Privacy Policy

We are the  MSA Property Services (MSA) is a trading style of Mottcombe Lowndes Limited, details of which can be found on Companies House.

This privacy notice is issued on behalf of Mottcombe Lowndes Limited so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in Mottcombe Lowndes Limited responsible for processing your personal data.

Mottcombe Lowndes Limited, a company incorporated and registered in England and Wales with company number 06467245, whose registered office is at the Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PG.

ICO Reference number: Z1417385

Websites

The following websites are in scope of this privacy notice:

• https://msapropertyservices.com/

Controller

Mottcombe Lowndes Limited acts as the Controller ( for all the organisations within the group that are covered by the scope of this privacy notice. This means that The Marketing Lounge Partnership (MSA) determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.

Our commitment to you

We respect your right to privacy and are committed to protecting it and complying with Data Protection Law. We will always keep your Personal Data safe. We will be clear and open with you about why we collect your Personal Data and how we use it. Where you have choices or rights, we will explain them to you and respect your wishes.

If you have questions about this Privacy Notice or the processing of your Personal Data, please contact us at:

Postal address

The Cow Shed, 
Walnut Tree Farm, 
Lower Stretton, 
Cheshire 
WA4 4PG
United Kingdom.

Email

hello@msapropertyservices.com.

Transaction data

Includes details about payments to and from you and other details of services you have purchased from us.

Payment data

Payments are made to customers as a reward incentive by BACS payment or cheques using the data subject’s information contained within other identifiers. Any supplier payments are made in the same way using information held within MSA Account Software.

Technical data

Includes IP address, your login information, time zone setting and location, browser plugin types and versions, operating system and platform, and other technology on the devices you use to access our website or our Apps

Profile data

Includes your email and password, the services you have used on our website [or our Apps], your use of social media functions on our Website [or our Apps] for [authentication, feedback, survey responses and such information as you provide to us].

Usage data

Includes information about how you use our Website ,the resources you access, pages you visit, the time and date of your visit or an email opened, the time spent on those pages, unique device identifiers, the URL (Uniform Resource Locator) clickstream to, through and from our website and other diagnostic data.

Further information will be required for successful candidates, such as, National Insurance Number, reference details, passport or driver’s license  for DBS checks and rights to work within the UK.

Marketing and communications data

Includes your preferences in receiving marketing from us and our third parties and your communication preferences and records of our correspondence  with you.

We may use technologies, such as tracking pixels (also called 1×1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing, leading to more relevant emails to our subscribers. It also helps us to identify subscribers that are not engaged with our marketing emails, enabling us to remove them from our send lists. For more information about the tracking pixels please see our

Chat sessions

This information includes online chat sessions and the chat history of previous sessions. For customer queries via chat sessions and verbal communications will need to undergo a two-step verification

Special Category Personal Data

No special category data is collected by MSA under this privacy notice.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature.

However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Notice.

We may use different methods to collect data from and about you through our websites, website live chat, by telephone, and through any , including LinkedIn, Facebook and Twitter.

Personal Data provided directly by you

You may give us your Personal Data by filling in forms, surveys, questionnaires or assessments on our Website, by applying to work for or with us or by corresponding with us by post, phone, email, chat or otherwise. This includes Personal Data you provide when you:

• Register to use our Apps, Website or services, or to receive general, marketing or commercial information;
• Submitting contact / enquiry forms

Data we collect when you use our Websites and Apps 

Each time you interact with our Website, we will automatically collect Personal Data, including technical data about your device, your browsing actions and patterns, content and usage data. We collect this data using Cookies, server logs and other similar technologies like pixels, tags and other identifiers in order to remember your preferences, to understand how our Website and Apps are used, and to customise our marketing offerings and to continually improve customer journeys.

Please see our Cookie Notice for further details.

Information we receive from third parties

We may receive Personal Data about you from various third parties, such as:

1. Device data from the following parties:
2. • Analytics providers such as Google.
   • https://fingerprintjs.com/ and https://www.transunion.com/
3. Contact, financial and transaction data from providers of technical, payment and delivery services.
4. Technical data and device data from the following parties:
   • Analytics providers such as Google Analytics
   • Advertising networks such as Google, Facebook and Instagram.
5. Information about our candidates from referees, recruitment agencies and social media such as LinkedIn;

Information we receive from public sources

Identity and contact data from publicly available sources such as the UK Companies House and the electoral register inside the UK .Publicly available data sources are used for Postcode and address or vehicle registration lookups.

Unique application numbers

When you want to install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example the type of operating system, may be sent to us.

General

We need your Personal Data to conduct our business and provide you with our services. Most commonly we will use your Personal Data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

UK GDPR/EU GDPR Lawful Basis table

The table below describes the ways we plan to use your Personal Data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

For more information on the Lawful Basis we use to process your data under the UK GDPR and EU GDPR, see our Lawful Basis table  below or contact us.

Reason for processing Special Category Personal Data:

Where we are processing your Special Category Personal Data, we must, in addition to the Lawful Basis in the Lawful Basis table, process your Special Category Personal Data because of an additional condition, including:

• You have given us your explicit consent to process that data;
• We are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
• The processing is necessary to carry out our obligations under employment, social security, or social protection law;
• The processing is necessary for the establishment, exercise, or defence of legal claims;
• You have made the data manifestly public; or
• Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes.

Commonly we will process that data:

• On your express consent; or
• On the basis of scientific research in the public interest.

For more information about us using your Special Category Personal Data, please see the Special Category Personal Data table below or contact us. The ICO has some useful information here.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the Lawful Basis that allows us to do so.

Using Personal Data for marketing purposes

We may use your information to provide you with details about services.

Where we are legally required to obtain your consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

You can opt out of us using your personal information for marketing purposes by following the included in each marketing email or by contacting MSA via our ‘contact us’ forms.

Sharing your Personal Data safely

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. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We ensure that the personal  data being supplied is also limited with the minimum being used for each of the services provided by the third-party service providers.

We may share your personal information with the following organisations that help us manage our business and deliver our products, applications, or services, or where we are legally obliged to share information, including with:

Text local

• https://www.textlocal.com/

Used to send SMS messages. Sending the 3^rd party first name, last name, phone number.

More information can be found here https://www.textlocal.com/legal/privacy/

Mail Services and Couriers

• https://www.royalmail.com/

Used to fulfil incentives to customers. . Sending the 3^rd party a first name, last name and full mailing address.
More information can be found here https://www.royalmail.com/privacy-notice

DPD

• https://www.dpd.co.uk/

Used to fulfil incentives to customers. . Sending the 3^rd party a first name, last name and full mailing address.
More information can be found here https://www.dpd.co.uk/privacy_policy.jsp

Parcel Force

• https://www.parcelforce.com

Used to fulfil incentives to customers. . Sending the 3^rd party a first name, last name and full mailing address.
More information can be found here https://www.parcelforce.com/privacy

Google

• https://www.google.com

Google Analytics  is a third-party service provider to assist us with client insight analytics

Used to tracking page views. Sending the 3rd party Page Information (URL, Title), Browser Information (Browser name, Viewport or Viewing pane, Screen resolution, Java enabled, Flash version), User Information (Location – IP address, Language).
More information can be found here https://policies.google.com/privacy?hl=en-US

• Third parties to which we outsource certain services such as couriers, IT systems or software providers, IT support service providers, and document and data storage providers;
• Third-party platforms to manage and deliver customer relationship management (CRM);
• Third parties for the purposes of App development;
• Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets (including without limitation in connection with any bankruptcy or similar proceedings);
• Other organisations for the purposes of fraud/crime protection and investigation;
• Courts of law and government, regulatory authorities or third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement.
• We use IT systems or software providers, IT support service providers, document and data storage providers.
• We use third-party platforms to manage and deliver customer relationship management (CRM).
• Third parties for the purposes of App

Business Services

Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets (including without limitation in connection with any bankruptcy or similar proceedings);

Law and Investigations

• Other organisations for the purposes of fraud/crime protection and investigation;

• Courts of law and government, regulatory authorities or third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement.

Why we share your Personal Data

As a general principle, we share data in order to facilitate or improve our services or offers. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

You can opt out of us using your personal information for marketing purposes by following the unsubscribe link included in each marketing email or by contacting us via our contact us form.

From time to time, we may share Personal Data and other information that we have collected about you:

• To get help in running our business, and delivering our products, Apps and services;
• Where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect or exercise our legal rights or to defend against legal claims or demands;
• Where we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Notice or inform you that you are covered by a new privacy notice);
• If we believe it is necessary in order to investigate, prevent or act regarding illegal activities, fraud, or situations involving potential threats to the rights, property or personal safety of any person, or other exigent circumstances; or
• If we believe it is necessary to investigate, prevent or act regarding situations that involve abuse of our infrastructure or the Internet in general (such as voluminous spamming, denial-of-service attacks, or attempts to compromise the security of the Website infrastructure), or to otherwise protect our assets or rights.

 Sharing your Personal Data overseas

Please note that we may send personal information outside of the country generally for, but not limited to, reasons relating to processing and storage by our service providers. For example, we may have

When we do this, we will ensure it has an appropriate level of protection and the transfer is made in line with Data Protection Law. Often, this protection is set out under a contract with the organisation that receives that information. You can find more details of the protection given to your information when it is transferred overseas by contacting us.

Risk

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many Information Security Risks that exist and take appropriate steps to safeguard your own information.

Breaches

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You should be aware that information about your use of the website (including your IP address) may be retained by your ISP (Internet Service Provider)  , the hosting provider and any third party that has access to your Internet traffic.

Our Website and Apps may contain links to third-party websites and plugins, for instance a social media login plugin. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties.

We are not responsible for the content or practices of those websites, plugins, or services. The collection use and disclosure of your Personal Data will be subject to the privacy notices of these third parties and not this Privacy Notice. We urge you to read the privacy and cookie notices of the relevant third parties.

We do not target children, and our Website, Services and Apps are not intended to attract children. Accordingly, our online services that collect Personal Data are not directed at and and we request that such individuals do not provide any Personal Data to us, including via Cookies, please see our for further information.

Minors must obtain express consent from parents or legal guardians before accessing or providing any Personal Data. If notified by a parent or guardian, or discovered by other means, that a minor under the age of 18 has provided their Personal Data to us, we will delete the minor’s Data that is in our possession.

We will keep your Personal Data in line with our data retention policy for no longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We use Cookies and similar technologies like pixels, tags, and other identifiers to remember your preferences, to understand how our Website and our Apps are used, and to customise our marketing offerings.

Further details can be found in our Cookie Notice.

You have several rights under Data Protection Law. The rights available to you depend on our reason for processing your information and are set out in the Table of your rights of Rights. Information on your rights under Data Protection Law can also be found at https://ico.org.uk/for-the-public/.

How to exercise your rights 

In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.

To exercise your rights or get more information about exercising them, please contact us, giving us enough information to identify you.

We hope that we can resolve any query or concern you raise about our use of your information. Please first and title your email “Complaint”. All complaints will be treated in a confidential manner and we will try our best to deal with your concerns. The Marketing Lounge Partnership is committed to manage complaints promptly, effectively and fairly.

You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred.

The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.