Privacy Policy
Treveth Holdings LLP is a limited liability partnership registered in England and Wales with registration number OC426719 and with its registered address at 5a Pydar House, Pydar Street, Truro, England, TR1 1XU.
The group of limited liability partnerships operating under the Treveth brand (and to whom this policy applies) is made up of different legal entities including: Treveth Holdings LLP (registered number (OC434272);Treveth Investment LLP (registered number OC440285), Treveth Development LLP (registered number OC426723), Treveth Commercial LLP (registered number OC438974), Treveth Tranche A LLP (registered number OC426722), Perran Housing LLP (registered number OC434272), and Treveth Pydar LLP (registered number OC446129), each also with its registered address at 5a Pydar House, Pydar Street, Truro, England, TR1 1XU.
Treveth Holdings LLP is responsible for this privacy policy for and on behalf of each of these group entities.
When we refer to (“Treveth”, “we”, “us” or “our”) in this privacy policy (or in our Cookie Policy), we are referring to the relevant limited liability partnership responsible for processing your data. This policy (together with our Cookie Policy) sets out the basis on which any personal data we collect from you, or that you provide to us, or that we obtain from other sources will be processed by us when you:
· use our website: www.treveth.co.uk;
· request to be added to our mailing list to receive marketing emails and updates from us;
· make contact with us to enquire about our properties or projects;
· purchase, or lease, a property from us; or
· use our services.
We are bound by applicable data protection laws in respect of the collection and handling of your personal data. We are registered as a data controller with the Information Controller’s Office (ICO) under the following registration numbers:
· Treveth Holdings LLP: ZA557802
· Perran Housing LLP: ZB230440
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1 BASIS FOR PROCESSING PERSONAL DATA
1.1 Sections 1.2 – 1.16 below explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.
1.2 To discuss potential new development opportunities: Where you are a landowner, or property owner, or other third party individual who has an interest in working with us, and you make contact with us to discuss a potential opportunity, we may process the personal data you share with us for that purpose. The legal basis on which we process your personal data in this way is our legitimate interests in having constructive conversations and dialogue with you to explore the relevant opportunity to our potential mutual benefit.
1.3 To provide information about our properties or projects: Where you make an enquiry regarding any of our current, completed or future property developments or projects, we will process your personal data to provide you, where possible, with the information you are seeking (including information about the relevant developer or estate agent from whom you can obtain further information). The legal basis on which we process your personal data in this way is the necessity for our legitimate interests to provide you with the information you are seeking about our properties or projects. If you do not wish to provide us with your personal data in this way, you will be unable to receive such services from us.
1.4 To enter into a contract with you: Where you lease or purchase a property from us, we may process your personal data in relation to any contract that we may enter into between you and us for such purposes. The legal basis on which we process your personal data in this way is the necessity to be able to enter into, and perform such a contract with you. If you do not wish to provide us with your personal data in this way, you will be unable to buy our properties from us, or use our services;
1.5 To carry out identify checks: In accordance with money laundering regulations and in order to carry out credit reference checks, we may be required to undertake checks on your identity. To do so, we will process your personal data. The legal basis on which we process your personal data in this way is the necessity for us to comply with legal obligations.
1.6 To take enforcement action: Where you occupy or vacate one of our properties without making full payment of the money owed for your period of occupancy, we may be required to process your personal data for the purposes of taking appropriate enforcement action. The legal basis on which we process your personal data in this way is the necessity for the performance of the contract we have with you, or the legitimate interests we have in securing access to, or payment for, our property.
1.7 To make our website better: We may process your personal data in order to provide you with a more tailored user experience (such as displaying information about our properties or projects and the related services which we believe you will be interested in, based on your browsing history and habits). We may also use your personal data to make sure our website is displayed in the most effective way for the device you are using. This processing means that your experience of our site will be more tailored to you, and that the information you see on our site may differ from someone accessing the same site with a different browsing history or browsing habits. We also use various cookies to help us improve our website (more details are set out in section 5), and may share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also process personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and have put in place suitable physical, electronic and managerial procedures to safeguard your personal data which we collect during your use of our website.
The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with the best customer experience we can, and to ensure that our website is kept secure.
1.8 To provide customer services to you: We may process your personal data in order to provide various supporting customer services to you (such as where you contact us by telephone or by email with a question in connection with a property or project and/or request certain information from us, such as in relation to one of our properties or projects). The legal basis on which we process your personal data in these circumstances is our respective legitimate interests in dealing with customer service requests and responding to communications to provide you with the best customer experience we can or to perform our contract with you. If you do not provide us with the personal data we request from you for customer services purposes (such as a telephone number to call you back on or an appropriate email address), we may not be able to fully answer your queries or provide you with the information you have requested.
1.9 To enable you to complete a survey: We may process your personal data in order to enable you to complete a survey regarding our properties, services or projects. The legal basis on which we process your personal data in these circumstances is our legitimate interests in collecting customer, tenant and buyer feedback and developing the services, properties and projects we (and our group) offer. In certain circumstances, we are required to collect and report on resident feedback in order to comply with a legal obligation (for example, to comply with our obligations under the Transparency, Influence and Accountability Standard (TIAS)). In these circumstances, the legal basis on which we process your personal data is the processing is necessary for compliance with a legal obligation to which we are subject.
1.10 For marketing purposes:
1.10.1 Where you expressly opted in and consented to receive marketing communications from us, we will process your personal data to provide you with information about our properties (including any upcoming home availability) or projects in line with the preferences you have selected. The legal basis on which we process your personal data is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us (please see section 13) or, where relevant, by following the unsubscribe link in every marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.
1.10.2 Where you make contact with us in a business-to-business context relating to one of our properties or projects, we may process your personal data to provide you with information about that project, or similar commercial projects. If we are not relying on the lawful basis of consent, the legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you, you can exercise your right to object to such contact from us.
1.11 In connection with recruitment activities: We may process personal data relating to you in order to respond to general or specific enquiries from you in connection with opportunities to work for us. These may have been sent by you on your own behalf, or by recruitment agents on your behalf. The legal basis on which we process your personal data in these circumstances is our legitimate interest to recruit employees and workers to grow our business.
1.12 If our business is sold: We will transfer your personal data to a third party:
1.12.1 in the event that we sell or buy any business or assets in whole or in part, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or
1.12.2 if we, or substantially all of our assets, or certain selected assets of ours, are acquired by a third party, in which case personal data held by us will be one of the assets transferred to the purchaser,
in each case, the legal basis on which we process your data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of personal data in this way, the relevant seller or buyer of our business may not be able to provide good and/or services to you.
1.13 To notify individuals of changes to our privacy policy: We may process personal data in order to update you to any changes made to our privacy policy. The legal basis on which we process personal data in these circumstances is our legitimate interest to remain transparent in our use of personal data and to ensure you are kept updated on how and why we process your personal data.
1.14 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
1.15 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
1.16 In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
2 CATEGORIES OF INFORMATION WE COLLECT ABOUT YOU
2.1 We will collect and process the following personal data in relation to you:
2.1.1 Information you give us: This is information about you that you give us when filling in forms on our website, or by corresponding with us by telephone, e-mail or otherwise. It includes information provided when you register to join our mailing list, engage with us in relation to one of our properties or projects, to receive our services, and when you report a problem with our website. The information you give us may include names, addresses, email addresses, phone numbers and date of birth. In some instances, we may request additional information from you to confirm that you satisfy necessary local connection criteria, including your workplace address and family location. We may also collect information relating to your ethnic origin in order to promote equal opportunities (see section 3).
2.1.2 Information we obtain about you: With regard to each of your visits to our website we will automatically collect the following information:
2.1.2.1 technical information (including information such as the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform); and
2.1.2.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
2.1.3 Information we receive from other sources: We may receive information about you when you use our website, or in relation to you living in, or making use of, (or in relation to any payment we may receive towards you living in or making use of) one of our properties. We work closely with third parties (including business partners, other land or property developers, estate agents, surveyors, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers) from whom we may also receive information about you.
2.1.4 We may obtain information about you (including but not limited to information pertaining to your name and/or current address) from a publicly accessible source if you vacate one of our properties without making full payment of the rent owed for your period of occupancy. In such circumstances, this information will be shared with appropriate third parties (such as specialist tracing service providers, business partners and/or estate agents) to find you for the purpose of obtaining the unpaid rent.
2.2 We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate tenants' survey responses to calculate our overall performance scores.
3 SPECIAL CATEGORIES OF PERSONAL DATA
3.1 We may process special category personal data pertaining to your racial or ethnic origin. We only do this as part of our shared ownership application process in order to promote equal opportunities for applicants. The legal basis on which we process such special category personal data is with your explicit consent, or on the basis that it is necessary for reasons of substantial public interest, on the basis of preventing discrimination in accordance with applicable domestic law (such as equality law). You are not under any obligation to provide us with such special category personal data for this purpose, and if you provide your explicit consent, you can withdraw your consent to this personal data being processed in this way at any time by contacting us (please see section 13). If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.
3.2 Other than set out in section 3.1, we do not process any special categories of personal data, meaning personal data revealing:
3.2.1 racial or ethnic origin;
3.2.2 political opinions; religious or philosophical beliefs or trade union membership;
3.2.3 genetic or biometric data that uniquely identifies you; or
3.2.4 data concerning your health, sex life or sexual orientation.
3.3 We do not collect data relating to criminal convictions or offences or related security measures.
4 CATEGORIES OF RECIPIENTS OF PERSONAL DATA
4.1 For the purposes set out in section 1, your personal data may be shared by us with certain third parties, including:
4.1.1 Internal third parties being other partnerships within our group who are based in the UK;
4.1.2 external third parties including but not limited to the local authorities, housing associations, and other developers we work with in relation to our properties or projects, or with choice-based letting scheme and deposit rental scheme providers we work with to help you find a property most suitable for you, or with estate agents responsible for showing you our properties or projects; or service providers who provide information technology, system administration and security services; or professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting insurance and services;
4.1.3 specific third parties, such as MailChimp, a marketing automation platform based in the USA and who provide us with products and services that help us to run our email marketing programmes; and
4.1.4 other third parties we may choose to sell, transfer, or merge parts of our business or our assets.
4.2 Third-party marketing – we will not share our personal data with any other developer other than Treveth, or any third party estate agent, for marketing purposes without first obtaining your express consent to do so.
4.3 The details in this privacy policy relating to third parties are for your information only. We are not responsible for the privacy policies or practices of third party recipients of your personal data. Where third parties are recipients of your personal data from us, please read any information those third parties provide you about how, why and the legal basis for, their processing of your personal data and make your own enquiries in respect of them.
5 COOKIES
5.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse the website, users are agreeing to our use of cookies in accordance with our Cookie Policy.
6 USES MADE OF THE INFORMATION
6.1 We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6.2 The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7 WHERE WE STORE PERSONAL DATA
7.1 Except where we make use of MailChimp's services in the USA for our email marketing programmes, the data that we collect from you will be stored in (and will not be transferred out of) the United Kingdom. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. In particular, any transfer of your personal data made by us to a location outside of the United Kingdom will be conducted in accordance with applicable data protection laws.
7.2 All information you provide to us is stored on secure servers.
8 PERIOD OF STORAGE
8.1 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.
8.2 To determine the appropriate retention period for personal data, we consider 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.
8.3 Where you purchase one of our residential properties through the estate agent appointed by us when that property first comes on to the market, we will generally retain your personal data for a period of the earlier of: (a) no less than 11 (eleven) years after the property was purchased by you as new properties that we develop come with a 10-year new build home warranty, and (b) seven (7) years after the date on which you sell and leave the property (if you do so within the 10-year new build home warranty period), to ensure that that we are able to assist you should you have any questions or feedback in relation to the property or to protect, or to defend our legal rights.
8.4 Other than as set out in section 8.3, where you purchase one of our residential properties during the period of that property's 10-year new build home warranty, and where we have been provided with your personal data, we will retain our personal data for the period of the earlier of: (a) the remaining time on the warranty period for that property and one (1) year thereafter, and (b) seven (7) years after the date on which you sell and leave the property (if you do so within the 10-year new build home warranty period), to ensure that that we are able to assist you should you have any questions or feedback in relation to the property, or to protect or to defend our legal rights.
8.5 Where you lease a residential property from us, or your personal data is used in a lease or a contract for the purchase of a commercial property from us, we will generally retain your personal data for the duration of the relevant lease or contract, and seven (7) years thereafter, to ensure that that we are able to assist you should you have any questions or feedback in relation to your lease, or to protect or to defend our legal rights.
8.6 Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our lists.
8.7 Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with one of our properties or a project, subject to sections 8.3, 8.4 and 8.5, we will retain your data for twelve (12) months.
9 YOUR RIGHT TO OBJECT UNDER DATA PROTECTION LAWS
9.1 You have the right to object to us processing your personal data where we are processing personal data:
9.1.1 based on our legitimate interests (as set out at sections 1.2 to 1.9 inclusive and 1.11 to 1.13 inclusive above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
9.1.2 for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
In each case please do so by making contact with us directly (please see section 13).
10 YOUR OTHER RIGHTS UNDER DATA PROTECTION LAWS
Right of access
10.1 You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. You can exercise this right by making contact with us directly (please see section 13). 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.
Right to rectification
10.2 You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
Right to restriction
10.3 You have the right to restrict our processing of your personal data where:
10.3.1 the accuracy of the personal data is being contested by you;
10.3.2 the processing by us of your personal data is unlawful, but you
do not want the relevant personal data erased;
10.3.3 we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or
10.3.4 we are processing your data on the basis of our legitimate interest (as set out at sections 1.2 to 1.9 inclusive and 1.11 to 1.13 inclusive above) and you:
10.3.4.1 object to our processing on the basis of our legitimate interest under section 9.1.1 above; and
10.3.4.2 want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides their legitimate interest.
10.4 Where any exercise by you of your right to restriction determines that our processing of particular personal data are to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
Right to data portability
10.5 You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.
Right to erasure
10.6 You have the right to require we erase your personal data which we are processing where one of the following grounds applies:
10.6.1 the processing is no longer necessary in relation to the purposes for which your personal data was collected or otherwise processed;
10.6.2 our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;
10.6.3 you object to the processing in your personal data as set out in section 9.1.1 above and we have no overriding legitimate interest for our processing;
10.6.4 the personal data have been unlawfully processed; and
10.6.5 the erasure is required for compliance with a law to which we are subject.
10.7 You have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales.
10.8 Exercising your rights: You can exercise your rights by making contact with us directly (please see section 13).
11 LINKS ON OUR WEBSITE
Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects you to different websites. If you follow a link to any of these websites or use our service, please note that you have left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before submitting any personal data to these websites.
12 CHANGES TO OUR PRIVACY POLICY
Any changes we make to our privacy policy in the future will be posted on this webpage and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
13 CONTACT
Questions, comments and requests regarding this privacy policy are welcomed.
You can contact us by writing to our Data Protection Officer at [email protected].
This privacy policy was last updated on 12th June 2025.