PRIVACY POLICY

Our Privacy Policy

The Flamingo Group are UK based online property experts that provide essential services in property management, lettings, sales and many other key areas. 

We are committed to earning and keeping your trust, while giving you control over the information that is personal to you. Being accountable to you is a responsibility we take seriously. Our commitment to privacy, including processing and protecting personal data, is demonstrated in this privacy policy (“Privacy Policy”).

This Privacy Policy applies to our processing of personal information collected in connection with your shopping with creating and managing your test account for evaluating our services

This Privacy Policy describes how The Flamingo Group (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Key Terms

The following key terms shall be used in this Privacy Policy:

  • Aggregated Data: Data that is consolidated and presented in a summarized manner, not by individual.
  • Anonymous Information: Information that has undergone anonymization such that it can no longer be used to identify an individual and cannot be combined with other information to re-identify an individual.
  • Data Controller: The natural person or legal entity which, alone or jointly with others, determines the purpose for which data is used and the means of the processing of Personal Data.
  • De-identified Data: Data where certain identifiers are removed to prevent a person’s identity from being directly connected with the information (such as masking certain personal identifiers).
  • Personal Data: Any information relating to or regarding an identified or identifiable natural person or information that can be used to identify you (or your household), either alone or in combination with other information available to us. 
  • Special Categories of Data: Categories of Personal Data that require a heightened level of protection under data protection legislation in some jurisdictions because it reveals or concerns sensitive information, such as health matters, race, or ethnic origin.
  • Standard Contractual Clauses (if ay when applicable): Any set of contractual clauses, approved by the European Commission and / or UK, for the transfer of personal data to processors established in a third country (outside of the EU/EEA) where that third country does not ensure an adequate level of protection. 
  • Supervisory Authority: Supervisory Authority (or its equivalent under any data protection legislation) is the independent public authority to whom data subjects may lodge a complaint.

Information We Collect

When you place an order from or otherwise use the Site, we collect the following types of information:

Information You Manually Provide

In the process of placing an order on the Site, you provide information required to complete your transaction, validate your identity, confirm compliance with regulations related to the purchase, and complete the transaction. This may include information such as name, address and credit card data. This information is provided to us under the conditions established in this Privacy Policy and the privacy policy of our Supplier. In addition to transactional information, you may provide additional information when seeking support for your purchase or other services from us, such as when you use customer service or register products. We may also collect information you provide to us if you enter a competition or promotion, or sign up to receive newsletters or related services.  We may also collect information when you apply for a job or otherwise submit employment data to us.

Special Categories of Data

We do not collect or process Special Categories of Data. However, if a situation like such arises where we may require to collect and process such data, we will be sure to comply with applicable data protection legislation and apply the necessary legal basis for processing data.

Information from Your Browser or Device

We may also receive information from your web browser. This may include information that does not identify you personally (such as the date and time of your visit). The information we receive depends on the settings on your web browser. Unless prohibited by law, creating a user identity during a visit to the Site constitutes your consent for processing of your Personal Data, and we may link the information your browser provides to information that identifies you personally, as described below. Please consult your browser’s help function to find out how to change the settings. We may also collect limited Personal Data (email address) through web technologies in connection with your use of the Site, as described below.

Geolocation Information

When you use a smart phone, mobile device or computer to access the Site, we may collect information about your physical location. We may combine this information with other location-based information (e.g., your IP address and billing/postal code), to provide you with other services on your mobile device. We only share your location information with third parties that help us provide you with services. You can opt out of sharing this information by changing the permissions in your mobile device.

Cookies and Other Similar Technologies

The information we collect using cookies and similar technologies is not typically personally identifiable, but we may link it to Personal Data that you provide. We use cookies and other similar technologies to collect information and support certain features of the Site. As the Internet evolves, we may use different types of technologies for this purpose. For example, we may use these technologies to collect information about how visitors use the Site (such as which pages they visit and the links they use). We analyse this information to better understand our visitors’ interests and needs, and to improve the content and functionality of the Site. We may also use the information to support Site features to avoid asking you to re-enter information we already possess. We also use this information to personalise your experience when you use the Site and to improve marketing efforts, including through use of targeted advertising. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://thenai.org/about-online-advertising/how-does-it-work/. 

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies, you may be unable to use all of the Site’s functions if your browser rejects our cookies.

Third Party Cookies and Other Similar Technologies

Web technologies may also be placed on the Site by third party providers. Also, we or third party providers may use web technologies on behalf of the Supplier whose branding appears on the Site or its service providers. This means our Supplier would be allowed to use the data collected. This information is used to enhance your experience with the Site, for marketing analysis, for targeted and display advertising, and for quality improvement. We may collect your IP address through web technologies.

We and our Suppliers may use third party service providers in connection with the Site. These and other service providers may collect information about your visits to websites, your interaction with websites, and the products and services offered by us or our Suppliers. Their collection and use of information are subject to their own privacy policies.

For more information regarding these third party services and how to opt out, please visit https://www.youronlinechoices.com/ (for EU & UK).

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

 

cookielawinfo-checkbox-analytics

This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”.

cookielawinfo-checkbox-functional

The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.

cookielawinfo-checkbox-necessary

This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.

cookielawinfo-checkbox-others

This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.

cookielawinfo-checkbox-performance

This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.

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The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Information from Third Parties

We may also receive certain information about you from third parties, such as through your use of a social network authentication to sign in to the Site, your use of an authenticated payment method, or through other online data sources, according to the rules of the use and processing of such information established by the respective source. If any Personal Data are freely available or accessible in the public domain, we will not have any obligations to you regarding the same.

Our Legal Basis for Processing Personal Data

In certain jurisdictions, the processing of your Personal Data is lawful only if it is permitted under data protection legislation. We apply several legal bases to ensure that our processing and use of your data is compliant with applicable laws and that we have a legal basis for processing activities as outlined below:

  • Performance of a Contract. 

By completing a transaction through this Site, you are entering into a contract for the sale of products or services, which is governed by our Terms of Sale. We must process your personal information to fulfil our obligations under that contract.

By using the Site or otherwise submitting your Personal Data to us, you consent to our collection, use and sharing of your information as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use or submit your information through the Site.

  • Legitimate Interest.

We may process Personal Data where processing is necessary for our (or a third party’s) legitimate interests, where those interests are not overridden by the interests or rights and freedoms of the data subject.  We will process your data based on legitimate interest, for reasons such as fraud screening, payment optimisation, and compliance with any applicable regulatory scheme governing the transaction. We may process your Personal Data to market to and contact you or to start a conversation using data collected from public sources. We may also, in compliance with applicable law, process your data based on legitimate interest. 

  • Other Legal Basis.

We may also process your data based on another legal basis such as in cases where processing is necessary to comply with legal obligations.

How We Use Your Information

When you visit the Site to complete a transaction, we will use your Personal Data in the following manner: 

In Connection with Your Transaction

When you visit the Site to complete a transaction, we must process your data to complete the transaction and to comply with our transactional obligations, including processing necessary to:

  • ensure security and monitor and prevent fraud;
  • process your order and payment, verify your tax status, contest chargebacks, or send you transactional notifications;
  • provide you with a personalised shopping experience;
  • register your purchase with the manufacturer or service provider for warranty, technical support or similar purposes;
  • provide notice of your purchase of a service right to the provider of that service;
  • where you have consented, establish an account for future purchases; and
  • provide you with an effective experience and support. As allowable by law, this may include contacting you if you start a checkout process to follow-up on the incomplete session or to see if there was a problem with your use of the Site.
  • We use WordPress to power our online store. You can read more about how WordPress uses your Personal Information here: https://en-gb.wordpress.org/about/privacy/

Marketing and Related Communications

When you provide Personal Data, we may offer you a choice as to whether you would like to receive further marketing and related communications from us or our Supplier. Where you have consented to receive them in accordance with applicable law, these communications could be in the form of direct mail, email or telephone and will contain information relating to our or our Supplier’s products and services. At any time, you may opt out of receiving these communications by emailing us at hello@theflamingogroup.co.uk

Except where otherwise required by law, if you give us consent to add your contact information to our Supplier’s mailing list and later withdraw this permission, you must contact our Supplier (or follow the unsubscribe instructions in the emails from our Supplier) to have your name removed from our Supplier’s mailing lists.

Our Use of Anonymous Information

We may use a process called anonymisation to make data collected by us Anonymous Information. In this case, all personal data elements, such as name, street address, phone number, email address, and others will be anonymised in accordance with applicable law.  We may use the Anonymous Information to:

  • personalise and support your use of the Site and/or the services of our Supplier;

improve the Site, the customer experience, our advertising systems, and our products

and services;

  • identify transactions as originating through an affiliate marketing or referral program;
  • deliver targeted advertisements on the Site and other commerce solutions;
  • provide reporting to our current and prospective Suppliers and service providers; and

conduct other historical or statistical research and analysis.

We may also use De-identified Data for the same purposes as described in this section, as well as for related purposes, as allowed by applicable law.

Other Ways We Use Your Personal Data

We may also use your Personal Data:

  • to verify compliance with applicable laws;
  • to verify that data we have about you is accurate;
  • as identified in any supplemental privacy notice posted on the Site;
  • to contact you if you have requested communication from us; and

     

How We Protect Your Information

We will process your Personal Data on secure servers. Your commerce transaction will be optimally processed in or near the region from which you initiated your session. A copy and/or back-up of your Personal Data may be stored and otherwise processed in our cloud service providers. 

No method of transmitting or storing data is completely secure, however, we take reasonable steps to provide a level of security appropriate to the sensitivity of the information we collect. We have implemented physical, technical, and administrative security practices and safeguards reasonably designed to protect your Personal Data from unauthorised access and disclosure. When we collect or transmit sensitive information such as a financial account number, we use industry standard methods to protect that information as required by applicable laws. Although we use reasonable measures to protect your information, we cannot guarantee the security of information provided over the Internet or stored in our databases. You are also responsible for taking reasonable steps to protect your information against unauthorised disclosure or misuse, for example, by protecting your password and signing off when you finish using a shared computer or mobile device. We leverage industry best practices to mitigate potential compromises. If the Personal Data under the custody of Sky Garden is (or is likely to be) divulged, damaged or lost, we will immediately take remedial measures, inform you, if impacted, in a timely manner and report to the competent government agencies as required by applicable laws.

In connection with a Sale, Merger or Related Event

If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions (such as part of a sale, merger, reorganisation, or similar event), your Personal Data will become owned by that company, unless otherwise provided for by local legislation. In that event, the acquiring company’s use of your Personal Data will be subject to the governing Privacy Policy, any applicable supplemental privacy notices, and the privacy preferences you have expressed to Sky Garden prior to merger.

Children's Privacy Policy

Sky Garden’s services are not directed at nor targeted towards children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use the Site unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove such information.

Your Rights to Access and Control Your Personal Data

We respect your right to make choices about the ways we collect, use, and share your Personal Data.

  • Accessing Your Data. If you would like to review, correct, restrict the processing of, object to direct marketing, or request erasure of your Personal Data, please send us a request on hello@theflamingogroup.co.uk 
  • Editing and Deleting Data. if there is any error in the Personal Data that you have submitted to us or if you would like to request erasure or deletion of your Personal Data, please contact us on hello@theflamingogroup.co.uk and we will take appropriate measures
  •  Objecting to Data Use. You have the right to object to our processing of Personal Data for direct marketing purposes. We do not sell your Personal data, nor will we use it for Direct Marketing purposes without your consent. If you contact us, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide enough information to verify your identity or to satisfy our legal and business requirements as noted in our data retention policy. When we delete your Personal Data or Special Categories of Data, it will be disposed of in a manner that prevents loss, theft, misuse, or unauthorised access in line with our data retention policy. You have the right to report to your local Supervisory Authority if you believe your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Data Retention Policy

The Flamingo Group may retain your Personal Data and transactional data for as long as you continue to use the Site, and thereafter as permitted or required by applicable law or to satisfy our business requirements.

Data Controller

All Personal Data collected by visiting the Site is controlled by The Flamingo Group as identified during the transaction, The Flamingo Group is the Data Controller for any Personal Data provided or collected during the transaction.

Automated Processing

The Flamingo Group does not use automated processing in connection with your purchase transaction. Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

  • Temporary deny list of IP addresses associated with repeated failed transactions. This deny list persists for a small number of hours.
  • Temporary deny list of credit cards associated with deny listed IP addresses. This deny list persists for a small number of days.

Changes to This Privacy Policy

We keep this Privacy Policy under review and will post any updates to the Site. Our changes will become effective immediately upon posting. We may also supplement or amend this Privacy Policy by placing other privacy notices on the Site. Such privacy notices will explain how we handle information specific to where the privacy notice appears and should be read together with this Privacy Policy.

A link to our previous privacy policy is included here.

Grievance Officer

As required under certain data protection laws, we have appointed a grievance officer. The Flamingo Group’s grievance officer is: Emma Lloyd (Operations Head)

Email: hello@theflamingogroup.co.uk. 

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@theflamingogroup.co.uk or by mail using the details provided below:

Flamingo Short Lets LTD, Suite 6 Salts Farm East, Guildford TN31 7PA, United Kingdom

Last updated: [29th June 2022]

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/