Rebloom respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Rebloom Ltd is a block management agent acting on behalf of Landlords (aka Freeholders) or Residential and Right to Manage Companies usually defined within the lease relating to the property or building under management. For the purpose of this notification, these entities are referred to as the Client.
Rebloom Ltd is registered with the Information Commissioner's Office (reference number: ZA137423).
Purpose of this privacy notice
This privacy notice aims to give you information on how Rebloom collects and processes your personal data, including any data you may provide through this website or more generally in your dealings with us.
As the agent for the Client, Rebloom has authority to act on the Client’s behalf and in doing so it determines the purposes and means of processing Data Subjects’ personal data. Therefore, for the purposes of data protection legislation, Rebloom is a joint-controller with its Client and the Data Processor.
Typically, Rebloom will process the personal data of the parties to the Contract (as defined above). This will usually be:
but this may extend on occasion to third parties such as (but not limited to) the following:
those with power of attorney for leaseholders
signatories of documents (e.g. neighbours who may be referred to in a Party Wall Award or witnesses of signatures)
officials who administer death and marriage certificates
Solicitors and barristers involved in any disputes
Debt collection agents approved by the Client to collect overdue service charges or other service related debt
those who sign cheques (leaseholders and those who pay on behalf of leaseholders)
property vendors and their representatives
property purchasers and their representatives
those who may give witness evidence in relation to disputes
To support vulnerable residents we may retain information regarding age; disabilities or special needs where provided by the individual or authorised carer.
Transaction data is also held which includes;
Financial Data including account balances, sums, due, owed or outstanding pursuant to the Contract (note, we do not collect bank account and payment card details).
Maintenance and value of a property, records of correspondence sent or received by us, local land-charge and planning information, information regarding any deed, sub-tenancy or contract related to the property and records of any breaches of obligations therein, historic property and account information, documents and contact details relating to personal representatives or agents, Court or Tribunal decisions relating to a property or its owner, reports of nuisance or anti-social behaviour and any other information voluntarily given to us.
Who to contact if you have a Data Protection question
Our data privacy management team is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy management team using the details set out below.
FAO: Data Privacy Manager
Courthill House, 60 Water Lane, Wilmslow, Cheshire SK9 5AJ.
Email address: email@example.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes personal data you provide when you:
make applications to us (eg: in connection with service charge demands)
provide notice in accordance with the terms of the Lease
buy or sell your property
correspond with us about the management of your property or matters in connection with your property
make payments to us in accordance with the Lease
give us feedback
Third parties or publicly available sources. We may receive or obtain personal data about you from various third parties and public sources as set out below:
Your solicitor or other representative (including agent, person with power of attorney, or other person to whom you have provided authority)
The vendor of your property (if you have bought a property or interest in land)
Your current or former landlord (if that person is potentially selling or has sold its interest to the Client)
Property managers or other professionals who may provide us with information about a property you may own
Your neighbours, who may provide us with information about a situation which may involve you or your property
Identity and Contact Data from publicly available sources such as Companies House, the Land Registry, Local Authority records and the Electoral Register based inside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to manage or perform functions under the Contract (as defined above) or we are about to enter into a contract or have entered into one 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.
Generally, we do not rely on consent as a legal basis for processing your personal data, but we may seek your consent in certain situations, if this is necessary. You have the right to withdraw consent to any marketing at any time by updating your personal details on our website or contacting us at firstname.lastname@example.org or writing to the Data Management Team (details above).
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you electronically or by contacting us at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below:
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
To the best of our knowledge, we do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as 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 potential 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.
Details of retention periods for different aspects of your personal data are available on request by contacting us at email@example.com.
In some circumstances you can ask us to delete your data: see Request erasure in paragraph 9 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.