Customer Privacy Notice

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect about you and how we comply with the law on data protection and what your rights are.

This notice applies to our customers who are looking for a new home to purchase or have reserved a new home to be purchased from us through until after completion of the purchase. This notice does not form part of any contract relating to any property you may agree to purchase.

References to we, our or us in this privacy notice are to the Bellway Group (being Bellway p.l.c. and each of its direct and indirect subsidiaries, trading under the "Bellway" brand including Bellway Homes Limited. Details of our main trading entities are as follows:

• Bellway p.l.c. is a public limited company incorporated in England and Wales. Registered Number: 1372603.
• Bellway Homes Limited is a limited company incorporated in England and Wales. Registered Number: 00670176.

Both companies have their registered office at Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF.
We have appointed a Data Protection Officer to oversee our compliance with data protection laws and they have overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.

For the purposes of this privacy notice the controller is the relevant part of the Bellway Group from which you have requested details of new build properties or have agreed to purchase or are purchasing a property and which is processing your personal information.

1. PERSONAL INFORMATION

When you interact with us, you may provide us with or we may obtain personal information about you, such as information regarding your:

• personal and work contact details and identifiers such as name, title, addresses, telephone numbers, and email addresses, emergency contact details, family members, date of birth, gender, details of availability;
• marketing preferences including preferred contact methods, property types, locations of interest, developments of interest, purchase schemes and incentives of interest;
• tax or governmental identifiers regarding any stamp duty or other relevant property taxes;
• bank accounts, credit card details, payment and receipt details, financial status, mortgage status and amounts and tax status, sale status of your current property;
• account information for any of our portals and websites including username, password and other identifying information and other account information;
• details of the property to be purchased, lease details, property options selected and payments made, and where you take part in our part exchange scheme, details relating to the property you are selling to us, payments we make to you and other associated information, relevant utilities records, decisions made by you;
• identification documents and information such as passport, utilities bills, identity cards, signature, etc;
• advisors appointed by you including mortgage brokers, lawyers, financial advisors, surveyors;
• property records, searches, documents and files (including our legal files relating to the sale to you, and where you take part in a part exchange, our legal files relating to the property you are selling to us);
• enquiries, complaints and correspondence and other communications with you;
• pictures where you feature in our marketing materials;
• details of your existing property where you participate in our Express Mover Scheme

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION AND CRIMINAL RECORDS INFORMATION

We will not generally collect, store and use any of the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your trade union memberships;
• information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also not collect, store and use any criminal records information in relation to you.

3. WHERE WE COLLECT YOUR INFORMATION

We will collect personal information from a number of sources. These include the following:

• Directly from you: from yourself, when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us, contact us by phone, email or communicate with us directly in some other way.
• Third parties authorised by you; a family member or someone else authorised by you
• Our website: provides us with information about how you use it and the devices that you use to connect to our website.
• Providers of information: which may include credit reference agencies, money laundering check provider, the Land Registry and other web platforms, product performance monitoring services, and energy solutions providers.
• Portals and other web platforms: for example Rightmove, Zoopla
• Journalists or other investigators: they may provide us with details or make enquiries about you or matters concerning you or ourselves.
• Your professional advisors: such as lawyers, accountants, planning consultants, mortgage brokers, financial advisors and surveyors.
• Our professional advisors: such as lawyers, accountants, planning consultants and surveyors.

We will also collect additional personal information throughout the period of you going through the purchase process connected to your dealings and activities connected to the purchase of the property and, if you are utilising our part exchange scheme, the sale of your property to us.

If you are providing us with details of referees, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. USES MADE OF YOUR PERSONAL INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal information used	Lawful basis
Marketing to you properties and developments of potential interest and our services, products and schemes which may be of potential interest to you	Name, personal contact details and other identifiers, marketing preferences and previous purchases	We have a legitimate interest in marketing our properties and developments to you in order to make new sales You have requested that we send to you details of certain properties and/or developments. We also may have obtained your explicit consent
Carrying out any identity and prevention of money laundering or financing terrorism checks	Name, personal contact details and other identifiers, and identification documents, prevention of money laundering or financing terrorism checks	We have a legal obligation to do so
Dealing with and managing the reservation, exchange of contracts and completion of your purchase of a property from us	All the personal information we collect	We need this information to be able to perform and administer your acquisition of the property To be able to enter into, manage and perform our contract with you regarding your property purchase and fixtures and fittings options
Dealing with and managing our part exchange with you of your property, exchange of contracts and completion of our purchase of your property	All the personal information we collect	We need this information to be able to perform and administer our acquisition of the property This is necessary to enter into and perform the contract with you regarding your sale of your property to us where you utilise our part exchange scheme
Dealing with and carrying out any fixtures and fittings options selected by you in relation to the property	Personal contact details, property details, options selected and payment and transaction information	This is necessary to enter into and perform the contract with you regarding any fixtures and fittings options selected by you in relation to your property purchase
Receiving money from you for your selected options and/or the property or payments from us under our part exchange scheme	Personal identifiers and transaction and payment information	To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, where you utilise the part exchange scheme, your property sale to us We may have a legal obligation to do so
Administering the contract we have entered into with you regarding property transactions and managing our relationship with you including your rights in relation to the property(s)	All the personal information we collect about you	To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, where you utilise the part exchange scheme, your property sale to us
Administering the Express Mover Scheme	All the personal information we collect about you	Where you have consented to us sharing your details with our nominated agent to facilitate your property purchase where you utilise our Express Mover Scheme
Managing our business and internal reporting	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and manage our business properly. To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, where you utilise the part exchange scheme, your property sale to us
Dealing with enquiries, defect rectification, complaints and other communications from you and dealing with legal disputes and warranty claims involving you	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications We have a legitimate interest to ensure that all legal claims are managed effectively To defend, bring or establish legal claims To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, where you utilise the part exchange scheme, your property sale to us
Providing to you purchaser portal and/or website access and for the purposes of ensuring the security of our systems and our information including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution	All the personal information we collect about you	We have a legitimate business in ensuring our premises and systems are secure To be able to manage and perform our contract with you regarding your property purchase and fixtures and fittings options and, where you utilise the part exchange scheme, your property sale to us
To conduct data analytics studies and customer satisfaction surveys to review, and better understand our customer purchase, retention, attrition and satisfaction levels	Our customer records and any information you provide in response to our customer satisfaction surveys. Data collected about the performance of your property and through monitoring of other products and materials.	We have a legitimate interest in order to improve as a company
For the purpose of complying with any regulatory requirements	All the personal information we collect about you	We may have a legal obligation to comply with regulatory requirements and we have a legitimate interest in complying with regulatory requirements
Storage of records relating to you and also records relating to our business	All the personal information we collect about you	To be able to manage and fulfil our contract with you, we may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you will have a legal, contractual or other requirement or obligation to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to sell to you the property you wish to purchase or we may not be able to properly perform our contract with you or comply with legal obligations. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you regarding sale of the property to you or, where you are utilising our part exchange scheme, purchase of your property by us.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to carry out certain activities.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

We share personal information with the following parties:

• Companies in the same group of companies as us: for the purpose of providing a service to you.
• Any party approved by you: for example mortgage brokers, financial advisors, legal advisors, your family, nominated agent where the Express Mover scheme is utilised by you.
• Other service providers to our business and advisors: repair and maintenance contractors, banks, professional advisors including legal advisors, product performance monitoring services, energy solutions providers, and administration and IT services. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
• Insurance providers: where relevant to the insurance of the property you purchase and/or the property we purchase from you.
• Managing agents, management company, landlords, the Land Registry: where relevant to the completion of your property transactions.
• Guarantee providers: such as the National House Builders Council or other guarantee or warranty providers in relation to your property and/or the fixtures and fittings in the property.
• Utility providers and council tax authorities: for example water, electric, gas, telephone, internet/broadband and the relevant council tax authority.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
• Government agencies and representatives: where you are taking part in any scheme run by them, for example help to buy.
• The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC, the National House Building Council or the Information Commissioner’s Office.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.

6. DIRECT MARKETING

Email, post, telephone and SMS marketing: from time to time, we may contact you by email, post, telephone or SMS with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you
represent have purchased similar services or goods from us previously.

You can unsubscribe from our marketing by clicking on the unsubscribe link in any written marketing messages we send to you or letting us know during any marketing telephone call. Alternatively you can let us know at any time that you do not wish to receive marketing messages by using the by using the details set out in the “Contacting us” section below

7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union (“EU”) except as set out in this section.

Our staff and other individuals working for us may in limited circumstances access personal information outside of the UK and EU. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information (or processors of personal information on their behalf) as mentioned in the section “Disclosure of your personal information” above may be located outside of the UK and EU. In cases where we export your personal information to a non-approved country outside of the UK and EU we will impose any legally required protections and appropriate safeguards for the personal information as required by law before it is disclosed. In cases where a third party (for example a service provider to us) exports your personal information to a non-approved country outside of the UK and the EU we will comply with our legal obligations to make sure that the third party exports the personal information in accordance with all legally required protections and that appropriate safeguards are put in place. Further details of the protections and safeguards are available from our Data Protection Officer by emailing data.protection@bellway.co.uk.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

8. HOW LONG WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of approximately 20 years until after you have completed your purchase of a property from us due to this being the limitation period for claims about latent defects. The exceptions to this general rule are:

• Legal property information and legal files will be retained for approximately 12 years after completion because this is the limitation period for claims related to property title claims;
• Information regarding fixtures and fittings will retained for approximately 6 years after completion because this is the limitation period for claims related to breach of contract
• CCTV images will generally be retained for approximately 30 days and then overwritten, unless required to be retained for any reason (please see our separate privacy notice for more details)
• Audio recordings will generally be retained for approximately 30 days and then overwritten or deleted, unless required for any reason (please see our separate privacy notice for more details)
• If for any reason your property transaction with us does not complete, then we would retain your records for approximately 6 years (instead of 20 years) because this is the limitation period for claims related to breach of contract.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You may be able to update some of the personal information we hold about you through our customer portal. Alternatively, you can contact us by using the details set out in the "Contacting us" section below.

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-pub....

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

10. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

11. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email data.protection@bellway.co.uk or write to the Data Protection Officer at Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF.

Rest of the World Privacy Notice

This notice applies to you if we process your personal information and you are not an employee or worker of ours, a prospective candidate employee or worker, a prospective customer or customer of ours or an individual to whom we have provided a specific privacy notice. You may, for example, be an individual that works at a supplier or another organisation that we deal with, an attendee at one of our events, a user of our website or someone who is affected by our activities.

References to we, our or us in this privacy notice are to the Bellway Group (being Bellway p.l.c. and each of its direct and indirect subsidiaries, trading under the “Bellway" or the “Ashberry” brands. Details of our main trading entities are as follows:

References to we, our or us in this privacy notice are to the Bellway Group (being Bellway p.l.c. and each of its direct and indirect subsidiaries, trading under the "Bellway" brand including Bellway Homes Limited. Details of our main trading entities are as follows:

• Bellway p.l.c. is a public limited company incorporated in England and Wales. Registered Number: 1372603.
• Bellway Homes Limited is a limited company incorporated in England and Wales. Registered Number: 00670176

Both companies have their registered office at Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws and they have overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection the company in our Group which is processing your personal information will be the controller of any of your personal information.

1. PERSONAL INFORMATION WE COLLECT

We may collect the following types of personal information about you:

• Contact details: information that allows us to identify and contact you directly such as your name, address email address, social media handles, telephone number and addresses.  Identification information: passport and other official identification details, information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes.
• Details of your work history: This includes may include positions, roles, responsibilities, professional qualifications.
• Personal history and information: This includes hobbies, interests, marital status, family details
• Advisors appointed by you: including mortgage brokers, lawyers, financial advisors, surveyors.
• Business information: including property owned by you, transactions, amounts paid or owed.
• Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
• Creditworthiness: We may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you.
• Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
• How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.
• Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.
• Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
• Subscription information: for example when you subscribe to one of our e-mail alerts or other materials.
• IP address information and cookies installed: your computer's IP address and cookies allow us to track your usage of our website.

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION AND CRIMINAL RECORDS INFORMATION

We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your trade union memberships;
• information about your health, including any medical condition, health and sickness records, medical records and health professional information; and

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

Also we will not generally collect, store and use any criminal records information in relation to you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

3. SOURCES WE COLLECT YOUR PERSONAL INFORMATION FROM

We will collect personal information from a number of sources. These may include the following:

• Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us, contact us by phone, email or communicate with us directly in some other way.
• Your landlord: such as a housing association
• From referrals and recommendations: usually given by other people who know you or have a working relationship with you.
• Our website and associated cookies: provides us with information about how you use our website and the devices that you use to connect to our website
• Social media, advertising or marketing providers and digital media: when you interact with or view them.
• Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms.
• Journalists or other investigators: they may provide us with details or make enquiries about you or matters concerning you or ourselves.
• Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.
• Our professional advisors: such as lawyers, accountants, planning consultants and surveyors and other consultants and advisors.
• The Government, local authorities, planning authorities or relevant regulators: to assist with investigations, for example the Information Commissioner's Office or planning applications to the local planning authority.

4. USES MADE OF YOUR PERSONAL INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

Purpose	Personal Information Used	Lawful Basis
Identity and money laundering checks and passing details of our money laundering checks to third parties and to carry out credit checks	All the personal information we collect	We and a third party also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid
Enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties	All the personal information we collect	To enter into and perform contracts with either yourself or the organisation that you represent. We have a legitimate interest to properly perform contracts with third parties
Deal with your queries, complaints, claims or legal disputes or raise queries, claims, legal disputes or complaints with you	All the personal information we collect	This may be necessary to perform a contract with you or the organisation that you represent. We have a legitimate interest to improve the services and/or products we provide. To defend, bring or establish legal claims
Data analytics, use of cookies and statistical analysis to help us improve our online services	How you use our website	We have a legitimate interest to improve the online services we provide and user experience
Determine services and/or products that may be of interest to you	All personal information we collect	We have a legitimate interest to improve the services and/or products we provide and to determine which products and/or services you may be interested in
To provide you with requested information	Contact details and services and products or other information that you have requested we provide to you or your organisation	To comply with any request made by you
Direct marketing, targeted advertising and social media advertising, marketing or promotions	Contact details, personal identifiers and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past or which you have indicated you or your organisation may be interested in	We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively we may market or carry out advertising or promotions in relation to our products or services as a legitimate interest in developing our business. You have the right to opt out from any direct marketing at any time
Holding events	Your contact details, details of attendance, your comments in response forms and dietary requirements and CCTV images	We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements
To comply with our legal and regulatory obligations	All the personal information we collect	To comply with any legal and regulatory obligation or requirement
Fraud, crime prevention and debt collection	All the personal information we collect	We have a legitimate interest to detect and prevent crime and to collect debts.
To manage our relationship with you and to operate our business	All the personal information we collect	We have a legitimate interest to operate our business in an efficient way and to expand our business To enter into and perform contracts with either yourself or the organisation that you represent
Storage of records relating to you and also records relating to our business	All the personal information we collect	To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records
Dealing with enquiries, defect rectification, complaints and other communications from you and dealing with legal disputes and warranty claims involving you	All the personal information we collect about you	We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications We have a legitimate interest to ensure that all legal claims are managed effectively To defend, bring or establish legal claims

For some of your personal information you may have a legal, contractual or other requirement or obligation to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share personal information with the following parties:

• Companies in the same group of companies as us: in relation to joint events
• Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain
• Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
• Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.  Marketing and public relations companies, social media, advertising or marketing providers and digital media: to help us to develop, carry out and assess marketing, public relations, promotions and advertising campaigns.
• Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
• Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business or parts of our business.
• The Government, local authorities, planning authorities or relevant regulators: where we are required to do so by law or to assist with their investigations, for example the Information Commissioner's Office
• Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.

We also use Google Analytics which sets cookies to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage....

We also use Microsoft Clarity to observe user engagement on our website. This allows us to improve your experience. It can record your mouse, scroll movements, and clicks. Some of the data obtained can be used by Microsoft for advertising, for more information and to opt-out, see Microsoft Privacy Statement: https://privacy.microsoft.com/....

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally entitled to do so. We do not sell your data

6. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in section 6 above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

7. HOW LONG WE KEEP PERSONAL INFORMATION FOR

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:

• For individual contacts at customers and suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 6 years afterwards.
• For website users it will generally be a period of 6 years after you used our website.
• For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years.
• For individuals attending an event it will generally be a period of 3 years after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let your usual contact at Bellway know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address.

8. SECURITY

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-pub....

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

10. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

11. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email data.protection@bellway.co.uk or write to the Data Protection Officer at Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF.

CCTV Privacy Notice

This notice sets out how Bellway Group (being Bellway p.l.c, and Bellway Homes Limited) and Ashberry Homes trading under the “Ashberry Homes” brand of Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF (we, us our) uses your personal information which may be recorded on our CCTV system. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection we will be the controller of any of your personal information recorded on our CCTV system.

Our staff and other individuals working for us may in limited circumstances access personal information outside of the UK and EU. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws, and contact details are set out in the "Contacting us" section at the end of this privacy notice

1. What information may we hold / process that will relate to you?

We may collect from you video recordings and still pictures which feature you if you are in the field of vision of any of our CCTV system. This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system

2. What do we do with your personal information?

As the data controller we will collect personal information on our CCTV system and use it for the following purposes:

• For the prevention and detection of crime
• For evidence in any civil or criminal legal proceedings
• To assist in investigations
• For safety and security
• Dealing with any queries, complaints or enquiries
• Retaining records

As well as being the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal information

We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.

3. Who we share your personal information with

We share your personal information with the following parties:

• Suppliers and service providers: to manage and operate the CCTV system as our data processor.
• Joint data controllers: who may jointly operate and maintain the CCTV system with us.  The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people and investigate alleged criminal activities.
• The security services: where relevant for matters of national security.
• People who have been injured, attacked or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.  People who have been involved in road traffic accidents and their insurance providers: to assist with insurance claims, legal claims and investigations.
• Private and other investigators: to aid their investigations.
• Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives, and this includes but is not limited to the Information Commissioner's Office

We do not disclose personal information obtained using our CCTV system to anyone else except as set out above.

4. Transferring your personal information internationally

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union.

5. How long do we keep your personal information for

We will keep your personal information for up to approximately 30 days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will usually be overwritten. However if we receive an enquiry about a particular recording on our CCTV we will generally then retain that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the particular case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be many years. As soon as it is no longer required we will then delete the personal information

Your rights in relation to your personal information

You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; (iii) the right to request the correction of inaccurate personal information we hold about you; (iv) the right to request the erasure of your personal information in certain limited circumstances; (v) the right to restrict processing of your personal information where certain requirements are met; (vi) the right to object to the processing of your personal information; (vii) the right to request that we transfer elements of your data either to you or another service provider; and (viii) the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored in our CCTV system. For example we do not use automated decision making in relation to your personal data in our CCTV system. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.

More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-pub....

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator in the European Union if you are based outside the UK or bring a claim in the courts. However we are here to help and would encourage you to contact us to resolve your complaint first.

6. Changes to this notice

We may update this privacy notice from time to time. You are encouraged to regularly check for any updated version of this privacy notice.

7. Contacting us

In the event of any query or complaint in connection with the personal information we hold about you or if you would like more information about or to exercise your rights, you can contact our Data Protection Officer. Please email data.protection@bellway.co.uk or write to the Data Protection Officer at Woolsington House, Woolsington, Newcastle upon Tyne, NE13 8BF.