Because it's so much more than bricks and mortar

Privacy Policy



This privacy notice sets out how we use your personal data and tells you about your privacy rights and how the law protects you.  Personal data is any information about you from which you can be identified.

This privacy notice applies when you have provided your personal data to us yourself or someone else has provided your personal data to us.


Our role as Data Controller

When we use personal data about you or others in connection with promoting and running our business and providing our services, we do so as a data controller.  The data controller is Fiona Penny (trading as Fiona Penny Bespoke Home Finders of West House, 66-72 High Street, Rolvenden, Kent. TN17 4LW. Telephone: + 441580 713825 (referred to in this notice as “we/our/us”). Our VAT number is 152 3152 46.

Who to contact

We have allocated informal responsibility for overseeing questions in relation to this privacy notice, including any requests to exercise your legal rights, to our privacy manager.  You can contact our privacy manager at the postal address or email address given above.  Please mark your communication “FAO Privacy Manager”.

Changes to the privacy notice

We may update this privacy notice from time to time.  The latest version is always available on our website.

Changes in your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes (for example, if you change your address).

Third party links

Our website may include links to third party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third party websites and are not responsible for their privacy statements.


We may collect different kinds of personal data about you when you interact with us, including via the website, social media, email, telephone, post or in person.  We may also receive this information from third parties (for example, a publicly available source or from someone who has recommended us to you and given us your contact details). Where you are a client or a prospective client, we may acquire personal data about you (and others) from other parties connected with you or the services you wish us to provide.   We have grouped this information in the following categories:

  • Identity Data such as your name. Where you are a client or you are seeking to appoint us to provide our services to you, Identity Data may also include copies of your passport, driving licence, birth certificate, national identity card, utility bills and/or other identifying information required to be provided to us for anti-money laundering purposes.
  • Contact Data such as your postal address, email address, telephone number and other contact details.
  • Enquiry Data such as your enquiries about engaging us to provide our services.
  • Services Data: includes any personal data about you connected with your instructions to us or the services we provide to you, including correspondence between us, notes of our phone calls and meetings, and third party information about the services we are providing to you.
  • Financial Data: which includes your bank account and/or other billing details.
  • Transaction Data: includes details about any payments to and from you.
  • Correspondence Data: such as any correspondence between us and you about an enquiry or when you provide us with a testimonial.
  • Technical Data: such as your IP address, operating system, browser type and version, location and other information about how you use our website.
  • Tracking Data: such as information we or others collect about you from cookies and similar tracking technologies.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not usually collect any Special Categories of Personal Data about you. Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Unless we are required to do so to comply with a legal obligation, we do not usually collect any information about criminal convictions and offences.

Other than where compelled to do so by a court or relevant law or regulation, you are not under any obligation to provide personal data to us.  However, if we need personal data to carry out our duties (for example, anti-money laundering checks or to progress our services) and you do not provide this information, we may not be able to provide you with our services, or to continue to do so.  We will inform you if this happens.



Our core purposes for processing personal data are to promote and operate our business, to provide services to our clients, to maintain our client and business records and to comply with the law and regulations.  Where you are a client, or you are seeking to appoint us to provide services to you, this primarily involves providing you with the information you have requested from us, invoicing you for services we have undertaken for you, keeping records of the work we have carried out for you and fulfilling our anti-money laundering obligations.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (for example, a contract between you and us to provide our services to you).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, to monitor and protect our IT systems).
  • Where we need to comply with a legal or regulatory obligation (for example, the rules which require us to verify the identity of someone before they can become a client).
  • Where we have your consent to do so.

Purposes for which we will use your personal data

This table sets out in more detail the lawful basis we rely on to process your personal data, depending on the category of personal data and the reason we are processing it. 

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.


Sharing your personal data with others

We may allow our officers, employees and self-employed consultants to access your data where we believe it is necessary. 

In order to provide you with our services, we may provide personal data to vendors, estate agents, letting agents, surveyors, lawyers or to other professionals.  We will do so on your instruction, but not otherwise.

We may disclose personal data to HM Revenue and Customs, the Information Commissioner’s Office and any other regulators and other authorities who require reporting or disclosure of processing activities, or other personal data, in certain circumstances.

We may share your data with third parties to whom we have outsourced certain tasks, such as IT, business administration or analytics services.

We may share your personal data with our insurers and our professional advisors (such as lawyers, bankers, auditors and accountants) in connection with services they provide to us.

We share personal data with Google so that we can make use of its Google Analytics product.  For more information on Google, and how you can control your settings, see

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We currently do not engage in unsolicited direct marketing (such as email or postal marketing), nor do we use targeted online advertising. We will not share your personal data with any third party for marketing purposes. If you see adverts for our services online, these will not be directed specifically at you.

If we change our marketing policy, we will update our privacy notice.  Where we are required to have your consent to market to you, we will do so.  You can object to us using your personal data for marketing purposes at any time by contacting our privacy manager by email, telephone or post.

We publish client testimonials on our website.  If you have provided a testimonial for our website, we will always ask for your consent before publishing it and we will not, unless you agree otherwise, publish your surname nor your full address (for example, a testimonial for Mr and Mrs Smith from Sevenoaks, would be published on our website as Mr and Mrs S, Sevenoaks, Kent, unless you agreed otherwise). 


A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.  Cookies contain information that is transferred to your computer’s hard drive.  We use analytical/performance cookies which allow us to recognise and count the number of visitors and to see how our visitors move around our website when they are using it.  This helps us to improve the way our website works.  We use Google Analytics for this purpose.  Google Analytics collects information anonymously and reports website trends without identifying individual visitors (by name or IP address). 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. 


We may hold copies of your personal data and other data on computers outside the European Economic Area (EEA). Sometimes we will share personal data with third parties outside the EEA.  If we do this, we will comply with the rules in the General Data Protection Regulation. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or by using one of the standard mechanisms available to us.  These may include:

  • transfer to countries that have been officially deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see
  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe (known as the “EU Model Clauses”).
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

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

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


How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will determine the period of retention based on the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Type of data

Lawful basis for processing including basis of legitimate interest

To provide the website to you

(a) Technical

Necessary for our legitimate interests (to promote our business and services via the web)

To register you as a new client and respond to your enquiry

(a) Identity

(b) Contact

(c) Enquiry

(d) Correspondence

(a) Performance of a contract with you

(b) Legitimate interests, including pursuing an opportunity to have you as a new client before (a) above applies

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking for feedback

(a) Identity

(b) Contact

(c) Enquiry

(c) Correspondence

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to ensure we provide our services on our most recently updated terms and to develop our services and grow our business)

To undertake anti-money laundering checks

(a) Identity

(b) Services

(c) Financial

(a) Necessary to comply with a legal obligation

(b) necessary for our legitimate interests (to administer our client file opening processes)

To provide our services to you and progress your matter as instructed (using personal data)

(a) Identity

(b) Services

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to ensure we provide our services on our most recently updated terms and to develop our services and grow our business)

To liaise with third parties as necessary as part of our services, as instructed by you (e.g. lawyers, estate agents, letting agents, surveyors; vendors)

(a) Identity

(b) Services

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to liaise with professionals and other third parties as necessary to progress the services we are providing to you)

To manage payments, fees and charges

(a) Identity

(b) Services

(c) Financial

(d) Transaction

Necessary for our legitimate interests (to take payment for our services)

To collect and recover money owed to us

(a) Identity

(b) Financial

(c) Transaction

Necessary in our legitimate interests (to collect money owed to us)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Enquiry

(d) Correspondence

(e) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, services, marketing, client relationships and experiences

(a) Identity

(b) Technical

(c) Tracking

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To display testimonials on our website

(a) Identity

(b) Contact

(c) Correspondence


We will retain your personal data as follows:

  • Where you are a client or you have sought to instruct us and we have undertaken anti-money laundering checks, we retain our files for six to eight years (or longer if required by law).
  • In all other cases, we retain your personal data for no longer than 2 years from the date we receive it.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. A summary of those rights is set out below. 

  • Request access to data: This enables you to receive a copy of the personal data we hold about you.
  • Request correction of data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of data: This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing: This enables you to object to processing of your personal data where we are relying on our legitimate interests (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of data: In certain cases you have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time: You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our privacy manager.

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

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

You have the right to make a complaint at any time to the Information Commissioner's Office.  The Information Commissioner's Office is the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office so please contact us in the first instance.

Want To Know More?

If you are considering using a home finder and would like to send us a brief description of what you are looking for, please use the form on our contacts page.  We will then contact you to discuss your property search and how we can be of assistance.

Get in touch