1. Welcome

This Privacy Notice applies to anyone who interacts with Hoult Homes, including property sellers, buyers, prospective clients, website visitors and anyone who contacts us in connection with our services.

At Hoult Homes, we are committed to protecting your privacy and handling your personal information with care, transparency and respect.

Whether you are selling, buying or enquiring about a property, we understand the importance of keeping your personal information secure. This Privacy Notice explains what personal information we collect, how we use it, who we may share it with and the rights you have in relation to your information.

We will only collect and use your personal information where we have a lawful reason to do so. We are committed to complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection legislation.

We encourage you to read this Privacy Notice carefully. If you have any questions about how we use your personal information, please contact us using the details provided at the end of this document.

2. Who We Are

Hoult Homes Limited is an independent estate agency specialising in the marketing and sale of residential property.

For the purposes of UK data protection law, Hoult Homes Limited is the Data Controller. This means we are responsible for deciding how and why your personal information is collected and processed.

Our details are:

Hoult Homes Ltd
Company Number: 17125284
ICO Registration Number: ZC155292
Registered Office: Hoult Homes Ltd,
Casterton Suite,
Clawthorpe Hall Business Centre,
Burton-In-Kendal,
Carnforth,
Lancashire,
LA6 1NU
Telephone: 01524 928250
Email: hello@houlthomes.co.uk
Website: www.houlthomes.co.uk

If you have any questions about this Privacy Notice or wish to exercise any of your data protection rights, please contact us using the details above.

3. The Information We Collect

The personal information we collect depends on how you interact with us and the services we provide. We only collect information that is relevant, necessary and proportionate for the purposes of providing our services and meeting our legal obligations.

Depending on your relationship with Hoult Homes, we may collect the following categories of personal information:

Personal and Contact Information

This may include:

• Full name
• Postal address
• Email address
• Telephone number
• Date of birth (where required)
• Preferred method of communication

Property Information

Where you instruct us to market or enquire about a property, we may collect information including:

• Property address
• Details about the property
• Property ownership information
• Viewing availability and access arrangements
• Property preferences and search criteria

Identity Verification Information

Where required by law, we may collect information to verify your identity and comply with anti-money laundering legislation. This may include:

• Photographic identification
• Proof of address
• Date of birth
• Nationality
• Information required to verify the source of funds or source of wealth where legally necessary

Financial Information

Where relevant to our services, we may collect information including:

• Bank account details (for example, where payments or refunds are required)
• Financial circumstances where relevant to a property transaction
• Mortgage status or purchasing position
• Proof of funds where appropriate

Communications

We may keep records of our communications with you, including:

• Emails
• Letters
• Telephone conversations
• Meeting notes
• Enquiry forms
• Website enquiries
• Feedback provided by you

Technical Information

When you visit our website, we may automatically collect certain technical information, including:

• IP address
• Browser type
• Device information
• Cookies and similar technologies
• Website usage information

Further information about cookies can be found in our Cookie Policy.

Account Information

If you choose to create a buyer or seller account through the Hoult Homes Client Portal, we may collect and process information including:

• Your name
• Your email address
• Your account username or unique user identifier (where applicable)
• Your account preferences and settings
• Records of your account activity, including login dates and times
• Information relating to your use of the Hoult Homes Client Portal, including your property preferences, saved properties, enquiries, viewing requests, documents, messages and other account activity, where applicable

You may access your account using your email address and password or, where available, through a supported third-party authentication provider.

For your security, passwords are securely hashed and stored using industry-standard security measures. Hoult Homes does not have access to your password in plain text.

Special Category Personal Data

We do not routinely collect special category personal data (such as information about your health, ethnicity, religious beliefs or biometric data).

If you voluntarily provide this type of information, or where it is necessary for us to make reasonable adjustments or comply with our legal obligations, we will process it only where UK data protection law permits us to do so and will apply appropriate safeguards.

4. How We Collect Your Information

We collect personal information in a variety of ways, depending on how you interact with Hoult Homes and the services you use. This may include information you provide directly, information generated during the course of our services, information received from trusted third parties and information collected automatically when you use our website or the Hoult Homes Client Portal.

Information you provide directly

You may provide personal information to us when you:

• Contact us by telephone, email, post or through our website.
• Request a property valuation or market appraisal.
• Instruct us to market or sell your property.
• Register as a prospective buyer.
• Arrange or attend a property viewing.
• Submit an enquiry about a property or our services.
• Create and use a Hoult Homes Client Portal account.
• Complete forms or provide documents during the course of a property transaction.

Information collected during our services

As we provide our estate agency services, we may collect and record information through our communications and interactions with you. This may include notes of conversations, viewing feedback, correspondence, appointment records, property preferences and information relating to your property transaction.

To help us deliver our services efficiently and maintain accurate records, this information may be securely stored and managed within our customer relationship management (CRM) system.

Information from third parties

Where appropriate, we may receive personal information from trusted third parties, including:

• Solicitors and licensed conveyancers.
• Mortgage advisers and lenders.
• Identity verification and anti-money laundering service providers.
• Property portals and referral partners.
• Surveyors, energy assessors and other professionals involved in a property transaction.
• Individuals acting on your behalf where you have authorised them to do so.

Information collected automatically

When you visit our website or use the Hoult Homes Client Portal, certain technical information may be collected automatically through cookies and similar technologies. This may include information about your device, browser, IP address and how you use our online services.

Further information about our use of cookies and similar technologies can be found in our Cookie Policy.

Publicly available information

In certain circumstances, we may obtain information from publicly available sources where this is necessary to provide our services or comply with our legal obligations. This may include information obtained from HM Land Registry, Companies House and other publicly available registers.

5. Why We Use Your Information

We only use your personal information where we have a legitimate reason to do so and where the law permits us. Depending on your relationship with Hoult Homes, we may use your information for the following purposes:

• To respond to your enquiries and provide information about our services.
• To carry out property valuations and market appraisals.
• To market and sell properties on behalf of our clients.
• To register prospective buyers and help match them with suitable properties.
• To arrange and manage property viewings, appointments and negotiations.
• To communicate with you throughout your property transaction.
• To create and manage your Hoult Homes Client Portal account and provide access to relevant information, documents and updates.
• To maintain accurate client records within our secure systems, including our customer relationship management (CRM) system.
• To verify your identity and carry out anti-money laundering and other legal compliance checks.
• To liaise with solicitors, mortgage advisers, surveyors, lenders and other professionals involved in your property transaction.
• To administer offers, sales progression and the completion of property transactions.
• To improve our website, online services and the Hoult Homes Client Portal.
• To send marketing communications where you have consented to receive them or where we are otherwise permitted to do so by law.
• To comply with our legal and regulatory obligations.
• To establish, exercise or defend legal claims where necessary.
• To protect the security of our business, systems, clients and website.
• To prevent fraud and other unlawful activity.

6. Our Legal Bases for Processing

Under the UK General Data Protection Regulation (UK GDPR), we must have a lawful basis for collecting and using your personal information. The legal basis we rely on will depend on the purpose for which we are processing your information. In some circumstances, more than one legal basis may apply.

Performance of a Contract

We process your personal information where it is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract. This includes providing our estate agency services, arranging property viewings, progressing property transactions, managing your Hoult Homes Client Portal account and responding to enquiries about our services.

Legal Obligation

We process personal information where we are required to do so by law. This includes complying with anti-money laundering legislation, fraud prevention requirements, tax and accounting obligations, court orders, regulatory requirements and other legal responsibilities that apply to our business.

Further information about our identity verification and anti-money laundering checks is provided in Section 7 of this Privacy Notice.

Legitimate Interests

We may process your personal information where it is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

• Providing and improving our estate agency services.
• Managing relationships with buyers, sellers and prospective clients.
• Maintaining accurate records within our secure systems.
• Communicating with clients throughout the property transaction.
• Improving our website, the Hoult Homes Client Portal and our customer experience.
• Ensuring the security of our systems, business and premises.
• Preventing fraud and other unlawful activity.
• Establishing, exercising or defending legal claims.

Before relying on this legal basis, we consider the potential impact on your privacy and ensure that our legitimate interests are balanced against your rights and freedoms.

Consent

Where required by law, we will ask for your consent before processing your personal information. This includes sending certain marketing communications and using non-essential cookies or similar technologies.

Where we rely on your consent, you have the right to withdraw it at any time. Withdrawing your consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.

To meet our legal obligations, we use Thirdfort, integrated with our customer relationship management (CRM) system, to assist with identity verification and anti-money laundering checks. This involves sharing relevant personal information with Thirdfort so that identity verification and anti-money laundering checks can be carried out. We require Thirdfort and any other third-party providers we use to handle personal information securely and in accordance with applicable data protection laws.

7. Identity Verification and Anti-Money Laundering Checks

As explained in Section 6, one of the legal bases we rely on for processing personal information is compliance with our legal obligations. This section explains how those obligations apply to identity verification and anti-money laundering (AML) checks.

As an estate agency, Hoult Homes is required to comply with UK anti-money laundering legislation and other laws designed to prevent money laundering, terrorist financing and financial crime.

Before we can provide certain services, we may be required to verify your identity and carry out anti-money laundering checks. The checks we undertake will depend on the nature of the transaction, the level of risk identified and our legal obligations at the time. We may also carry out further verification or request updated information during the course of our relationship with you where this is necessary to meet our ongoing legal and regulatory obligations.

To carry out these checks, we may ask you to provide information such as:

• your full name, date of birth and residential address;
• photographic identification, such as a valid passport or driving licence;
• proof of your current address;
• information relating to the source of funds or source of wealth, where required;
• information necessary to determine whether you are a politically exposed person (PEP) or subject to financial sanctions; and
• any other information or documentation reasonably required to comply with our legal and regulatory obligations.

To help us meet these obligations, we currently use Thirdfort, which is integrated with our customer relationship management (CRM) system. Thirdfort assists us with electronic identity verification and anti-money laundering checks. Where necessary, we will securely share relevant personal information with Thirdfort for these purposes.

These checks also help protect our clients, our business and the wider property market from fraud and financial crime.

We will only collect and process the personal information reasonably necessary to comply with our legal and regulatory obligations and will use it only for those purposes, or as otherwise permitted or required by law.

We may disclose information to law enforcement agencies, regulators or other competent authorities where we are legally required to do so, or where this is necessary to prevent, detect or investigate financial crime.

8. Sharing Your Personal Information

We treat your personal information with care and confidentiality. We will only share your personal information where it is necessary to provide our services, comply with our legal obligations, protect our legitimate interests, or where you have asked us to do so.

Depending on the services we provide to you, we may share your personal information with:

• solicitors, licensed conveyancers and other legal professionals involved in your property transaction;
• mortgage advisers, lenders and other financial service providers, where you ask us to introduce you or where this is necessary to progress a transaction;
• our identity verification and anti-money laundering provider, currently Thirdfort, to help us comply with our legal and regulatory obligations;
• our customer relationship management (CRM) provider, Alto, and its integrated electronic signature functionality, to help us securely manage enquiries, client relationships, transactions and electronically signed documents;
• our integrated proposal and presentation platform, currently Acaboom, to create and deliver property appraisal presentations, proposals and related client communications;
• property portals and advertising platforms, including Rightmove, Zoopla and OnTheMarket, where your property is being marketed;
• professional photographers, drone operators, floor plan providers, EPC assessors and other trusted contractors instructed to assist in marketing your property;
• technology providers that support our business, including website hosting, email services, cloud storage, security services and other IT providers;
• artificial intelligence service providers, including Anthropic Claude, which supports certain customer service functions, such as responding to enquiries submitted through our website chatbot;
• professional advisers, including accountants, auditors, insurers and legal advisers;
• regulators, courts, law enforcement agencies and other public authorities where we are legally required or permitted to do so; and
• any other person or organisation where you have instructed us to do so or have otherwise given your consent.

Where we use third-party service providers, we take reasonable steps to ensure they process personal information securely, only for the purposes for which it has been shared, and in accordance with applicable data protection laws.

We do not sell, rent or trade your personal information to third parties for their own marketing purposes.

9. International Transfers

Some of the organisations we work with may process or store your personal information outside the United Kingdom (UK).

Where personal information is transferred outside the UK, we will take reasonable steps to ensure that it continues to receive an appropriate level of protection. This includes relying on safeguards recognised under UK data protection law, such as:

• an adequacy decision issued by the UK Government;
• the UK's International Data Transfer Agreement (IDTA) or other approved contractual safeguards; or
• another lawful transfer mechanism permitted under applicable data protection legislation.

Where appropriate, we will also ensure that organisations handling your personal information have suitable technical and organisational security measures in place to protect it.

If you would like further information about the safeguards we use when transferring personal information internationally, please contact us using the details provided in Section 15.

10. Marketing Communications

From time to time, we may contact you with information about our services, the local property market and opportunities that we believe may be of interest to you.

We will only send direct marketing communications where we have a lawful basis to do so. Depending on the circumstances, this may be because you have given your consent or because we are permitted to do so under the 'soft opt-in' provisions of the Privacy and Electronic Communications Regulations (PECR).

Where appropriate, we may send direct marketing communications by email, SMS or other electronic means. These communications may include:

• new property alerts tailored to your search criteria, saved preferences or areas of interest;
• updates about properties you have enquired about, viewed or added to your favourites;
• local property market news, insights and guidance;
• newsletters, articles and updates from Hoult Homes;
• information about our services; and
• other communications that we believe may be relevant to your property interests.

You can withdraw your consent or change your marketing preferences at any time by:

• clicking the unsubscribe link included in our marketing emails;
• contacting us using the details provided in Section 15; or
• updating your communication preferences within the Hoult Homes Client Portal, where this functionality is available.

Choosing not to receive direct marketing communications will not affect important service communications, including updates about your property transaction, valuation, account, enquiries, viewings, appointments or information that we are legally required to provide.

We will always respect your communication preferences and will only contact you in ways that are appropriate to the services you have requested or the preferences you have chosen. We aim to ensure that any direct marketing communications we send are relevant, useful and proportionate, and we will not send unnecessary or excessive marketing.

We do not sell your personal information or permit third parties to use it for their own direct marketing purposes.

11. Keeping Your Information Secure

Protecting your personal information is a priority for Hoult Homes. We are committed to maintaining appropriate technical and organisational security measures to protect the personal information we hold against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information.

These measures include, where appropriate:

• secure, access-controlled business systems;
• encrypted connections to our website and online services;
• secure cloud-based technology and data storage;
• role-based access controls so that personal information is only accessible to those who need it to carry out their duties;
• password protection, multi-factor authentication and other appropriate authentication measures;
• regular monitoring, software updates and security maintenance of our systems;
• secure backup, disaster recovery and business continuity arrangements designed to help protect the availability and integrity of personal information;
• staff training and internal procedures designed to promote good information security practices; and
• procedures for identifying, investigating, managing and responding to suspected personal data breaches.

We also ensure that employees, contractors and trusted service providers who handle personal information on our behalf are subject to appropriate duties of confidentiality.

Where we use trusted third-party service providers, we take appropriate steps to satisfy ourselves that they maintain appropriate technical and organisational security measures and process personal information in accordance with applicable data protection laws.

While we take appropriate steps to protect your personal information, no method of transmitting information over the internet or storing information electronically is completely secure. Although no security measures can eliminate every risk, we regularly review and update our security measures to reflect changes in technology, emerging risks and the way we deliver our services, helping to protect the information entrusted to us.

If we identify a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will comply with our legal obligations, including notifying the Information Commissioner's Office (ICO) and, where required, affected individuals.

12. How Long We Keep Your Information

We will only keep your personal information for as long as it is reasonably necessary to fulfil the purposes for which it was collected. This includes providing our services, complying with legal, regulatory and accounting obligations, resolving disputes, establishing, exercising or defending legal claims, and meeting our legitimate business needs.

The length of time we retain personal information depends on the nature of our relationship with you, the services we have provided and our legal obligations. For example:

• information relating to property transactions may be retained for the periods required or permitted by applicable law, regulation, professional standards, insurance requirements or our legitimate business interests;
• identity verification and anti-money laundering records may be retained for the periods required by applicable legislation;
• correspondence, enquiries and client records may be retained where reasonably necessary to respond to queries, resolve complaints, maintain an accurate record of our dealings, or establish, exercise or defend legal claims; and
• marketing information will generally be retained until you withdraw your consent, object to receiving direct marketing, or where we determine that it is no longer appropriate or necessary to retain it.

In some circumstances, we may retain personal information for longer where we are required or permitted to do so by law, or where it is reasonably necessary in connection with actual or anticipated legal proceedings, investigations, regulatory enquiries or the protection of our legal rights.

When personal information is no longer required, we will securely delete, anonymise or destroy it in accordance with our data retention policies and applicable legal requirements.

We regularly review the personal information we hold and the retention periods that apply to it to help ensure that personal information is not kept for longer than is reasonably necessary.

13. Your Rights

Under UK data protection law, you have a number of rights in relation to your personal information. These rights are not absolute and may apply only in certain circumstances, but we will always consider any request carefully and respond in accordance with applicable law.

Depending on the circumstances, you have the right to:

• request access to the personal information we hold about you;
• request correction of inaccurate or incomplete personal information;
• request erasure of your personal information where there is no lawful reason for us to continue processing it;
• request restriction of the processing of your personal information in certain circumstances;
• object to the processing of your personal information where we are relying on our legitimate interests or where we are processing your personal information for direct marketing purposes;
• request the transfer of certain personal information to you or another organisation (known as the right to data portability), where applicable;
• withdraw your consent at any time where we rely on your consent to process your personal information. This will not affect the lawfulness of any processing carried out before your consent was withdrawn; and
• not be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects, unless permitted by law.

If you would like to exercise any of your rights, please contact us using the details provided in Section 15.

Before responding to your request, we may ask you to provide information to verify your identity. This helps us protect your personal information and prevent unauthorised disclosure.

Where someone is acting on your behalf, we may ask for evidence of their authority before responding to the request.

We will respond to your request without undue delay and, in any event, within the time limits required by applicable data protection law.

We will not normally charge a fee for responding to your request. However, we may charge a reasonable fee or refuse to act on a request where permitted by law, for example where a request is manifestly unfounded or manifestly excessive.

If you are not satisfied with the way we have handled your request, you also have the right to make a complaint to the Information Commissioner's Office (ICO). Further information about making a complaint is provided in Section 16.

14. Cookies

Our website uses cookies and similar technologies to help it function effectively, maintain the security of our website and online services, provide access to the Hoult Homes Client Portal, improve your browsing experience, remember your preferences, analyse website performance and, where appropriate, support our marketing activities.

Some cookies are strictly necessary for the operation of our website and cannot be switched off. Others, such as functionality, analytics and marketing cookies, will only be used where you have given your consent, unless their use is otherwise permitted under applicable law.

Some cookies may be placed by trusted third-party service providers acting on our behalf to help us operate, maintain, secure and improve our website and online services.

When you first visit our website, you will be presented with a cookie banner that allows you to accept, reject or manage your cookie preferences. You can withdraw or amend your consent at any time through our cookie settings.

You can also control or delete cookies through your browser settings. Please note that disabling strictly necessary cookies, or certain other cookies, may affect the functionality of parts of our website, including the Hoult Homes Client Portal.

Further information about the cookies we use, the purposes for which they are used and how you can manage your preferences is available in our Cookie Policy.

15. Contact Us

If you have any questions about this Privacy Notice, how we use your personal information, or if you would like to exercise any of your rights under UK data protection law, please contact us.

Hoult Homes
Data Protection Lead
Email: privacy@houlthomes.co.uk
Telephone: 01524 928250
Website: www.houlthomes.co.uk
Address:
Hoult Homes Ltd,
Casterton Suite,
Clawthorpe Hall Business Centre,
Burton-In-Kendal,
Carnforth,
Lancashire,
LA6 1NU

We aim to respond to privacy-related enquiries as promptly as possible and in accordance with applicable data protection law. If we can resolve your query directly, we will always do our best to help.

16. Complaints

We hope that we can resolve any questions or concerns you may have about how we collect, use or protect your personal information.

If you have a concern about the way we have handled your personal information, we encourage you to contact us first using the details provided in Section 15. We will investigate your concerns fairly and respond as promptly as possible.

If you remain dissatisfied with our response, or you believe that we have not processed your personal information in accordance with applicable data protection law, you have the right to make a complaint to the Information Commissioner's Office (ICO), the UK's independent authority responsible for upholding information rights.

You can find further information about the ICO, including how to make a complaint, on its website at www.ico.org.uk.

Making a complaint to the ICO will not affect any other legal rights or remedies that may be available to you.

17. Changes to this Privacy Notice

We keep this Privacy Notice under regular review and may update it from time to time to reflect changes in our business, the services we provide, the technology we use, our legal or regulatory obligations, or developments in data protection law.

When we make changes, we will update the "Last Updated" date shown at the beginning of this Privacy Notice. Where appropriate, and where required by law, we may also notify you of significant changes by email, through the Hoult Homes Client Portal or by other suitable means.

The most up-to-date version of this Privacy Notice will always be available on our website.

We encourage you to review this Privacy Notice periodically so that you remain informed about how we collect, use, protect and share your personal information.

We are committed to handling your personal information responsibly, being transparent about how we use it, and maintaining your trust.