Privacy

This Privacy Policy explains how we collect, use, and protect the personal data you provide to us, or that we collect about you. Please read it carefully to understand what information we gather, why we collect it, and how it is handled.

Our website and services may include links to third-party websites that we do not operate or control. We are not responsible for the content, security, or privacy practices of those external sites, and we encourage you to review their privacy policies before providing any personal data.

We may update this Privacy Policy from time to time by making changes on this page.

For the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR) (EU 2016/679), the Data Controller is Page & Rodgers Estate Agents Ltd T/A hodders. We are registered in England under company number 05419789, with our registered office at 15 Windsor Street, Chertsey, Surrey, KT16 8AY.

What Information We Collect From You

The personal information we collect will typically include the following:

• Full name and contact details – including telephone number, email address, and postal address.
• Identity verification information – required to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), underpinned by the Proceeds of Crime Act 2002 (POCA), and the Immigration Act 2014.
  • We are legally required to carry out anti-money laundering checks on all clients involved in buying or selling a property.
  • While we retain overall responsibility for ensuring these checks and any ongoing monitoring are completed correctly, the initial checks are conducted on our behalf by Lifetime Legal.
  • Lifetime Legal will contact you once you have instructed us to sell your property or had an offer accepted on a property you intend to purchase.
  • The cost of these checks is a one-off payment of £65 (inclusive of VAT) per property for each transaction, regardless of the number of individuals involved, and is payable directly to Lifetime Legal. This fee covers the cost of obtaining relevant data, together with any manual checks and ongoing monitoring that may be required. The fee is non‑refundable.  **In some circumstances a portion of this fee may be retained by hodders as an administration fee for facilitating the process.
• Information relating to close connections, where we are required to identify potential conflicts of interest under our regulatory obligations.
• Banking and financial details, where required to:
  • manage rental payments,
  • set up an approved tenancy deposit account, or
  • facilitate other property-related transactions.
• Access requirements or special needs information – where necessary to help us identify suitable properties. This may involve collecting special category personal data such as information relating to a disability or health condition.
• Marketing preferences and interests – including details of areas or property types you are interested in, where you have agreed to receive marketing communications from us.
• Website usage information – including data collected via cookies. This may cover:
  • pages visited and time spent on our website,
  • clicks, interactions, and navigation paths,
  • technical details such as IP address, browser type and version, device information, time zone settings, operating system, and platform.
  • For further details, please refer to our Cookie Policy.
• App usage information – including technical and location data (where enabled by you on your device).
• Communications with us – such as records of your email correspondence, phone calls, and other interactions with our staff in relation to our services.

When We Need Your Personal Data

We process your personal data only where we have a valid legal basis to do so.

In certain circumstances, we are legally required to collect personal data (for example, to meet our obligations in relation to fraud prevention and anti-money laundering regulations) or to fulfil the terms of a contract we have with you. If you fail to provide the information requested, we may be unable to perform the contract we have entered into with you, or that we are seeking to enter into (for example, providing you with our services). In such cases, we may be required to cancel the product or service you have with us, but we will inform you at the time if this becomes necessary.

Lawful Bases for Processing Your Information

Under data protection legislation, we are permitted to process your personal data on the following grounds:

• Contractual necessity – where the processing is required to perform a contract with you, or to take steps at your request prior to entering into a contract (for example, providing you with our products and services).
• Consent – where you have given us clear and explicit consent to process your data for one or more specific purposes, including:
  • receiving electronic marketing communications from us, and/or
  • processing Special Category Personal Data (as described above).
    Please note, you are not required to provide marketing consent in order to use our services.
• Legitimate interests – where the processing is necessary for our legitimate business purposes, except where such interests are overridden by your fundamental rights, freedoms, or interests. When relying on legitimate interests, we consider factors such as:
  • the information provided to you at the time your data was collected,
  • your reasonable expectations regarding the processing of your data,
  • the nature and sensitivity of the data, and
  • the potential impact of the processing on you.
    Our legitimate interests include activities such as improving and promoting our services, gaining a better understanding of the property market and our customers’ interests, and managing the technical and administrative aspects of our products and services.
• Legal obligation – where processing is necessary for us to comply with the law.
• Vital interests – in rare cases, where processing is necessary to protect your vital interests or those of another person.
• Public interest or official authority – where processing is necessary for reasons of substantial public interest or to carry out official functions.

How We Use Your Information

We will hold and use your personal information for the following purposes:

• To deliver our services – fulfilling our obligations to you when providing property-related services.
• To share information where necessary – including with third parties where required to provide our services, or where we are acting as an agent on your behalf.
• To comply with legal and regulatory obligations – such as verifying your identity, preventing fraud and money laundering, and assessing creditworthiness.
• To communicate with you – keeping you updated throughout the provision of our services, including responding to your enquiries and requests.
• For statistical and business analysis – enabling us to review performance, manage our business effectively, and plan strategically for the future.
• For marketing purposes –
  • to provide you (or allow selected third parties to provide you) with information about goods and services that may be of interest to you, where you have consented to receive such communications; or
  • if you are an existing customer, to contact you by electronic means (such as email or SMS) with information about our own goods and services that are similar to those you have previously obtained or discussed with us.
    You may unsubscribe from marketing communications at any time.
• To monitor and improve our services – including tracking your use of our website and App to help us enhance functionality and user experience.
• To notify you about changes – informing you of updates to our services, policies, or terms of business.
• To optimise website content – ensuring our site is presented to you in the most effective way for your device and browsing experience.

How Long We Keep Your Data

We retain personal data for different periods depending on the services provided and our legal obligations. In some cases, we are required to hold your information for longer than the duration of the service itself. This may be necessary to:

• comply with statutory or regulatory obligations,
• meet our duties under relevant legislation, or
• retain records in the event of a legal claim, dispute, or complaint.

As a general rule:

• Property transactions (sales and lettings): we are legally required to retain customer due diligence and transaction records for at least five years from the end of the business relationship or completion of the transaction, in line with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017). In practice, we usually retain these records for six years, which also aligns with HMRC and industry best practice.
• Tenancy agreements and related documentation: typically retained for six years after the end of the tenancy, in line with limitation periods for potential legal claims.
• Marketing data (with consent): retained until you withdraw your consent or unsubscribe from communications.
• General correspondence and enquiries: usually retained for up to two years, unless a longer retention is required for regulatory, legal, or operational reasons.

After the relevant retention period has expired, your personal data will be securely deleted or anonymised.

Who We Share Your Information With

To provide our services effectively, we may share your personal data with carefully selected third parties. These third parties generally fall into two categories under data protection law:

• Data Processors – organisations that process personal data on our behalf and under our instructions, to help us deliver our services. Examples include payment service providers, IT and cloud hosting providers, technical support service providers, and contractors engaged to carry out property-related works.
• Data Controllers – organisations that determine the purposes and means of processing personal data independently. These include solicitors, surveyors, managing agents, relocation companies, and local authorities involved in your transaction.

We may share your information with third parties for the following purposes:

• Service delivery – to perform our contractual obligations, including sharing information with solicitors, surveyors, landlords, tenants, relocation services, contractors, and other partners involved in property transactions.
• Regulatory compliance – to meet legal requirements, including anti-money laundering checks, fraud prevention, identity verification, and credit reference checks, in line with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017) underpinned by the Proceeds of Crime Act 2002 (POCA).
• Business operations – to administer our services effectively, including through cloud service providers, IT support, data storage, and technical system maintenance.
• Legal and protective purposes – to comply with applicable laws and regulations, protect our rights, property or safety, and to prevent fraud or other unlawful activity.
• Business transfers – in connection with a sale, merger, reorganisation, or acquisition of all or part of our business or assets, your information may be transferred to the relevant third party as part of that process.

We will never share your personal information with third parties for marketing purposes without your prior consent.

Security of Your Data

We take the security of your personal data seriously and use appropriate technical and organisational measures to protect it against unauthorised access, loss, or damage. Your data is stored on secure servers within the European Economic Area (“EEA”), and wherever possible, identifiable information is encrypted or minimised.

Access to your data is limited to authorised personnel and secured by industry-standard controls. If you have been given a username and password to access our systems, you must keep them confidential and notify us immediately if you believe they have been compromised.

We regularly review our security measures to ensure they remain effective and compliant with the UK GDPR and the Data Protection Act 2018.

Your Rights – Accessing and Updating Your Information

You have the right to request access to the personal information we hold about you (a “data subject access request”). You also have the right to request that any inaccurate or incomplete information we hold is corrected, updated, or deleted where applicable.

Such requests are free of charge. To make a request, please contact our Data Protection Officer at:

Data Protection
hodders
15 Windsor Street
Chertsey
KT16 8AY

We will respond to your request in accordance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018.

How You Can Request Erasure of Your Data

You have the right to request the deletion or removal of your personal data where there is no legitimate reason for us to continue processing it. This includes situations where:

• You have successfully exercised your right to object to processing,
• You have withdrawn your consent,
• We have processed your data unlawfully, or
• We are required to erase your data to comply with applicable law.

Please note that there may be circumstances where we are legally required to retain certain information. If this applies, we will inform you at the time of your request.

How You Can Withdraw Your Consent

You have the right to withdraw any consent you have given us to process your personal data at any time. Please note that withdrawing consent will not affect the lawfulness of any processing carried out before your withdrawal.

To withdraw consent, please contact us at: hoddersadmin@hodders.net.

How You Can Restrict or Object to Our Use of Your Data

You may request that we restrict the processing of your personal data in certain circumstances, or object to our processing where we rely on legitimate interests (or those of a third party), and you believe such processing impacts your fundamental rights and freedoms. You also have the right to object where we process your data for direct marketing purposes.

In certain cases, we may demonstrate compelling legitimate grounds to continue processing your data which override your rights. Please note that restricting or objecting to processing may affect our ability to provide you with our services.

To make such a request, please contact us at: prodgers@hodders.net.

Moving Your Information to Another Organisation (“Data Portability”)

Where we process your personal data by automated means and either with your consent or to perform a contract with you, you have the right to request a copy of that data in a structured, commonly used, and machine-readable format. You may also request that we transfer your data directly to another organisation where technically feasible.

To make such a request, please email: hoddersadmin@hodders.net. We will respond within one month of receiving your request, considering technical feasibility and compatibility with the receiving organisation.

Complaints About Our Use of Your Personal Data

If you have concerns about how we process your personal data, please contact us so we can investigate your complaint: prodgers@hodders.net.

If you are not satisfied with our response or believe your data is being processed unlawfully, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO). For further information, visit: www.ico.org.uk or call 0303 123 1113.

This Privacy Policy was last update: 29 September 2025