At Clockwork, we’re committed to respecting and protecting your privacy.
Review of this Policy
We keep this Policy under regular review. This Policy was last updated in February 2023,
Clockwork is the trading name of Clockwork Maintenance and Refurbishment Limited company registration number 12868499), the registered office is 248a City Road, Cardiff, Wales, CF24 3JJ, and Clockwork Construction Limited (company registration number 07035818) and the registered office is 1 St Martin’s Row, Albany Road, Cardiff, South Glamorgan, CF24 3RP. We are registered in England and Wales and we are based in the UK.
Responsible Person – Data Controller
The person responsible for all matters concerning the privacy and processing of any personal data, also known as the Data Controller, is:
Miss Celyn Evans
Clockwork Construction Limited/ T/A Clockwork and Clockwork Maintenance & Refurbishment Limited T/A Clockwork
1 St Martin’s Row
The Data Controller can be contacted at firstname.lastname@example.org or you can write to the above address.
How do we collect personal information about you?
We obtain personal information about you that you provide to us through our website, emails, telephone conversations, documents you provide to us or when you visit us, for example when you:
- Enquire about specific maintenance or refurbishment requests
- Ask us to quote for a job
- Ask us about one of our maintenance services
- Register for our email newsletters
- Participate in one of our surveys
- Interact with us on our social media sites
We also obtain personal information relating to you using automated technical means when you visit our website.
What type of personal information is collected?
The information we collect from you might include (but is not limited to) your name, address, email address, phone number, date of birth and financial details and any other information you choose to provide to us. During the Covid-19 pandemic, we may also be obligated to collect health data, such as whether you have symptoms of Covid-19, if you have been tested positive for Covid-19 or had any contact with anyone who has tested positive. This information is required in order to keep staff and customers safe. Please see further information relating to this at the end of this notice.
The information we collect through our website using automated technical means includes: the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, identification number, online identifier and location data. We also collect information about your website visit including which website pages are accessed, page response times and length of visits to pages.
How long do we retain your personal information?
We review our retention periods for personal data on a regular basis. We are legally required to hold some types of information for certain prescribed periods to fulfill our statutory obligations. Outside of specific statutory obligations, we will hold your personal data on our systems for as long as is necessary for the relevant purposes for which we use it, or in accordance with any retention periods set out in any relevant contract you hold with us.
We will retain personal information (for customers and tenants) relating to any works organised by us for:
- A maximum of 6 years from the end date of a job/service.
- If you apply or enquire about a maintenance service with Clockwork but this does not proceed to a purchase, we will retain your data for a maximum of 12 months.
For all maintenance works, we hold both homeowner and agent information, this includes contact details such as name, address, phone number and contact number. In instances where the property is sublet we would also require tenants’ contact information, we collect this information on the basis that you have obtained consent to pass these on to us. Your details are stored in our customer database and our accounts software.
When you subscribe to our newsletter we collect your name and your email address, which will be stored in our email marketing system. We keep this information for the duration of your custom.
We need this data to be able to send you details of any offers, relatable matters or local news. We are processing this data with your consent. You may withdraw your consent at any time by clicking on the unsubscribe link at the bottom of the newsletter.
Your details are stored in our customer database. We require this data so that we can meet legal requirements in relation to anti-money laundering legislation and for our financial records, we keep this for the required period of seven years.
We will only share your details with relevant specialists (for example, subcontractors, surveyors and suppliers etc) and relevant government bodies when you ask us to do so or are required to do so. We have formal data-sharing agreements in place with our referral partners to ensure your data is handled appropriately when we share it.
We may use properties as case studies to be published on our website and social media.
Once we have completed the agreed work, we keep your details for seven years to meet our legal obligations in relation to financial records keeping. Where warranties exceed this period, data will be held for the length of the warranty.
Your records are hosted in the EU or in countries with EU equivalency.
We collect your name, telephone and email address, whereby the customer (landlord/letting agent) has obtained permission from you to do so. We need this data to be able to carry out works instructed by the customer (landlord/letting agent). We keep this information as part of our customer database and will be held for seven years to meet our legal obligations in relation to our financial record keeping. Where we hold resident data on behalf of customers (landlord/letting agent), it is the customer (landlord/letting agent) responsibility to obtain consent to pass this data on.
Your records are hosted in the EU or in countries with EU equivalency.
From time to time we may use specialist suppliers and contractors where the property requires maintenance etc we will require your address, postcode, and contact telephone numbers plus any pertinent company information such as VAT number, company number and if necessary, copies of insurances, accreditations or training etc. Your details are stored in our supplier database and our accounts software.
All records are hosted in the UK, EU, or in countries with EU equivalency.
In some cases, it is not possible for us to specify in advance the periods for which we will retain your personal information. In such cases, we will determine the period of retention based on the following criteria:
(a) the legal basis or legitimate interest to retain the data
(b) your personal preference
Under the General Data Protection Regulation (GDPR), you have certain rights regarding your data. You have the right to:
- Ask us for a copy of any data we hold about you.
- Have any data that is incorrect, corrected.
- Object to the use of your data.
- Have your data provided to you to take elsewhere in a suitable format.
- Have your data deleted in certain circumstances.
If you wish to exercise any of these rights then please contact our Data Controller.
You also have the right to lodge a complaint about the use of your data with the Information Commissioner’s Office (ICO). Details for the ICO and making a complaint can be found on their website at www.ico.org.uk
Where third-party data is passed to us, it is those that pass on this data that is responsible for a data-sharing agreement to ensure the correct permissions are received.
How do we use your personal information?
We may use the information that you directly provide to us in the following ways:
- We may use your name, address and contact details for the purpose of carrying out our obligations arising from any contracts entered into by you and Clockwork, such as; providing you with products and services that you have requested and performing maintenance at your property. Our legal basis for this use is that it is necessary for the performance of a contract to which you are party.
- We may use your name, email address and postal address to provide you with information you have requested from us or relevant information such as new legislation that could affect you, respond to enquiries or requests from you, communicate with you in relation to those enquiries or requests and arrange visits to the property by our staff. Our legal basis for this use is our legitimate interests, namely carrying out activities in the course of Clockwork business in response to customer enquiries or requests.
- We may use your name, email address and postal address to provide you with information regarding similar goods and services to those you have already enquired about or purchased. Our legal basis for this use is our legitimate interests, namely the ongoing marketing of our goods and services to individuals with whom we have an existing relationship in connection with our goods and services and/or who have expressed an interest in those goods and services;
- Where you have entered into a contract with us or we have provided you with services, we may use your name, email address, postal address or phone number to ask for your feedback about the services we have provided to you. Our legal basis for this use is our legitimate interests, namely evaluating and where necessary improving the quality of our service provision with a view to promoting the success of our business and positive customer relationships.
- Where you are a party to an existing contract with us or regularly enter into contracts with us for our goods and services, we may use your name, email address, postal address or phone number to notify you of changes to the terms and conditions of our services. Our legal basis for this use is our legitimate interests, namely the administration and management of our business contracts and relationships.
- We may use your name, email address and postal address to send you marketing communications, if you have chosen to receive these. These may include information about properties for rent or for sale, the current property market, promotions or offers. Our legal basis for this use is consent.
- We may request and use your ID or a utility bill to verify your identity where required. Our legal basis for this is compliance with legal obligations to which we are subject, our legitimate interests to confirm identity, namely ensuring the security of our systems, network and information and those of third parties.
We may use the information that we automatically collect using technical means through our website to:
- Administer our site and for troubleshooting, testing, research and statistical purposes. We use Google Analytics, a third-party website monitoring tool. Our legal basis for this is our legitimate interests, namely monitoring the use of our software and IT systems, improving our website
- Measure or understand the effectiveness of our own advertising activity. Our legal basis for this use is our legitimate interests, namely improving the relevancy of our advertising.
- Measure or understand the effectiveness of our marketing emails via email marketing service MailChimp.
We use MailChimp for marketing or information messages to customers. Personal data is stored within our MailChimp account in order to allow us to create distribution lists and send email campaigns. Our legal basis for this use is consent to contact you where you have opted in to marketing messages or, where you have entered into a contract with us or we have provided you with services, we may use your email address to inform you about any changes to legislation that may affect you. Our legal basis for this use is our legitimate interests, namely ensuring the legal compliance of Clockwork and its customers.
We may analyse the personal information we collect directly from you and obtain using automated technical means to create a profile of your interests and preferences so that we can contact you with information relevant to you (if you have chosen to receive marketing communications from us). We may make use of additional information about you when it is available from external sources to help us do this effectively. These sources include the Land Registry Public Register.
We may also use any of your personal information that we collect from you directly and additional information about you from external sources where necessary to detect and reduce fraud and credit risk. These sources include Credit Risk Agencies, the Land Registry Public Register and Companies House Public Register. Our legal basis for this use of your personal information is our legitimate interests in preventing our business being subject to fraud or credit risk. Where a credit check is completed (this would not be carried out without your express permission to do so) this is a “soft” search and does not leave a footprint on your credit file, only you will be able to see that a search has been undertaken.
Who has access to the information?
We will not sell or rent your information to third parties. We may pass your information to third-party service providers, including but not limited to:
Business partners, suppliers and sub-contractors working on our behalf for the purposes of completing tasks and providing services to you.
Your personal data, including name, address, contact details and preferences will be shared with:
- Simpro, based in Australia (with EU equivalency, who provide Clockwork with maintenance management software.
- G Suite and Google Gmail, who provide Clockwork with Email and calendar service and filing system.
- A2Z Computing Ltd, based in the UK who provide Clockwork with IT services.
- Kane Cloud Communications and 8×8, based in the UK who provide Clockwork with cloud-based telephony and call recording facilities.
- MailChimp, an email marketing service based in the USA (Clockwork control the data within their account, data is not used by MailChimp directly or passed to other third parties).
- Barclays Bank, based in the UK, for customers and suppliers who provide Clockwork with banking facilities
- Various Contractors for the purpose of arranging maintenance at the property or complying with legal obligations to complete certification of the building or appliances at the property. Our legal basis for this use is that it is necessary for the performance of a contract to which you are party.
- The Solicitor and Surveyor relating to any maintenance of your property.
When we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and otherwise use your information in accordance with applicable data protection law.
We may disclose your personal information to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information to our insurers and /or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
In addition to the specific disclosures set out in this section, we may disclose your personal information 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, or for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure.
This Policy seeks to ensure that the Close Circuit Television (CCTV) system used by Clockwork is operated in compliance with the law relating to data protection (currently the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA 2018”))
We seek to ensure compliance with privacy law and take into account best practice as set out in codes of practice issued by the Information Commissioner. We, therefore, use CCTV only where it is necessary in pursuit of a legitimate aim.
We use CCTV in order to:
- promote a safe community and to monitor the safety and security of its premises;
- assist in the prevention, investigation and detection of crime in and around our premises;
- assist in the investigation of breaches of its codes of conduct and policies by staff, customers and contractors and where relevant and appropriate investigating complaints.
CCTV images will not be retained for longer than necessary, taking into account the purposes for which they are being processed. Data storage is automatically managed by the CCTV digital records which overwrite historical data in chronological order to produce an approximate 28-day rotation in data retention. All retained CCTV images will be stored securely.
Third-party requests for access will usually only be considered in line with the GDPR and DPA 2018 in the following categories:
- legal representative of the Data Subject;
- law enforcement agencies including the Police;
- disclosure required by law or made in connection with legal proceedings.
In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, applying only in certain circumstances and subject to certain exceptions, and in the interests of keeping this policy concise, 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.
You have the right:
- To object to us processing your personal information for marketing purposes. If you object, we will stop processing your personal information for this purpose. When we collect your data, you can choose whether you wish to receive marketing communications from us. If you wish to stop receiving marketing communications, you can opt-out at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails.
- To access the information we hold about you and certain information about our processing of it and your rights in relation to it.
- In certain circumstances, to obtain erasure of the personal information we hold about you, subject to certain exceptions.
- To rectification of the information we hold about you.
- In certain circumstances, to restrict our processing of your personal information or object to us processing it. If you object, we will stop processing your personal information unless certain exceptions apply.
- Where our legal basis for processing your personal information is your consent or the performance of a contract and we process it by automated means, to be provided with the personal information we hold about you in structured, commonly used and machine-readable format and to transmit the information to another controller.
- To not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly affecting you, subject to certain exceptions.
- Where our processing of your personal information is based on your consent, to withdraw that consent at any time. If you withdraw your consent, we will stop the relevant processing, but it will not affect the lawfulness of our processing before the withdrawal.
To exercise any of these rights, please contact us at email@example.com or Clockwork, 1, St. Martin’s Row, Albany Road, Cardiff CF24 3RP
In addition, you can exercise your right to object to direct marketing at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails.
If you consider that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint to a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. More information about lodging a complaint with the Information Commissioner’s Office (the relevant UK supervisory authority) can be found at https://ico.org.uk/concerns/.
Security precautions in place to protect your information
We take appropriate technical and organisational precautions to secure your personal information and prevent its loss, misuse or alteration. All information you provide to us is stored on our secure servers. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
The transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and for this reason we cannot guarantee the security of data sent between us over the internet.
Website and Security
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Social Media Policy
You may interact with employees or representatives of Clockwork speaking on behalf of Clockwork on Twitter, Facebook and other social media. When interacting on those platforms you are subject to the terms and conditions of those platforms as well as any privacy policies of those platforms.
Should you choose to interact with Clockwork on these platforms,
- you agree that your contributions, including your comments, photos or other media you share are able to be used by Clockwork or other members of the Seraph group for the purposes of continuing the social media dialogue or for other marketing purposes, for instance as a customer testimonial, or as a quote in a press release, or in another sympathetic manner.
- you assert that you are the creator or copyright holder, (or that you have permission from the copyright holder) to share and distribute any material you share with us, and you give us permission (or that you have sought permission from the copyright holder for us) to share and distribute this material.
Should we use your material in this way, Clockwork will not misrepresent or change the meaning of your material, though we may edit for brevity or clarity.
Under government guidance and for the business to continue to operate, measures have been put in place to ensure the organisation is covid-secure. This notice describes how we may use your information to protect you and others during the COVID-19 outbreak.
We may seek to collect and process information from you, which is above and beyond what would ordinarily be collected. This is necessary to ensure your safety and well-being, however, we will ensure that this will be limited to what is proportionate and necessary for us, in accordance with Government guidance, to manage and contain the virus and enable us to effectively keep people safe, put contingency plans into place to safeguard those who are vulnerable and to aid business continuity.
We will collect health data in relation to covid-19. We will only keep your information for as long as it is necessary, as a minimum the information outlined in this privacy notice will be kept for the duration of the COVID-19 response. When the information is no longer needed for this purpose, it will be securely deleted.
You can obtain further information about data protection laws by visiting the Information Commissioner’s Office website at www.ico.org.uk.
Talk to us for more information
If you’d like to discuss our service options and packages or need advice regarding maintenance issues, please give us a call on 02920 602444 or: