Privacy Policy | SHB

Privacy Policy

This is the privacy notice of SHB Real Estate In this document, “we”, “our”, or “us” refer to SHB Real Estate. We are company number 7958956 registered in United Kingdom. Our registered office is at 3-4 Holborn Circus, London, England, EC1N 2HA

  1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at
  7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

  • Information we process because we have a contractual obligation with you
  • When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
  • In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
  • We may use it in order to:
    • -verify your identity for security purposes
    • -sell products to you
    • -provide you with our services
    • -provide you with suggestions and advice on products, services and how to obtain the most from using our website

    We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

  • Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
  • We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
  • Information we process with your consent
  • Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including Job Opportunities our products and services, you provide your consent to us to process information that may be personal information.
  • Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
  • Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
  • Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
  • If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
  • We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
  • You may withdraw your consent at any time by instructing us [email protected] However, if you do so, you may not be able to use our website or our services further.
  • Information we process for the purposes of legitimate interests
  • We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
  • Where we process your information on this basis, we do after having given careful consideration to:
    • -whether the same objective could be achieved through other means
    • -whether processing (or not processing) might cause you harm
    • -whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
    • -record-keeping for the proper and necessary administration of SHB Real Estate responding to unsolicited communication from you to which we believe you would expect a response protecting and asserting the legal rights of any party.
  • -insuring against or obtaining professional advice that is required to manage SHB Real Estates risk
  • protecting your interests where we believe we have a duty to do so
  • Information we process because we have a legal obligation
  • We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
  • For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.This may include your personal information.
Specific uses of information you provide to us:
  1. Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:
-posting a message our forum
-tagging an image
-clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at [email protected]

Complaints regarding content on our website

Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person.

We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Information relating to your method of payment

We store information about your debit or credit card or other means of payment when you first provide it to us.

We store this payment information at your request in order to make repeat purchasing of goods and services easier next time you visit our website.

We also store it to help us prevent fraud.

We take the following measures to protect your payment information:

  1. We keep your payment information encrypted on our servers.
  2. We do not keep all your payment information so as:
  • -to prevent the possibility of our duplicating a transaction without a new instruction from you;
  • -to prevent any other third party from carrying out a transaction without your consent
  • Access to your payment information is restricted to authorised staff only.
  • If we ask you questions about your payment information, we only show the last four digits of the debit or credit card number, so that you can identify the means of payment to which we refer.

We automatically delete your payment information when a credit or debit card expires

Information about your direct debit

When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank for processing according to our instructions. We do not keep a copy.

We keep this information only for the duration of the direct debit arrangement.

We are registered under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.

Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of SHB Real Estate

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.


When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website

  1. Cookies
  2. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
  3. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
  4. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
  5. Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
  6. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
  7. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
  8. We use cookies in the following ways:
    • -to track how you use our website
    • -to record whether you have seen specific messages we display on our website
    • -to keep you signed in our site
    • -to record your answers to surveys and questionnaires on our site while you complete them
    • -to record the conversation thread during a live chat with our support team
  9. Personal identifiers from your browsing activity
  10. Requests by your web browser to our servers for web pages and other content on our website are recorded.
  11. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
  12. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
  13. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
  14. Our use of re-marketing
  15. Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
  1. Information we obtain from third parties
  2. Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
  3. Third party advertising on our website
  4. Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
  5. Credit reference
  6. To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
  7. Data may be processed outside the European Union
  8. Our websites are hosted in the UK. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly data obtained within the UK or any other country could be processed outside the European Union. For example, some of the software our website uses may have been developed in the United States of America or in Australia. We use the following safeguards with respect to data transferred outside the European Union:
    1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
    2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union, specifically that in the UK
    3. we comply with a code of conduct approved by a supervisory authority in the European Union, specifically that in the UK
    4. we are certified under an approved certification mechanism as provided for in the GDPR
    5. both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information
Access to your own information
  1. Access to your personal information
    1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
    2. To obtain a copy of any information that is not provided on our website you may send us a request at [email protected]
    3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
  2. Removal of your information
  3. If you wish us to remove personally identifiable information from our website, you may contact us at [email protected] may limit the service we can provide to you.
  4. Verification of your information
  5. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
  1. Use of site by children
    1. We do not sell products or provide services for purchase by children, nor do we market to children.
    2. If you are under 18, you may use our website only with consent from a parent or guardian
    3. Certain areas of our website are designed for use by children over 15 years of age.
    4. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
    5. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
  2. How you can complain
    1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is [email protected]
    2. You can find further information about our complaint handling procedure at
    3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
    4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at
  3. Retention period for personal data
  4. Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
    1. -to provide you with the services you have requested;
    2. -to comply with other law, including for the period demanded by our tax authorities;
    3. -to support a claim or defence in court.
  5. Compliance with the law
  6. Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website.
Privacy Notice (Recruitment)

This notice provides you with important information concerning personal data the Company may collect, retain and process relating to job applicants. The personal data is limited to that which is relevant for recruitment and selection purposes. The Company seeks to be transparent in respect to personal data and is committed to meeting its data protection obligations. This notice aims to assist in this matter.

This Privacy Notice should be read in conjunction with the Company’s Data Protection Policy.

Name and Contact Details of Data Controller

SHB Real Estate Ltd is the Data Controller. Holly Sherwood is responsible for the Data Controller’s data protection compliance. She may be contacted at [email protected].

Purpose of Processing and Legal Basis for Processing

The Company needs to collect, retain and process or use personal data for the following reasons:

• In order to enter into a contract of employment or any other work contract with you or to take steps at your request prior to entering into a contract;

• To meet our legal responsibilities as an employer (for example to check you are entitled to work in the UK and/or to meet our responsibilities under the Equality Act 2010);

• To pursue the relevant and legitimate interests of the business (for example, to process and retain information in order to manage the recruitment process; in order to make appropriate decisions about suitability of candidates; or in order to make offers of employment);

• Special categories of personal data may be processed in order to comply with the Equality Act 2010 and/or other legislation.

The Company will not use your personal information for any purpose other than recruitment activity. However, if you are not successful the Company may retain your details for a 6 month period and may then contact you if, during this period, a suitable vacancy arises.

Who has Access to Personal Data

Your personal data will only be disclosed where appropriate to authorised individuals within the Company or third parties who are involved in the recruitment process.

Those who are authorised individuals within the Company include those with HR and/or recruitment responsibilities, the management team in the area where the vacancy exists, those involved in the interview and assessment process, and those with responsibility for IT, where they need access to your data for the performance of their role. However, in respect of those with access to your data, the data to which they have access will be limited only to that which is necessary for the proper performance of their function.

If you are not successful your personal data will not be shared with third party providers, other than those who may be included in the recruitment process. If, however, you are successful in your application your personal data may be provided to third party providers, such as any third parties providing accountancy, payroll, HR, legal, occupational health or benefit provision support to the Company, and in such circumstances only data relevant to such support will be provided. Further, the need for pre employment checks and/or the obtaining of references may result in us sharing information with other employers. Also we may need to perform pre employment screening or conduct Disclosure and Barring checks and again we may share your data with such external organisations as are used in such circumstances.

Where data is provided to third parties they are placed under an obligation of confidentiality and are given written instructions to only use the data for the purposes for which it is disclosed.

It may be that your personal data will be transferred outside the European Economic Area (EEA) through the use of cloud storage or similar technology. In such circumstances data will only be transferred to organisations in accordance with the relevant data protection legislation.

Time Period for Retaining Data

If you are unsuccessful in your application the Company will retain your personal data for a period of up to 6 months following the decision in relation to your application. If you are successful, your personal data will be retained in accordance with the Company’s Data Protection Policy (and you will be issued with a further Privacy Notice as an employee of the Company).

Your Rights

As a data subject you have the following rights:

• You can request from the Company access to and a copy of your data;
• You can request the Company to correct or erase personal data;
• You can request a restriction of processing of your personal data; and
• You can object to processing of your personal data.

If you wish to exercise any of the above rights you should contact the Data Controller identified above.

In addition, you have the right to lodge a complaint about data protection with the Information Commissioner’s Office.

You are not under any contractual or statutory requirement to provide any personal data to the Company during the process of recruitment. However, if you fail to provide relevant personal data this may prevent the Company from being able to fully or properly process your application or it may be the Company will not be able to process your application at all.

No automated decision making is used in respect to any personal data.

Categories of Personal Data

The Company may collect, use and process a range of personal information relating to you during or as part of the recruitment process. The nature of the personal data may include information such as or relating to the following:

Your name, address, email address, contact details, phone number, personal details, right to work in the UK, criminal records your qualifications, work history, future career plans, experience, skills, current level of pay and associated employment benefits, health records/history, whether you have a disability and or whether reasonable adjustments are needed, references, equal opportunity related information, information relating to your suitability for the role.


The data collected and processed relating to you is received from a number of sources. These include information provided by you (such as CVs, application forms, identity documents) or information gained at interviews, meetings or assessments with you.

In addition data about you may be obtained from other sources for example where references are provided from a previous employer or third party or from other employment checks such as criminal records checks or other pre employment checks where appropriate.

The data held will be stored securely by the Company and will be held within the Company’s Computerised systems, including the email system, HR System, as well as in the appropriate hardcopy and electronic recruitment file(s).

  1. Review of this privacy policy
  2. We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact us.