Muir Homes Privacy Policy

Muir Homes Ltd. Privacy Notice ISSUE NO: Original DATE: 21.05.2018

1. Muir Group Plc & Muir Homes Ltd Privacy Notice

Muir Group Plc (“Muir Construction Ltd”, “Muir Homes Ltd”, “Muir Timber Systems Ltd”, “Muir Leisure Ltd”, “Hermiston Securities Ltd”, “Muir Aberdeen Ltd”, “JW Muir Property Investments Ltd”) is committed to respecting your privacy and to complying with applicable data protection and privacy laws.

For Muir Homes Ltd. the protection of personal data is of the utmost importance. Our Privacy Notice has been written to offer you peace of mind so that you know exactly how we use, store and protect the personal information you give to us.

Just like the homes we provide, our data is safe and secure – we comply with all of the relevant Data Protection regulations, including General Data Protection Regulations (GDPR), and we are committed to using your data in a responsible and sustainable way, making sure that your privacy is protected at all times. We want you to feel good and feel secure when visiting our website (www.muirhomes.co.uk), safe in the knowledge that any data you provide to us will be processed, used and kept carefully and respectfully.

2. Information Collection

Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (such as anonymous data).

There are some ‘special categories’ of more sensitive personal data which require a higher level of protection.

We collect, store and use some or all of the following categories of personal information:

• Client engagement information: name, title, address, telephone number, email address, photographic identification, date of birth, credit check, copies of council tax and utility bills.
• Client file information: name, title, job title, address, telephone number, email address, bank account details.
• Marketing information: name, title, address, telephone number, email address and marketing preferences.
• Mortgage Advice, your relevant details will be used to be referred to a mortgage adviser as part of our qualification process
• Solicitor, should you wish to receive legal advice we will refer you to a solicitor

There are areas of the Muir Homes website where you may be asked to give your personal information, which includes (but is not limited to):

• Name
• Contact information (e.g. email address and phone number)
• Demographic information (e.g. postcode and location)

We use this information for the following reasons:

• To improve our product and service offering
• For market research purposes
• To provide more information about our products/services
• To refer you for mortgage, protection or legal advice

In addition to these purposes, we add users who have actively opted into further communications from Muir Homes to our internal database (see Active Opt-In section below for more details).

Non-personal data

By using our website, we may automatically collect non-personal information about you and your website usage, such as:

• How you interact with the Muir Homes website, including session duration, the number of pages visited etc.
• Whether you have been on the website before
• Which device you are using to access our site (including hardware and software information like what model you are using and the browser operating system you accessed our website from)
• Tracking information – whether you came to muirhomes.co.uk directly or via another site
• Location information – which country/region you’re in when you access our website

Please bear in mind that all this information is anonymous and is provided to us through the use of cookies – these are numerical ID identifiers that uniquely associate to a specific web browser or computer and tracks the usage of that particular device. Cookies do not ever hold personal data such as name, address and contact information. You can read more about our cookie policy here (link to Cookie Policy).

We use the following channels to collect non-personal data:

• Google AdWords – Muir Homes conducts external digital marketing via Google Adwords, which is “an online advertising service where advertisers (in this case Muir Homes) pay to display brief advertising copy, product listings and video content within the Google ad network to web users”.

We aim to target our campaigns specifically to people who have already shown an interest in Muir products to make it more relevant to you as a user, which is why we try to serve relevant ads to the IP addresses we have collected based on your past viewing habits. However, you can control the information Google uses to show you ads here.

• Google Analytics – In keeping with our dedication to providing only relevant and engaging content on our website, Muir Homes uses a third-party service called Google Analytics to collect information such as website visitor behavior patterns and user journeys when on the muirhomes.co.uk site.

Again this uses your unique IP address rather than your personal information (meaning you won’t be identified by name but by your device’s unique numerical ID), but allows us to monitor things like tracking and conversion data:

• o Tracking – We track user activity on our website (such as the number of pages visited and time spent on each page) for statistical analysis purposes, allowing us to gather aggregate patterns and improve the website and its functionality based on past visitor usage.

• o Conversions – in the same way as the tracking data, Muir Homes uses Google Analytics to show how many people ‘converted’ on the site (that is, how many people, for example, filled out a form on the website). This allows us to monitor how effective our website is for providing relevant information, and monitor how engaged our users are when on the muirhomes.co.uk website.

If you don’t want Google to collect data for use on their Google Analytics software, you can install the Google Analytics Opt-Out Browser add-on here.

• Google Remarketing – Muir Homes also use the Google remarketing service, which allows us to advertise on third party websites (including Google) to people we know have already visited our site.

Using the data we gathered using cookies (based on your device’s unique ID rather than your personal data), Google will be able to identify if you have visited the Muir Homes website within a certain period of time and can send an advertisement to you on our behalf. These remarketing ads can appear on an organic Google search engine results page, or within the Google Display Network, but will be based on your past viewing habits.

This is in keeping with our Cookies policy (which you can read here) and with Google’s overarching Privacy Policy, which you can read here.

• Facebook Pixel – Muir Homes use Facebook as a way to advertise, which we do using Facebook’s in-built Conversion Tracking Pixel – this allows us to follow users using their unique ID when they access our site by clicking on Facebook advertisements. This is done to monitor the effectiveness of the adverts we show on Facebook, and the anonymous data we gather is used for statistical and research purposes.

As with all services we use for marketing, Facebook Pixel is used in line with Muir Homes’ Privacy Notice, as well as Facebook’s Privacy policy – which can be viewed here.

The non-personal data we collect that tracks visitors and user journeys on the Muir Homes website are anonymous – you cannot be identified from this information, nor can any of your personal data be accessed by Muir Homes at any time using the above channels.

You can opt-out of these services at any time – the links above will provide you with how you can prevent your data being used in this way.

3. How will we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

•  Contract – your personal information is processed in order to fulfil a contractual arrangement.
•  Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
•  Legitimate Interests – this means the interests of Muir Group in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way.
•  Legal Obligation – where it is statutory or other legal requirements to share the information e.g. when we have to share your information for law enforcement purposes – identify fraud etc.

We may use your information for a number of purposes which includes:  managing and administering your account and/or contract; delivering any services, products or information requested by you; referring you for mortgage or legal advice; responding to complaints or account enquiries; administering debt recoveries; verifying your identity when required and after sales care on your property. Our lawful basis for this is to fulfil a contract and legitimate interest. We use your marketing information for marketing purposes, this includes contacting you with relevant information about our services, developments, special offers, products, inviting you to events and measuring engagement with our communications to ensure that the content that we create is relevant and useful. Our lawful basis for this is your consent.

In submitting a job application and/or speculative CV and if you have provided your consent, we may contact you to discuss if there are other opportunities or provide you with recommended jobs or contact you for other jobs you may be interested in. We will keep your details on file for 12 months unless you inform us otherwise. Our lawful basis for this is your consent.

Any social media posts or comments you send to us (on the Muir Homes Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook / Twitter) on which they are written and could be made public. We are not responsible for this kind of sharing. We recommend you should review the terms and conditions and privacy policies of the social media platforms you use.

Active opt-in policy

In compliance with changing GDPR regulations, we have now made sure that every form on the Muir Homes website contains an active opt-in.

This means that, instead of relying on a tick box to say you don’t want to receive ongoing communications from Muir Homes, we operate an active opt-in policy, which means that you’ve got to actively tick a box when submitting an online form to say: “I’d like to receive offers, new release information, and updates from Muir Homes and related services”. Only then can we contact you with marketing information.

However, if you submit your personal information on muirhomes.co.uk without ticking the active opt-in box, your information will be used for its intended purpose only – that is, discussing your initial query and any subsequent services such as referring you for mortgage or legal advice – we will keep your data on our records unless you request the information to be permanently deleted.

Please note: under the Data Protection Act, you have the right to withdraw your permission at any time (even if you have actively opted in), at which point we will be legally obligated to delete any information we hold on you.

Change & Consent

You can update your details, change marketing preferences and/or change your mind and withdraw such consent at any time by contacting:

Data Protection Officer Muir Homes Ltd

Belleknowes Industrial Estate Inverkeithing KY11 1HY

muirhomescompliance@muir-group.co.uk

4. Data Sharing

We share your data with third parties, including third-party service providers, which include but not limited to – solicitors, sub-contractors, mortgage advisers, warranty providers (NHBC), financial advisors. We require all third parties to respect the security of your data and to treat it in accordance with the law.

We engage third parties to provide the following services: public relations and marketing, IT support, practice management systems, document management systems, case management systems, printing and reprographics support, event hosting services and telephone customer satisfaction surveys.

All third parties are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow third parties to use your personal data for their own purposes. We only permit them to access your personal data for specific purposes and in accordance with our instructions.

Muir Homes Ltd may also be obliged to disclose your personal information to meet any legal or regulatory requirements (for example to comply with a court order or during audits) or obligations in accordance with applicable law (for example HMRC).

5. Data Retention

To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for. In most cases, this means we will keep your information for as long as you continue to use our services, and for a reasonable period of time afterward if you stop doing so. After that, we will delete it other than where we lawfully can keep any data for audit or legal reasons.

When we no longer need to keep certain data, we destroy paper documents securely by shredding and delete the electronic record.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

6. Information Security

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those people who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

We cannot be responsible for the privacy policies and practices of other websites. even if you access them using links from our website. Once you have clicked through and left our website, Muir Homes no longer have any control over your protection and privacy of any information you may provide on the external website, and as such these sites are not governed by this Privacy Notice.

For this reason, we would always recommend that you check the policy of each site you visit for further details.

7. Your rights

We will securely retain your information for as long as is reasonably necessary and in accordance with applicable law. Under certain circumstances, by law, you have the right to:

• Request access to your personal information. This is commonly known as a subject access request. This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• Whenever you are asked to complete an online website form, look for a clickable box to indicate that you don’t want the information to be used by anybody for direct marketing purposes (see Active Opt-In)

If you want to review, verify, correct or request erasure of your personal information or object to the processing of your personal data, please write to us at the following:

Data Protection Officer Muir Homes Ltd

Belleknowes Industrial Estate Inverkeithing KY11 1HY

muirhomescompliance@muir-group.co.uk

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You may continue to receive information and mailings for a short period while your request is dealt with.

8. If you fail to provide personal information

If you fail to provide certain personal information when we request it, we may not be able to perform our contract with you properly or we may be prevented from achieving our legitimate interests (such as engaging with you on social media).

9. Change of purpose

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

10. Privacy Support

Muir Group Plc reserves the right to amend or modify this Privacy Notice at any time and in response to changes in applicable data protection and privacy legislation. If we decide to change our Privacy Notice, we will post the changes on our website.

11. Complaints

If you have any concerns over how we use your data, please contact us in the first instance at the following contact details:

Data Protection Officer Muir Homes Ltd

Belleknowes Industrial Estate Inverkeithing KY11 1HY

muirhomescompliance@muir-group.co.uk

If you are not satisfied that we have addressed your concerns adequately, you have the right to lodge a complaint with the ICO. Their contact details are below:

The Information Commissioner’s Office – Scotland

45 Melville Street

Edinburgh

EH3 7HL

Telephone: 0303 123 1115

Email: Scotland@ico.org.uk