Privacy Policy
Tersons Privacy Policy
Tersons is the trading name of Cilec Limited. This document explains how we collect, use, store and share personal data, and how to contact us if you have a question or complaint about the way in which your personal data is handled.
This policy applies to personal data processed by Tersons in connection with our estate agency, lettings, property management, block management, commercial agency and related professional services.
We process personal data in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, and any other applicable data protection, privacy, consumer protection, anti-money laundering or sanctions legislation. References to data protection legislation include amendments made by the Data (Use and Access) Act 2025 as and when those provisions are in force.
Tersons are based at 29 Castle Street, Dover, Kent, CT16 1PT.
Telephone number 01304 246110.
The data controller is Cilec Limited trading as Tersons. The data protection contact is Simon Crowley, who can be contacted at the above address or at simon@tersons.com. General enquiries may also be sent to dover@tersons.com.
Personal data is information which identifies you or could reasonably be used to identify you. It may include information provided by you, information generated during our dealings with you, and information obtained from third parties or public records where this is necessary for the services we provide.
The Personal Data we will collect
In all cases, we will normally need to collect your name, address, telephone number(s), email address and details relevant to the service or transaction in which you are involved.
Depending on the nature of your relationship with us, we may also collect identification documents, proof of address, date of birth, nationality, source of funds, source of wealth, bank details, payment records, employer details, salary or income information, pension or benefit information, National Insurance number where genuinely required, property ownership details, tenancy information, leasehold information, service charge and ground rent information, guarantor information, references, communications with you, notes of conversations, complaint records, viewing records, access arrangements, key records and other information required for the relevant service.
We may process special category data, such as health information, only where this is necessary and lawful. This may include information you provide about a disability, vulnerability, accessibility requirement, medical issue or other circumstance which we need to take into account when providing services, arranging access, managing a tenancy, dealing with a repair, handling a complaint or complying with legal obligations. We will only process this type of information where we have a lawful basis under Article 6 of the UK GDPR and a separate condition under Article 9 of the UK GDPR.
Failure to provide information we reasonably require may cause delay and may prevent us from acting for you, progressing a transaction, arranging a viewing, managing a tenancy or property, complying with our legal obligations or continuing to provide services.
How will we collect your Data
We will usually collect personal information from you directly. We may also collect information from public records, including HM Land Registry, Companies House, local authority websites, planning records, the electoral register and other lawful publicly available sources.
We may receive information from third parties where this is necessary for our services. These may include solicitors, licensed conveyancers, financial advisers, lenders, surveyors, accountants, referencing agencies, employers, landlords, tenants, leaseholders, freeholders, managing agents, residents' management companies, guarantors, family members, referees, contractors, insurers, utility providers, deposit protection schemes, property portals, regulators, professional bodies and public authorities.
If you contact us through our website, we may collect information provided through any enquiry form and technical information about your use of the website. Cookies and similar technologies are dealt with below.
Cookies and Website Use
Our website may use cookies and similar technologies. Cookies are small files placed on your device which help a website function, remember preferences, understand how the website is used or support marketing activity.
Strictly necessary cookies may be used without consent where they are required to provide a service requested by you or to make the website work properly. Non-essential cookies, such as analytics, advertising or marketing cookies, will only be used where the appropriate consent has been obtained. You can usually manage or disable cookies through your browser settings, but some website functions may not work properly if you do so.
Use of your Personal Information
We will only use personal data where we have a lawful basis for doing so. The lawful bases we rely on will depend on the circumstances and may include performance of a contract, steps taken before entering into a contract, compliance with a legal obligation, our legitimate interests, your consent, the establishment, exercise or defence of legal claims, and, in rare cases, vital interests.
We may use personal data for the following purposes: providing estate agency, lettings, property management, block management, commercial agency and related services; identifying clients and customers; carrying out anti-money laundering, sanctions and fraud prevention checks; marketing properties; arranging viewings and valuations; negotiating offers; progressing sales, purchases, lettings and management matters; communicating with solicitors, surveyors, lenders and other professional advisers; arranging repairs, maintenance, inspections and access; managing service charges, ground rents, client accounts, payments and invoices; dealing with complaints, disputes, claims and regulatory matters; maintaining business records; training staff; managing our relationship with you; and complying with legal and regulatory obligations.
Where we rely on legitimate interests, those interests may include operating and managing our business, providing services requested by our clients, communicating with parties involved in a transaction or management matter, protecting our legal position, preventing fraud, maintaining accurate records, recovering debts, improving our services and ensuring the effective management of properties. Where we rely on consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.
Sharing your Personal Data
We do not sell, lease or otherwise commercially exploit personal data. We do not provide personal data to third parties for their own marketing purposes unless you have given consent or another lawful basis applies.
Tersons does not receive commission, referral fees, retainers, rewards or other financial benefits from solicitors, licensed conveyancers, surveyors, mortgage advisers, contractors, suppliers or other third parties to whom clients, customers or prospective purchasers may be referred, unless this is expressly disclosed in writing.
Tersons does not have connected business arrangements with other businesses for the purpose of its interaction with a client or customer. Changes to that policy will be expressly disclosed in writing.
Where we share personal data, we will only share information which is reasonably necessary for the relevant transaction, instruction, contract, legal obligation, regulatory obligation or legitimate business purpose.
We may share personal data where necessary with sellers, buyers, landlords, tenants, leaseholders, freeholders, residents' management companies, right to manage companies, solicitors, licensed conveyancers, surveyors, lenders, financial advisers, mortgage brokers, referencing agencies, contractors, inventory clerks, energy assessors, insurers, utility providers, deposit protection schemes, property portals, IT providers, software providers, payment processors, professional advisers, debt recovery agents, courts, tribunals, The Property Ombudsman, HMRC, local authorities, law enforcement bodies, regulators and any other person or organisation where disclosure is necessary for our services or required or permitted by law.
We may be legally restricted from explaining certain disclosures or actions, for example where anti-money laundering, sanctions, fraud prevention or law enforcement restrictions apply.
Marketing of Services
We may contact you about services which are relevant to your relationship with us. We will comply with the Privacy and Electronic Communications Regulations 2003 and applicable data protection legislation when sending marketing communications by email, text or other electronic means.
For individual customers, we will usually need your consent before sending electronic marketing, unless the soft opt-in applies. The soft opt-in may apply where we obtained your contact details during a sale or negotiation for similar services, you were given a clear opportunity to opt out at the time, and you are given a clear opportunity to opt out in every further message.
You may object to direct marketing or withdraw consent at any time by contacting us or by using any unsubscribe option provided. We will then stop sending marketing communications to you, although we may retain limited details on a suppression list so that your preference can be respected.
Social Media and Property Portals
We use property portals, our own website and, where appropriate, social media to market properties for sale or rent and to provide general updates about our services. Property marketing will not normally require your separate marketing consent where it is part of the service you have asked us to provide, but we will seek consent where the proposed use goes beyond what is necessary for the service or where consent is otherwise required.
Where will your data be held?
Personal data may be held in paper files, on our internal computer systems, within our property management and accounting software, within email systems, on secure cloud-based systems and by service providers who process data for us. We take reasonable technical and organisational measures to protect personal data, including access controls, backups, firewalls, anti-virus protection, staff training, physical file security and secure disposal procedures.
Some of our service providers may store or access data outside the United Kingdom. Where personal data is transferred internationally, we will ensure that appropriate safeguards are in place, such as adequacy regulations or approved contractual safeguards, unless an exemption applies.
How long will we keep your data?
We will not keep personal data for longer than is necessary for the purpose for which it was collected, unless a longer period is required or permitted by law. Retention periods will depend on the nature of the information and the reason it is held.
As a general guide, transaction, management, accounting and complaint records may be kept for a period which enables us to meet legal, tax, regulatory, professional indemnity and limitation requirements. Anti-money laundering records will generally be retained for at least five years after the end of the relevant business relationship or transaction, unless a longer period is required or permitted by law. Marketing records will be retained until you opt out or until there is no longer a lawful reason to retain them. Where information is no longer required, we will delete it, anonymise it or destroy it securely.
Your Rights
Subject to legal conditions and exemptions, you may have the right to request access to your personal data, correction of inaccurate data, erasure of data, restriction of processing, objection to processing, data portability, withdrawal of consent and information about automated decision-making or profiling. We do not make decisions about individuals based solely on automated processing where those decisions have legal or similarly significant effects, unless this is lawful and appropriate safeguards are in place.
If you make a subject access request or another data protection rights request, we will respond without undue delay and within one month of receipt of the request, subject to any lawful extension. If a request is complex, or if you have made a number of requests, the response period may be extended by up to a further two months. We may need to verify your identity before responding and may ask you to clarify a request where this is reasonably required.
How do I seek Clarification? How do I complain?
If you have any questions about this privacy policy, how we handle your personal information, or if you wish to exercise a data protection right, please contact Simon Crowley at Tersons, 29 Castle Street, Dover, Kent, CT16 1PT or by email at simon@tersons.com. General enquiries may also be sent to dover@tersons.com.
If you are dissatisfied with the way we handle your personal data, please tell us first so that we can investigate and respond. We will maintain a clear and accessible complaints procedure for data protection complaints.
If you are not satisfied with our response, you have the right to complain to the Information Commissioner's Office. The ICO's website is www.ico.org.uk and its helpline number is 0303 123 1113. The ICO's postal address is Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
