else who might.
Gen² do not use automated methods to analyse, combine and evaluate information that you have provided to us, or use automated decision-making processes based on personal data.
There are various ways in which we may use or process your personal information. We list these below:
5.1 Forwarding to Third Parties
We may forward your information to a third party within the KCC Group to resolve the enquiry, task or complaint that you have raised with us if we are not the direct point of resolution (e.g. KCC-related Compliance and Facilities Management or Estates Management or Project Management queries)
If you wish for us to not forward your information or query details on, it may impact our ability to assist you with any open enquiries you have with us where the third party relies on this information for resolution. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf.
5.2 Legitimate Interests
We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
Processing necessary for us to respond to understanding customers’ needs and requirements
- To respond to any correspondence you send to us and fulfil the requests you make to us (for example: ownership enquiries, lease and rent enquiries, consultations);
- To provide property support and services (for example maintenance and facilities services);
- To analyse, evaluate and improve our products and services so that your visit and use of our website, email and telephone correspondence are more useful and enjoyable.
- For product development purposes (for example to improve quality, performance and safety);
Processing necessary for us to promote our business, brands and products
- To contact you if the company opens, closes or moves premises.
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
- For network and information security purposes i.e. in order for us or our IT Provider to take steps to protect your information against loss, damage, theft or unauthorised access;
- To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- To inform you of updates to our terms and conditions and policies.
5.3 Legal Obligation
We may process your personal information to comply with our legal requirements (for example to register sales with HM Land Registry).
5.4 Vital Interest
Sometimes we will need to process your personal information to contact you if there is an urgent safety concern relating to a property under our control and we need to tell you about it.
Under the General Data Protection Regulation (GDPR), we are required to provide you with the lawful basis under which we are processing your data.
5.5 Contacting Us
Via email, via our contact form or by giving us your business card or personal details in person.
By contacting us you are consenting to the processing of your personal data and as such consent is the legal basis being utilised. If you contact us via email, letter or our contact form your information may be held for a longer period of time.
6.0 Engaging our Services and Working with Gen2
By engaging the services of Gen², you will be asked to give us personal information including your name, company name, email address, job title, phone number, account details and any other relevant information. We require this information to provide our service, and as such contract is the legal basis for processing any information. If we are required to share information with agencies such as HMRC during the course of our engagement or afterwards, legal obligation is also the legal basis for processing any information. We will use your data to send you relevant information about the services you have requested. Depending on the nature of the contract between us we will keep this data up to a maximum of 6 years after the services have been provided.
7.0 How we may use your personal data
- Carry out our obligations arising from any agreements entered into between you and us, or our mutual client, and to provide you with the information, products and services that are requested;
- Provide you with marketing information about other services or products we offer that are similar to those that you have already enquired about, or services or products you have given us consent to do so;
- Send you event invites, company news updates and technical bulletins, when you have given us consent to do so;
- Reply to any enquiry you have sent us via this website, via email, via letter or in person;
- Send you non-marketing communications.
8.0 Your Data and your rights
You have the right to:
- be informed about how your personal data is being used;
- access your data and supplementary information;
- update your data if your information needs to be corrected or updated;
- delete your data from our records;
- restrict processing of your personal data;
- object to the processing of your data;
If you would like to exercise any of your rights, please email us at email@example.com.
9.0 Links to third-party websites
Gen² does not endorse the content contained in these sites, nor the organisations publishing those sites, and hereby disclaims any responsibility for such content.
10.0 Cookie usage policy
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer, smart phone, tablet etc. These include small files known as cookies. They cannot be used to identify you personally.
We use Google Analytics software to collect information about how you use www.gen2.co.uk. We do this to help make sure the site is meeting the needs of its users and to help us make improvements.
Google Analytics stores information about:
- the pages you visit on www.gen2.co.uk.
- how long you spend on each www.gen2.co.uk page;
- how you navigated to the site;
- what you click on while you’re visiting the site.
We do not collect or store your personal information (for example your name or address) so this information can’t be used to identify who you are. For more information on how Google Analytics processes this information, visit www.google.com/analytics.
The www.gen2.co.uk site does not collect any information about you except that required for system administration of the website.
Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. They are stored in the cookie directory of your hard drive, and do not expire at the end of your session. Cookies do not contain any personal information about you and cannot be used to identify an individual user. If you choose not to accept the cookie, this will not affect your access to the majority of facilities available on our website.
Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookie.
During your visit to the site you may notice some cookies that are not related to Gen². This happens when you visit a page with content embedded from a third party (for example Twitter) or use some of the links to social networking sites (e.g. LinkedIn). These websites may place cookies on your computer. You should check these third-party websites’ privacy policies for more information about their cookies if you are concerned about this.
11.0 Make a complaint
If you are unhappy with how we have processed your information, please contact us at firstname.lastname@example.org in the first instance (please indicate that this is a data protection enquiry).
12.0 Reviewing the Policy