By continuing to use this site, you agree that we may provide you with the information you have requested and that you have read and understood how we use your personal data as set out in this Privacy Policy.

This Privacy Policy explains how we collect, use, store, and protect personal data we obtain from you or about you. Please read it carefully to understand what data we collect, why we collect it, and how we use it under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Our website and services may contain links to third‑party websites that are not operated or controlled by us. We are not responsible for the content, security, or privacy practices of those independent sites, and we encourage you to review their privacy notices before providing any personal information.

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the updated version will apply from the date it is published.

Who We Are (Data Controller)

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is:

Ensum Brown, a trading name used by the following companies:

• Neil Wise Royston Ltd — Company No. 12407730
• Fraser Clemence Ltd — Company No. 14551686
• Neil Wise (Lettings) Ltd — Company No. 13719588

Registered office for all entities: Hardcastle Burton, Lake House, Market Hill, Royston, Hertfordshire, SG8 9JN

These companies are collectively referred to as “we”, “us”, or “our” throughout this Privacy Policy.

What Personal Data We Collect

The personal information we collect from you will typically include:

• Full name and contact details, including your address, email address, and telephone number.
• Identity verification information, where required by law, including to comply with the Money Laundering Regulations 2017 and the Immigration Act.
• Information about close connections, where required to assess potential conflicts of interest under regulatory obligations.
• Banking and financial details, where necessary for property sales, lettings, tenancy deposit arrangements, or rental payment processing.
• Access or accommodation requirements, where needed to help us identify suitable properties. This may include special category data, such as information relating to a disability or health condition.
• Marketing preferences and areas of interest, where you have opted to receive information about our services or similar products.
• Website usage and technical data, including cookies and analytics information. This may include:
  • URLs visited
  • Click‑through data
  • Products or pages viewed
  • Page response times
  • Download errors
  • Length of visits
  • Interaction data (scrolling, clicks, mouse‑overs)
  • Browsing behaviour and navigation paths
  • Any telephone number used to call our office Please see our Cookie Policy for further details.
• Device and technical information, including:
  • IP address
  • Browser type and version
  • Time zone settings
  • Browser plug‑ins
  • Operating system and platform
  • Device identifiers
  • Location data (where enabled on your device)
• Communications with us, including emails, telephone calls, and records of enquiries or service requests.

If You Do Not Provide Required Personal Data

Where we are required by law to collect certain personal data (for example, to comply with anti‑money laundering or fraud‑prevention obligations), or where the information is necessary for us to enter into or perform a contract with you, we may be unable to provide our services if you fail to supply the requested data. In such circumstances, we may need to cancel or suspend a service or product you have with us. We will notify you at the time if this becomes necessary.

Our Legal Bases for Processing Your Personal Data

We process your personal data under the following lawful bases set out in the UK GDPR:

• Performance of a contract — where processing is necessary to enter into or fulfil a contract with you, including providing property services, progressing a transaction, or taking steps at your request before entering into a contract.
• Consent — where you have given us clear and explicit consent for a specific purpose, such as:
• receiving electronic marketing communications; and/or
• allowing us to process special category data (e.g., health or access‑related information). You do not need to provide marketing consent in order to receive our services.

• Legitimate interests — where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms. We consider what you were told at the time of data collection, your expectations, the nature of the data, and the impact of the processing. Our legitimate interests include:
• improving and promoting our services
• understanding customer needs and behaviour
• managing and developing our business
• administering the technical operation of our website, systems, and services

• Legal obligations — where we must process your data to comply with the law, including identity verification, anti‑money laundering checks, fraud prevention, and regulatory reporting.
• Vital interests — in rare cases, where processing is necessary to protect your life or the life of another person.
• Public interest or official authority — where required for reasons of substantial public interest, though this will only apply in limited circumstances.

How We Use Your Personal Information

We will hold and use your personal data for the following purposes:

• To deliver our property services, including progressing sales, lettings, valuations, and related activities.
• To share your information with third parties, where necessary to fulfil our services or where we act as an agent on your behalf.
• To comply with legal and regulatory obligations, including identity checks, anti‑money laundering requirements, fraud prevention, and creditworthiness assessments.
• To communicate with you during the course of providing our services, including responding to enquiries and managing your instructions.
• For statistical and analytical purposes, helping us understand market trends, manage our business, and plan strategically.
• For marketing, where:
  • you have provided consent; or
  • you are an existing customer and we contact you by electronic means (email or SMS) about our own similar products or services. You can unsubscribe from marketing at any time.
• To monitor and improve our services, including tracking your use of our website and App.
• To notify you about changes to our services, policies, or terms.
• To ensure our website content is presented effectively across your devices and browser settings.

How Long We Keep Your Data

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet any legal, regulatory, accounting, or reporting requirements. Retention periods vary depending on the service we provide and may extend beyond the duration of our relationship where required by law (for example, anti‑money laundering obligations) or where necessary to establish, exercise, or defend legal claims.

Who We Share Your Information With

We may share your personal data with trusted third‑party service providers (“data processors”) who assist us in delivering our services. These may include:

• payment service providers
• property management agents
• credit reference and fraud‑prevention agencies
• cloud hosting and IT service providers
• technical support providers
• advertising and digital marketing platforms
• email marketing service providers

Where relevant to your transaction, we will also share your information with your appointed solicitors and the solicitors acting for the other party.

Other Third‑Party Disclosures

We may also disclose your personal data:

• If we sell or acquire a business or assets, in which case your personal data may be disclosed to the prospective buyer or seller.
• If our business or assets are acquired by a third party, in which case personal data held by us will be transferred as part of the assets.
• Where required by law or regulation, or to protect the rights, property, or safety of our business, our customers, or others. This includes sharing information with fraud‑prevention agencies and credit‑reference bodies.

We will never share your personal data with third parties for their own marketing purposes without your explicit consent.

Security of Your Data

Introduction

Your personal data is stored on secure servers located within the United Kingdom or in other locations that have been assessed as providing an adequate level of protection under UK data protection law. We implement appropriate technical and organisational measures to safeguard your data against unauthorised access, loss, misuse, or disclosure.

Where possible, identifiable information is encrypted or minimised. If you have been provided with login credentials to access parts of our systems, you are responsible for keeping these details confidential and must not share them with anyone.

We do not routinely transfer your personal data outside the United Kingdom. Where a transfer is necessary, we will ensure appropriate safeguards are in place in accordance with UK data protection law, such as adequacy regulations or approved standard contractual clauses.

Your Rights

Under the UK General Data Protection Regulation (UK GDPR), you have a number of important rights in relation to your personal data. These are summarised below.

Accessing and Updating Your Information (Right of Access & Rectification)

You have the right to request a copy of the personal data we hold about you (a Data Subject Access Request). You also have the right to ask us to correct or update any information that is inaccurate or incomplete.

These requests are free of charge and can be sent to us at:

Hardcastle Burton, Lake House, Market Hill, Royston, Hertfordshire, SG8 9JN

Email: enquiries@ensumbrown.com

Erasing Your Information (Right to Erasure)

You can ask us to delete or remove your personal data where:

• there is no lawful reason for us to continue processing it
• you have successfully exercised your right to object
• you withdraw consent (where consent was the lawful basis)
• we have processed your data unlawfully
• we are required to erase your data to comply with legal obligations

We may not always be able to comply with your request for specific legal or regulatory reasons. If this applies, we will explain this to you at the time of your request.

Withdrawing Your Consent

Where we rely on your consent to process your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before consent was withdrawn.

You can withdraw consent by contacting us at enquiries@ensumbrown.com or by calling 01920 412 200.

Restricting or Objecting to Processing

You have the right to:

• request that we restrict the processing of your personal data in certain circumstances
• object to our processing where we rely on legitimate interests and you believe this impacts your rights or freedoms
• object to direct marketing, including profiling for marketing purposes

In some cases, we may demonstrate that we have compelling legitimate grounds to continue processing your data. If you ask us to restrict or stop processing your data, this may affect our ability to provide services to you.

Any queries or concerns can be sent to:

Hardcastle Burton, Lake House, Market Hill, Royston, Hertfordshire, SG8 9JN Email: enquiries@ensumbrown.com

Moving Your Information (Right to Data Portability)

Where we process your data by automated means and the processing is based on your consent or on a contract, you have the right to request that we transfer your personal data to you or to another organisation.

If you would like us to move, copy, or transfer your information, please email enquiries@ensumbrown.com. We will respond within one month and will assess whether the transfer is technically feasible.

Complaints About the Use of Your Personal Data

If you have concerns about how we handle your personal data, you can contact us at:

Hardcastle Burton, Lake House, Market Hill, Royston, Hertfordshire, SG8 9JN

If you are not satisfied with our response, you have the right to lodge a complaint with the UK data protection regulator:

Information Commissioner’s Office (ICO) Website: www.ico.org.uk Telephone: 0303 123 1113