Privacy and Cookie Policy

1 Introduction
1.1 We are committed to safeguarding the personal information of our service users and website visitors and ensuring our platforms are safe and enjoyable environments for our audiences.
1.2 This policy applies where we act as a data controller with respect to the personal data of our service users and website visitors; in other words, where we determine the purposes and means of processing that personal data.
1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. For further information, please see our Cookies Policy.
1.4 Our website incorporates privacy controls that affect how we process your personal data. When you share your data with us, you can specify whether you would like to receive digital marketing communications from us. If you wish to edit your details at any time, you can access the privacy controls for our digital communications via any emails from ‘Duoma’ by selecting the ‘Update Your Details’ or ‘Unsubscribe’ links at the bottom, or by emailing us at info@duoma.co.uk to update your preferences.
1.5 In addition to our digital marketing communications, we sometimes send direct marketing by post, for which the legal basis is consent or legitimate interest. If you wish to update your details, you can email us at info@duoma.co.uk.
1.6 In this policy, “we,” “us,” and “our” refer to Duoma Limited. For more information about us, see Section 12.

2. Personal Data Processing
2.1 In this Section 2, we outline:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases for processing.
2.2 We may process data about your use of our website and services (“usage data”). Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. We use Google Analytics to collect this data. Usage data may be processed for the purposes of analysing the use of the website and services. This data is only for internal use and will never be shared with third parties. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process personal data provided in the course of using our services (“service data”). Service data may include your name, email address, telephone number, property address, and further property details, including but not limited to the design and history of the property. It may also include your budget and location preferences, financial information, and further details relating to the sale or purchase of a property. Service data may be processed for operating our website, providing services, ensuring security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and in some cases, the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). Enquiry data may be processed for offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent or legitimate interest, namely the proper administration of our website and business, and in some cases, the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data”). Transaction data may include your contact details and transaction details. Transaction data may be processed for supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
2.6 We may process information that you provide to us for subscribing to our email notifications and/or newsletters (“notification data”). Notification data may be processed for sending you relevant notifications (including Property Alerts) and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us.
2.7 We may process information contained in or relating to any communication you send to us (“correspondence data”). Correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. Correspondence data may be processed for communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.8 We may process information you supply to us for publication on our website (“publication data”). Publication data – including information and images for property sales listing details, practice information, and images supplied by architects, designers, and companies to be featured on our site, and any content supplied for publication – may be processed for enabling such publication and administering our website and services. Publication data may also be shared with relevant third-party sites, including property portals (Rightmove, Zoopla, and Primelocation). The legal basis for this processing is consent or the performance of a contract between you and us.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
2.10 We may process any of your personal data identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. 
2.12 Please do not supply any other person’s personal data to us unless we prompt you to do so.

3. Providing Your Personal Data to Others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 We may disclose contact details and relevant property information to freelance viewing staff, freelance photographers, property or interior stylists, and journalists insofar as reasonably necessary for the proper administration of our website, business, and communications with users. Where this data may be published, for instance, by journalists sourcing data for publications, the legal basis for processing would be consent.
3.3 We may ask you to provide your personal data (including name, date of birth, property address, and passport or other identification document details) to third parties which carry out automated decision-making based on anti-money laundering and fraud prevention criteria, where such processing is necessary for compliance with a legal obligation to which we are subject and for the proper administration of our website, business, and communications with users.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International Transfers of Your Personal Data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the UK.
4.3 You acknowledge that personal data that you submit or approve for publication through our website or services may be available, via the internet, around the world. We will do what we can to protect this information, but we cannot prevent the use or misuse of such personal data by others.

5. Retaining and Deleting Personal Data
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) All data relating to contracted property transactions, including contact details, correspondence records, and all transaction details, will be retained for a minimum of six years where such processing is necessary for compliance with a legal obligation to which we are subject.
5.4 In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) We will hold your personal information on our systems for as long as is necessary for the relevant activity or as long as is set out in any relevant contract you hold with us.
(b) If you have not received or requested correspondence from us in the last five years, your information may be classed as dormant and may be deleted.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

6. Security of Personal Data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent its loss, misuse, or alteration.
6.2 We will store all your personal data on secure servers, personal computers, and mobile devices and in secure manual record-keeping systems.
6.3 The following personal data will be stored by us in encrypted form: your name, contact information, and passwords.
6.4 Data relating to your financial transactions that is sent from your web browser to our web server or from our web server to your web browser will be protected using encryption technology.
6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential, and we will not ask you for your password (except when you log in to our website).

7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email.

8. Your Rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organization or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8.

9. Third-Party Websites
9.1 Our website includes hyperlinks to, and details of, third-party websites.
9.2 We have no control over and are not responsible for the privacy policies and practices of third parties.

10. About Cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10.4 We use both session and persistent cookies on our website.

11. Our Details
11.1 This website is owned and operated by Duoma Limited.
11.2 We are registered in England and Wales under registration number 15513921, and our registered office is at 16a Grafton Crescent, London NW1 8SL.
11.3 You can contact us by writing to the business address given above, by using our website contact form, by email to info@duoma.co.uk.