Privacy Policy & Notice

This is the privacy notice of TwoCan. In this document, "we" or "us" refers to TwoCan.

Our registered office is at Rivers Meet, Cleeve Mill Lane, Newent, Gloucestershire GL18 1DS

This is a notice to tell you our policy about all information that we record about you. It covers both information that could identify you and information that could not.

We are extremely concerned to protect your privacy and confidentiality. We understand that all users of our web site are quite rightly concerned to know that their data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. Our policy is both specific and strict. It complies with UK law. If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.

We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our web site immediately.

Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected at this site.

Here is a list of the information we collect from you, either through our web site or because you give it to us in some other way, and why it is necessary to collect it:

1. Basic identification and contact information

This information is used:

  • 1.1. to provide you with the services which you request;
  • 1.2. for verifying your identity for security purposes;
  • 1.3. for marketing our services and products;
  • 1.4. Information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.

2. Market place information

When we obtain information from you specifically to enable you to use or buy a service offered on our web site by some other person, we assume that in giving us your information, you are also giving us permission to pass it to the relevant person.

3. Your domain name and e-mail address

Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded

We shall not under any circumstances divulge your e-mail address to any person who is not an employee or contractor of ours and who does not need to know, either generally or specifically.

This information is used:

  • 3.1. to correspond with you or deal with you as you expect.
  • 3.2. in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our site;
  • 3.3. to send you news about the services to which you have signed up;
  • 3.4. to tell you about other of our services or services of sister web sites.

4. Information you post on our website

Information you send to us by posting to a forum or blog is stored on our servers. We do not specifically use of that information except to allow it to be read, but you will see in our terms and conditions that we reserve a right to use it in any way we decide.

5. Website usage information

We may use software embedded in our website (such as JavaScript) to collect information about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page, and how we perform in providing content to you.

6. Financial information relating only to your credit cards

This information is never taken by us either through our website or otherwise. At the point of payment, you are transferred to a secure page on the website of a secure reputable payment service provider. That page may be dressed in our livery, but it is not controlled by us. Our staff and contractors never have access to it.

7. Note on padlock symbols and other trust marks

Many companies offer certification and an icon or other small graphic to prove to site visitors that the site is safe. Some certify to a high level of safety. We do not handle information about your credit card so do not subscribe to any such service.

8. Financial information about your direct debit or your credit cards

If you agree to set up a direct debit arrangement, the information you have given to us is passed to our own bank for processing according to our instructions. We do keep a copy.

9. Credit reference

To assist in combatting fraud, we share information with credit reference agencies so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

10. Business and personal information

This includes all information given to us in the course of your business and ours, such as information you give us in your capacity as our client. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect you to reciprocate this policy.

We keep information which forms part of our business record for a minimum of seven years. This is in line with the relevant legislation.

11. Third party advertising

Third parties may at times advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or Javascript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

12. Cookies

Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we may use cookies:

  • 12.1. to record whether you have accepted the use of cookies on our web site. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you.
  • 12.2. to allow essential parts of our web site to operate for you.
  • 12.3. to operate our content management system.
  • 12.4. to operate the online notification form - the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.
  • 12.5. to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
  • 12.6. to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
  • 12.7. to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.
  • 12.8. to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.
  • 12.9. to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.
  • 12.10. to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube's privacy-enhanced mode.

13. Calling our office

When you call our office, we may collect Calling Line Identification (CLI) information. We use this information to help improve the efficiency and effectiveness of our help line.

14. Sending a message to our support system

When you send a message, we collect the data you have given to us in that message in order to obtain confirmation that you are entitled to receive the information and to provide to you the information you need. We record your request and our reply in order to increase the efficiency of our business / organisation. We may keep personally identifiable information associated with your message, such as your name or email address.

15. Complaining

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

16. Third party content

Our web site is a publishing medium in that anyone may register and then publish information about himself or some other person. We do not moderate or control what is posted. If you complain about any of the content on our web site, we shall investigate your complaint. If we feel it may be justified, we shall remove it while we investigate. Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content which offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

17. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

18. Content you provide to us

If you provide information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the World, you have no control whatsoever as to how it is used.

19. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.

20. Affiliate information

This is information given to us by you in your capacity as an affiliate of us or a customer or client of ours. Such information is retained for business use only. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect any affiliate to agree to reciprocate this policy. As an exception to this, we have the right to disclose your first name and URL of your affiliate connection to other affiliates and to any other person or organisation, on and off site. The reason is solely to enable us to mention winners and others whose performance as an affiliate is in some way outstanding.

21. Disclosure to Government and their agencies

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

22. Review or update personally identifiable information

At any time you may review or update the personally identifiable information that we hold about you by contacting us at the address below. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

TwoCan
Rivers Meet, Cleeve Mill Lane, Newent, Gloucestershire GL18 1DS

23. Sale of your personal information

Except as specified above, we do not rent, sell or otherwise disclose any of your information to any person outside our business.

24. Data may be "processed" outside the UK

Our web sites are hosted in the EU. We also use outsourced services in countries outside the EU from time to time in other aspects of our business. Accordingly data obtained within the UK may be "processed" outside the UK and data obtained in any other country may be processed within or outside that country.

25. Compliance with the law

This confidentiality policy has been compiled so as to comply with the law of every jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your country, we should like to hear from you, but ultimately it is your choice as to whether you wish to use our website.

26. Removal of your information

If you wish us to remove personally identifiable information from our site, you may contact us. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information. If you have any question regarding this privacy policy and notice, please contact us on info@twocan.estate.



GDPR Related Privacy Statement

1. Summary

This Privacy Notice is a public document available to anyone and applies to customers of TwoCan Estate Agents to explain how the organisation collects and processes personal information in order to conduct normal business activities.

TwoCan Estate Agents was set up by Two Rivers Housing. Offices are run by individual Housing Associations on a franchise basis. We offer a sale and lettings service, including full property management. We may also offer associated services such as EPC’s, property maintenance and grounds keeping.

2. Who we are

TwoCan is the Data Controller whose head office is located at Rivers Meet, Cleeve Mill Lane, Newent, Gloucestershire GL18 1DS. The Data Protection Officer can be contacted at DPO@2rh.org.uk.

3. How we collect your information

TwoCan collects information from you via a variety of sources, including when you call, write, email or meet us. We may collect information when you use our social media sites or website.

Our landline phone calls maybe recorded for training and monitoring purposes and our recordings are usually held for a period of six months

We may operate a CCTV system at our offices for the detection and prevention of crime.

We may also take photographs at events, at our properties and in our communities to use for general marketing and publicity. Photographs of individuals, however, will only be used with consent.

We may also receive information about you from third parties including:

  • Prior Landlords and credit agencies
  • Financial institutions when you apply for our services
  • Other estate agents if they are involved in a transaction

4. What information we collect about you

The information we may require from you includes:

  • Full name
  • Contact details (phone, email, correspondence address)
  • Details of anyone authorised to act on your behalf if applicable
  • Banking details
  • Other personal information
  • Financial information
  • Photo ID, bank statements, payslips or income details

If you do not provide the information we need then we may not be able to provide all our services to you and ultimately you may not be able to buy, rent, sell or let through us.

5. What processing we do with the information collected

The information we require from you is used to manage the process. Please read any contract carefully for specific details as ‘performance of a contract’ is usually the legal basis for processing your information and carrying out our activities.

The processing activities we conduct can be summarised as:

  • Managing the account charges and payments for Landlords and Tenants
  • Complying with relevant legislation and regulation
  • Monitoring and liaising with third parties such as mortgage companies, legal representatives and other estate agents

TwoCan conducts research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised.

TwoCan may conduct surveys periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

TwoCan operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practise cyber security standards.

We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

6. Additional services

TwoCan may offer additional services. For these services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up/ consent form for that service.

7. Children’s information

TwoCan does not usually process children’s information as part of a tenancy or sale.

8. Property Information

Much of the data we use relates to the properties and their location and condition. We do not consider property information to be your personal information.

As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property visit, then this is treated as personal information.

9. How we will communicate with you

TwoCan needs to communicate with its customers and this will usually be in writing, by email or by telephone.

TwoCan will operate an opt-in mechanism for receiving direct marketing.

10. Who we share data with and how long we keep information

TwoCan shares limited personal data with companies associated with our sales and lettings transactions. This may include surveyors, mortgage advisors and other contractors who need to arrange to visit a property, or are involved in the process.

TwoCan may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally obliged to do so.

11. What we will not do

We will not send you unsolicited marketing material.

We will not sell your personal data on to third parties.

We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that.

We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK/European regulations.

12. Your rights, the right to complain and the ICO

You have the right to request a copy of the data we hold about you. Please contact your local TwoCan office if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service. We will not charge for this and will respond within one month of receiving your request.

You have the right to correct information that we hold if it is inaccurate. Please advise your local office of any corrections.

You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to do so.

You have the right to complain about any matter relating to our service, including how we use your personal data. In the first instance contact your local office. If you are still not happy, you may complain to the Property Ombudsman ( www.tpos.co.uk).

If you wish to complain about the use of your personal data you may complain to the UK’s Information Commissioner’s Office (ICO) at www.ico.org.uk.

13. Further information

Our privacy policy is regularly kept up-to-date and was last updated on the 4th May 2018.