Website Privacy and Cookie Policy

Fairfield Real Estate Finance Services Limited 
 

Who we are

This website privacy and cookie policy is issued by Fairfield Real Estate Finance Services Limited, a limited company registered in England and Wales with company number 10231795 ("Fairfield"). This privacy policy explains how we may use, process and store your personal data through use of this website. Fairfield is the controller and responsible for your personal data. In this policy, reference to "we", "us" or "our" are references to Fairfield.
 

The Types of Personal Data We Collect

1. Personal data means any information relating to an identified or identifiable natural person. Many of the services offered by Fairfield require us to obtain personal data about you in order to perform the services.
    
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
    
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website;
      
   • Usage Data includes information about how you interact with and use our website, products and services; and
      
3. We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 
    

How does Fairfield collect personal data?

We use different methods to collect data from and about you including through:

1. Automated technologies or interactions: As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see Cookies section for further details. 
    

How does Fairfield use personal data?

Legal Basis:

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
    
2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure services. This includes the legitimate interests of third parties. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
    
3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
    
4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
    
5. Purposes for which we use your personal data
    

The table below explains what we use your personal information for and why.

Disclosure of your personal data?

1. Fairfield may share personal data with our group companies insofar as reasonably necessary for the purposes of our service offering or for bona fide compliance purposes as well as on the legal basis as set out in this policy. 
    
2. Except as described in this paragraph, Fairfield will not disclose, transfer or sell your personal data to any third party unless you have consented to this.
    
3. Fairfield may share personal data to subcontractors for the purpose of the proper performance of the services we provide to our clients. It may, for example, disclose or transfer such personal data to third party service providers who provide administrative, due diligence, IT, payment, debt collecting or other services.
    
4. In addition, Fairfield may share personal data to protect our rights or those of our clients and/or to prevent fraud. Fairfield can also be obliged to disclose or transfer personal data to competent authorities in order to comply with our legal and/or regulatory obligations.
    
5. 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. 
    

International transfers

We do not transfer your personal data outside the UK. 
 

Retention

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.
    
2. In some circumstances you can ask us to delete your data: see 'Erasure’ of your personal information (the right to be forgotten)' below. 
    

Your rights

You have a number of rights under data protection laws in relation to your personal data. These include:

1. Right to object: You have the right to object to personal data being processed by us where we are processing your information for direct marketing purposes, or where we are relying on a legitimate interest (or the legitimate interests of a third party) to process your personal data.
    
2. Access to your personal data: You can request access (commonly known as a 'data subject access request') to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity.
    
3. Consent: We won't need your consent to use your personal data as we will be using it only to fulfil our obligations and exercise our rights as an employer. There are limited circumstances where we may ask for your consent to process your information. Where you have given us your consent to use personal data, you can withdraw your consent at any time.
    
4. Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
    
5. Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Where we are required by law to keep certain information, we will be unable to delete such information.
    
6. Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred to you or a third party.
    
7. Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
    
8. No automated decision-making: Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless: (a) you have given us your consent; (b) it is necessary for a contract between you and us; (c) we have notified you of the decision and given you not less than one calendar month to request a reconsideration; or (d) it is otherwise permitted by law.
    

You also have certain rights to challenge decisions made about you. We do not currently envisage that any decisions will be taken about you using automated decision-making in the course of you working with us, but we will notify you in advance if this changes.

If you wish to exercise any of the above rights, you can contact Fairfield using the contact details below. 
 

Cookies

1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
    
2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
    
3. We use the following cookies:
    
   • Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won't work properly without them. They include, for example, cookies that track errors on our website and keep our website secure You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
      
   • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may share your data with third-party analytics providers like Google Analytics for this purpose.
      
   • Functionality cookies. These are used to recognise you when you return to our website. These cookies remember your preferences and tailor the website to provide enhanced features. Without these cookies, we cannot remember your choices or personalise your online experience.
      
   • Cookies used include _ga (Google Analytics) for tracking user sessions. The retention of this data is for 26 months. You can manage cookie preferences at https://www.fairfieldref.com/#editCookieSettings. 
      

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout 
 

How we protect personal data?

1. Fairfield is committed to ensuring the security of your personal data. Fairfield has put in place appropriate technical, physical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
    
2. Employees of Fairfield are trained to handle personal data securely and with utmost respect and they will treat your personal data strictly confidential. Staff members shall only access personal data to the extent necessary to serve the applicable legitimate purposes for which the data is processed by Fairfield and to perform their job. Fairfield will not divulge client information to a third party, other than in the way described above, unless we have received explicit client authorisation or we are required to do so by law.
    
3. 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. 
    

Changes to this policy

We reserve the right to change this policy at any time. 
 

Contacting us

If you have any questions, concerns or complaints with respect to this privacy policy, the way Fairfield is handling your privacy, or you wish to exercise any of your rights please contact: Sue Hoole at info@fairfieldref.com. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance and we will investigate the matter.