Privacy Policy

1 Introduction
• 1.1 This Privacy Policy describes how and why Oakngate Ltd, we or the Company) acquire and
use personal information about you (Personal Data).
• 1.2 For the purpose of the Data Protection Act 2018 (the Act) and the provisions of Regulation
(EU) 2016/679 (the General Data Protection Regulation or GDPR), the Company is the Data
Controller. We are registered with the Information Commissioner’s Office and we exercise and
implement all such Privacy Regulations throughout all websites under our control.
• 1.3 This Privacy Policy (together with the terms of the Sites and any other documents referred to
on them) set out how we acquire, use and process your Personal Data in accordance with data
protection laws.

2 How we collect your Personal Data
• 2.1 We collect Personal Data directly from you via the Sites or when we meet with you at our
sales sites and via other communications between us when you make enquiries with, or
purchase a property from us; including:
• 2.1.1 your name, date of birth, home address(es), home and mobile telephone number(s), email
address(es) and employment information;
• 2.1.2 information about your transactions with us;
• 2.1.3 information and documentation you provide when you respond to requests to submit
personal information about yourself, such as identity documents;
• 2.1.4 records of written and verbal communications between us either electronic or written;
• 2.1.5 information regarding your use of the Sites, including when you access the Sites, which
parts of the Sites you access most often and the developments and properties that you view on
the Sites or save. This information is collected by actively tracking and recording your browsing
activity and collected through the use of cookies (please see section 8 for further details);
• 2.1.6 CCTV images if you attend on our premises where we use CCTV recording (see under
‘CCTV’ below);
• 2.2 We may also collect your Personal Data from third parties, for example:
• 2.2.1 from searches of Credit Reference Agencies (CRAs) and Fraud Prevention Agencies
(FPAs) of their records relating to you;
• 2.2.2 from public records (e.g. the electoral roll);
• 2.2.3 from other third parties with your consent (for example your solicitor or mortgage broker).

3 How we use your Personal Data
• 3.1 We may use the information we collect about you in order to:
• 3.1.1 provide you with our products and services;
• 3.1.2 communicate with you by telephone, email, SMS, or post;
• 3.1.3 meet our legal, regulatory and contractual obligations, including verifying your identity for
the purposes of preventing fraud and money laundering in the event that you wish to reserve one
of our properties and passing your personal data to the relevant warranty provider in order that
they can discharge their legal obligation to administer the warranty provided to you as a new
homeowner;
• 3.1.4 manage shared equity loan products you may have in place with us;
• 3.1.5 provide you with updates you have requested including keeping track of specific
developments and properties;
• 3.1.6 deliver marketing information to you about other products and services we offer that are
similar to those that you have already purchased, requested or enquired about, unless you have
opted out of receiving such communications (see under ‘Marketing’ below);
• 3.1.7 ensure that any content on the Sites is presented to you in the most effective manner for
you, your requirements and your computer;
• 3.1.8 contact you for your views on our services and events and notify you occasionally about
important changes or developments to the Sites or our services;
• 3.1.9 provide and improve customer service and support;
• 3.1.10 administer, monitor, support, improve and develop our Sites to enhance operational
capabilities and for internal operations;
• 3.1.11 verify or enforce compliance with this Privacy Policy and applicable laws.
• 3.1.12 data, generally is kept for 6 years unless specified differently within this document

4 Sharing your Personal Data
• 4.1 We may share your Personal Data with:
• 4.1.1 third parties which provide services for us where necessary for the delivery of our products
and services, for example:
a) contractors who undertake snagging work on our behalf;
b) collection agents who act on our behalf (for example to collect ground rent);
c) third parties who administer agreements on our behalf (for example shared equity loans if you
have entered into such an agreement with us);
d) suppliers who provide or make provisions to provide services to, or in relation to your property;
e) managing agents appointed in accordance with the terms of your home purchase agreement;
f) one or more specified estate agents where you enter into a Home Change agreement with us
or where we arrange the marketing of your existing home in a part exchange deal;
g) home warranty suppliers such as LABC and Premier Guarantee in order to support the
administration of the relevant warranty;
h) NHBC in order to support the administration of your Buildmark Policy where applicable;
• 4.1.2 other third parties with your consent and where you request we introduce you to them, for
example mortgage brokers and bodies including the NHBC for the purposes of undertaking
market research analysis in respect of purchasers of new homes;
• 4.1.3 law enforcement agencies or regulatory bodies where we are required to do so in order to
comply with a regulatory or legal provision;
• 4.1.4 Credit Reference Agencies and Fraud Prevention Agencies;
• 4.1.5 our professional advisers;
• 4.1.6 those companies named in the definition of Data Controller under paragraph 1.1 of this
Notice (all of those companies being in the same group of companies) for fulfilling those
purposes set out in paragraph 3 above.

5 Our legal basis for using your Personal Data
• 5.1 Our use of your Personal Data as outlined above is subject to different legal bases for
processing, including where necessary for:
• 5.1.1 The purposes of the performance of our contractual agreement with you or to take steps at
your request prior to entering into an agreement with you. If you do not provide such information
we will be unable to sell a property to you or provide other services, for example under the Home
Change scheme;
• 5.1.2 Our legitimate interests, for example in managing and monitoring the operation of our Sites
and for preventing fraud and for our services and offers to you (subject in this case to offering
you an ability to opt out);
• 5.1.3 Compliance with a legal obligation, for example under consumer, anti-money laundering
and data protection laws and making reports to regulatory authorities and to law enforcement
agencies;
• 5.1.4 Where you have consented to do so, for example in relation to data we provide to home
warranty providers for them to undertake customer satisfaction surveys.
• 5.2 Where our use of your data is not necessary for one of the purposes outlined above we may
seek your consent to use it in a particular way (as outlined at 4.1.2 above). Where we ask for
your consent you are free to refuse our use of the data for those purposes and you may withdraw
your consent at any time by contacting us using the details set out below.

6 Credit Reference Agencies (CRAs) & Fraud Prevention Agencies (FPAs)
• 6.1 We may undertake searches of CRAs to verify your identity when you apply to reserve a
property on one of our sites. We do this by submitting your Personal Data to them. We need to
undertake such searches in accordance with anti-money laundering laws. If we undertake such a
search for these purposes it will leave a ‘soft’ footprint on your credit file.
• 6.2 If you apply for a shared equity loan with us, we will undertake fuller searches with CRAs and
FPAs which go beyond verification of your identity and enable us to review your credit history.
We do this to assess creditworthiness and product suitability, manage your account, trace and
recover debts and prevent criminal activity and this may leave a ‘hard’ footprint on your credit
file.
• 6.3 Where you borrow from us under a shared equity loan, we may give details of your accounts
and how you manage it to CRAs. If you borrow and do not repay in full and on time, in
accordance with the terms of your loan, CRAs may record the outstanding debt. This information
may be supplied to other organisations by CRAs and FPAs to perform similar checks and to
trace your whereabouts and recover debts that you owe. Records remain on file for 7 years after
they are closed.
• 6.4 If you provide false or inaccurate information to us and fraud is identified, details will be
passed to FPAs.
• 6.5 You can find more information about the various CRAs and the ways in which they use and
share your personal information at https://www.experian.co.uk/crain/index.html or you can
contact the agencies directly:
Callcredit Consumer Services Team, PO Box 491, Leeds, LS3 1WZ Tel: 0330 024 7579 or
visit www.callcredit.co.uk
Equifax PLC Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US Tel: 0870 010 0583 or
visit www.myequifax.co.uk
Experian Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF Tel: 0870 241 6212 or
visit www.experian.co.uk

7 CCTV
• 7.1 We may use CCTV recording on some of our premises, including site offices, for the
purposes of security, crime prevention, health and safety and performance monitoring.
• 7.2 Wherever CCTV is in operation there will be appropriate signage.
• 7.3 We retain the images recorded only for so long as is necessary and will normally keep them
for no longer than 12 months, unless there is a specific requirement to retain them longer. The
images are recorded for our internal use and will only be shared with any third parties to protect
the legitimate business interests of the Company or where required, for example for the
purposes of the prevention, investigation or detection of crime.

8 Use of cookies
• 8.1 A cookie is a small file which is sent to your browser by the Sites and which is then stored on
your computer’s hard disk. When you browse the Sites cookies record your activity to enables us
to keep a record of any personal data submitted. We use this to understand more about you and
your preferences, to optimise your browsing experience and deliver content to you in the most
appropriate way.
• 8.2 We may work with third parties to track and research, on our behalf, your usage and activity
on the Sites. No personal information about you is shared, however in the course of conducting
this research these third parties may place a unique “cookie” on your computer’s hard disk.
• 8.3 We use cookies solely to gather information on IP addresses such as geographic location, to
analyse trends, administer the Sites, track users’ movements on the Sites and gather broad
demographic information for aggregate use as set out in paragraph 8.1. IP addresses are not
linked to other personally identifiable information and will not be used to deliver targeted
marketing messages.
• 8.4 For information about blocking the use of cookies, please refer to the instructions/help screen
on your internet browser. You may not be able to use or access certain parts of the Sites or
online services however if you block the use of cookies.
• 8.5 We advise you of our use of cookies when you first access our Sites via an automated ‘popup’,
which explains the cookies we use and what we use them for. If you continue to use our
Sites you implicitly accept our use of cookies. If you set your web browser to decline the use of
cookies, you may experience limited functionality in the use of our Sites.

9 Links to other sites
• 9.1 In governing the use of your data in web browsing activity, this Privacy Policy relates
specifically to the use of the Sites only and does not extend to your use of, provision of data to
and collection of data on any site not connected to us to which you may access by following a
hyperlink within the Sites or contained within any e-mail sent from or on behalf of the Persimmon
Group.
• 9.2 If you follow a link to any other websites, they should have available their own privacy and/or
cookie policies We do not accept any responsibility or liability for their operation or misuse of
your personal data. You should review these policies before submitting any Personal Data to
those websites.

10 How long we will keep your Personal Data
• 10.1 We will retain your Personal Data for up to six years from the end of our relationship with
you (unless required by law to retain it longer)).

11 Transfer of your Personal Data
• 11.1 The Personal Data that we collect from you will not ordinarily be transferred to, or stored at,
a destination outside the European Economic Area (EEA).
• 11.2 However, if we do need to transfer your Personal Data outside the EEA we will take all
steps reasonably necessary to ensure that any such transfer is made securely and that there is
adequate protection in place in order to protect your Personal Data, as required by the Act and
Chapter V of the GDPR, including requiring the transferee to enter into model contractual
clauses or (if US based) being a member of the Privacy Shield.
• 11.3 Please contact us if you wish to find out more; if we ever transfer your Personal Data
outside the EEA you can ask us for a copy of relevant safeguards.

12 Security
• 12.1 The information you supply to us will be held on our servers located in datacentres hosted
by one or more approved providers. The internet is not a secure medium, however we take all
reasonable care to prevent any unauthorised access to your Personal Data.
• 12.2 We take reasonable technical and organisational measures to protect Personal Data in our
possession from loss, misuse and unauthorised access, disclosure, alteration and destruction.
• 12.3 Personal Data stored electronically is secured by us in the following ways:
• 12.3.1 Stored in a restricted access format;
• 12.3.2 Secured within networks that have certified firewalls in a multi-layered manner and which
are penetration-tested at least annually;
• 12.3.3 Personal Data can only be accessed by staff on an as-needed basis, and;
• 12.3.4 All network and computer equipment is secured with passwords and servers are only
physically and logically accessible by authorised personnel, systems and software.
• 12.4 We will require third parties acting on our behalf who collect or use your Personal Data
under our instructions to agree to safeguard your Personal Data in accordance with this Privacy
Policy and comply with data protection laws.

13 Marketing & opting out
• 13.1 Unless you have opted out, we may contact you via email, SMS/text message or other
electronic mail to inform you about other products or services provided by us that are similar to
those that you have already agreed to, requested or enquired about.
• 13.2 You have the right at any time to ask us not to use your Personal Data for marketing
purposes by notifying us using the contact details set out in the ‘Contact and Complaints’ section
below.

14 Your rights
• 14.1 Your personal information is protected under data protection laws and you have a number
of rights (see below) which you can seek to exercise. Please contact us in writing, by email or
telephone using the details shown under ‘Contact and Complaints’ below if you wish to do so, or
if you have any queries in relation to your rights. Please note these rights do not apply in all
circumstances. We may need to verify your identity before we can respond to any request to
exercise your rights.
• 14.2 Right of access – subject to certain exceptions, you have the right of access to your
Personal Data that we hold.
• 14.3 Right to rectify your personal information – If you discover that the information we hold
about you is inaccurate or incomplete, you have the right to have this information rectified (i.e.
corrected).
• 14.4 Right to be forgotten – You may ask us to delete information we hold about you in certain
circumstances. This right is not absolute and it may not be possible for us to delete the
information we hold about you, for example, if we have an on-going contractual relationship or
are required to retain information to comply with our legal obligations.
• 14.5 Right to restriction of processing – In some cases you may have the right to have the
processing of your personal information restricted. For example, where you contest the accuracy
of your personal information, its use may be restricted until the accuracy is verified.
• 14.6 Right to object to processing – You may object to the processing of your personal
information when it is based upon our legitimate interests. You may also object to the processing
of your personal information for the purposes of direct marketing and for the purposes of
statistical analysis.
• 14.7 Right to data portability – You have the right to receive, move, copy or transfer your
personal information to another controller when we are processing your personal information
based on consent or on a contract and the processing is carried out by automated means.

15 Changes
• 15.1 We may edit or amend this Privacy Policy from time to time. If we make any substantial
changes to the Privacy Policy, we will notify you by presenting on the home page of the Sites a
notice to this effect. Please check our Sites frequently to see any updates or changes to this
Policy.
• 15.2 As a result of improvements we make to our services, amendments to laws or regulation or
developments in the technology or processes we use, we may change the way in which or the
purposes for which we process such information. If we make any substantial changes in the way
in which we use your Personal Data we will notify you by email or by post.

16 Contacts & complaints
• 16.1 If you have any questions about how we treat and protect your Personal Data and your
privacy, if you have any comments, wish to seek to exercise any of your rights as outlined above
or to complain, please contact customercare@oakngate.co.uk.
• 16.2 You may also lodge a complaint with the Information Commissioner’s Office, Water Lane,
Wilmslow, SK9 5AF telephone 0303 123 1113. www.ico.org.uk/