Privacy Policy

Last updated: 08.09.25

This Privacy Policy contains 10 sections. You can click on each section to see a summary and access further details by clicking “Find out more”.

1. Introduction

This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection law, Welborne Garden Village Trust Limited (WGVT) is the controller of that information.

  • WGVT (we, our or us) is committed to protecting and respecting your privacy. 

    This Privacy Policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use. Please read the following carefully. 

    WGVT is the Data Controller in relation to the processing activities described below. This means WGVT decides why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information. 

    Terms of Reference:

    ‘The/Our Website’ – WGVT’s website, hosted on the main Welborne website

    ‘The Portal’ – The portal provided by a third party property management partner of WGVT, providing our members with access to the WGVT’s property management platform. 

    This policy was last updated on the date that appears at the bottom of this page.

2. Personal information we collect about you

We receive personal information about you that you give us by your consent when you become a member of WGVT, and from your communication with our Community Development Manager during the welcome process, via application forms, home visits, your account on the Portal and general correspondence. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.

  • Personal information that you give to us

    We collect the following information from you when you join as a member of WGVT:

    • Your name and title.

    • Your contact details (email address, telephone number, postal address).

    • Any information you include in correspondence you send` to us or in forms you submit to us when using WGVT’s communication platforms, including:

      • the Website

      • correspondence via your WGVT member account on the Portal and app

      • email correspondence

    • Your identification information when exercising the rights that you have in relation to our processing of your personal information. (See section 8 Your rights in relation to your personal information.)

    If you consent to being contacted by our Community Development Manager, we also collect the following information:

    • Your contact preferences.

    • The opinions and other information you provide when responding to surveys.

    Information that we collect about you

    When you visit our Website and the Portal to access your WGVT member account, we automatically collect:

    • The internet protocol (IP) address of your device and details regarding the type of device and browser software you use to access the Website and the Portal.

    • Details of your use of our Website, namely traffic data, weblogs and statistical data, including where and when you clicked on certain parts of our Website and details of the webpage from which you visited it.

    • Details regarding when and how you consented to receive marketing communication from us (including the time and date you provided your consent), and

    • Cookie, pixels and beacon identification information. For more information please see the Cookie Policy on the main Welborne website.

3. Use of your personal information

We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive unsolicited marketing communications if you have consented, and can opt-out of receiving them at any time.

  • We use your personal information in the following ways:

    Where you have provided consent

    We may use and process your personal information for the following purposes where you have consented for us to do so:

    • To contact you via email or SMS (as you have indicated) with information about our services (see section below: Marketing communications), and

    • To process personal information we receive about you from any non-essential cookies we use. For more information please see the Cookie Policy on the main Welborne website.

    You may withdraw your consent for us to use your information in any of these ways at any time. (Please see section 8 below: Your rights in relation to your personal information.)

    Where necessary to comply with our legal obligations

    We will use your personal information to comply with our legal obligations:

    • To keep a record relating to the exercise of any of your rights relating to our processing of your personal information, and

    • To handle and resolve any complaints we receive relating to the services we provide.

    Where necessary for us to pursue a legitimate interest

    We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

    • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and deliver our services to property owners, residents and all members of WGVT.

    • Processing necessary for us to support our visitors with their enquiries and to respond to correspondence you send to us and fulfil the requests you make to us.

    • Processing necessary for us to respond to changing market conditions.

    • To undertake market analysis and research (including contacting you with surveys) so that we can better evaluate and improve our services.

    • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively, including:

      • to administer the Portal and Website

      • for the prevention of fraud and other criminal activities

      • to verify the accuracy of data that we hold about you and build a picture of our members’ appetite for community events and activities

      • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access

      • to comply with a request from you in connection with the exercise of your rights (for example, where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)

      • for the purposes of corporate restructure or reorganisation

      • for the purposes of reading and writing cookies which are strictly necessary for the operation of the Website (see the Cookie Policy on the main Welborne website)

      • for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating the records we hold about you

      • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings

      • to inform you of updates to our terms and conditions and policies, and

      • for other general administration including managing your queries, complaints or claims, and to send service messages to you

    Marketing communications:

    If you give your consent, we may use your personal information to contact you by email or SMS (as you indicate) to send you newsletters or to notify you of offers, promotions, or our services. We try to adapt any marketing material that we send to you, for example by notifying you of information, events and activities that apply to your interests and in your location. If you do not wish to receive email communications from us, please inform us by using the unsubscribe link inside the email or code within the SMS or by using the contact information at the end of this policy.

    If you opt-out of receiving marketing communications from us, we keep your email address and mobile phone number on our suppression list for a defined period to ensure that we comply with your wishes. (Please see section 7: The periods for which we retain your personal information.)

    Embedded content:

    Certain pages, features and other content may appear to be part of our Website but are in fact elements transmitted from third party websites that are not operated by us. For example, we may present videos from a third party video hosting service by framing them within pages on our Website. In some cases, it will be clear that we have incorporated third party elements, whilst in others it may not. These third party websites may use cookies to collect personal information about you when you access the content they host through this website. (For further information please refer to the Cookie Policy on the main Welborne website.)

4. Disclosure of your personal information by us

We only disclose your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.

  • As the controller of your personal information, we decide why and how it is processed. Our responsibility for that processing extends to processing by our service providers if they process your personal information based on our instructions. We may also work with other, more independent organisations in future, in connection with some of the processing activities described in this statement, such as our group of companies, and certain suppliers.

    Where that personal information is collected and sent to other organisations for a processing purpose that is in both our and their interests, or where we make decisions together in relation to that particular processing, we will be ‘joint controllers’ with the organisations involved. Where this applies, we and the other organisation will be jointly responsible to you under data protection laws for this processing. If we pass your personal information to an organisation that independently decides why and how to use your personal information, then it will be separately responsible to you for that processing and use of your personal information, in the ways described in its privacy policy (and not ours).

    We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf. Our Suppliers can be categorised as follows:

When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure. 

We may disclose the personal information to other third parties as follows:

  • If we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals or regulators.

5. Transfers of your personal information outside of Europe

We do not transfer your personal information outside of Europe. The WGVT’s property management system and the Portal is cloud-based and the data held there stored in UK based data storage units.

6. Security and links to other websites

We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to our Website may not be completely secure, so please exercise caution. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.

  • We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Website or the Portal, you are responsible for safeguarding it and keeping it confidential, and you promise to not allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.

    Our Website may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites, so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide), and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

    In addition, if you linked to our Website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

7. The periods for which we retain your personal information

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a short period, whilst for others we retain it for a period of 7 years after the information is no longer required for business reasons so that we can deal with any legal proceedings that could arise.

We retain your personal information for the following periods:

The only exceptions to the periods mentioned above are where:

• You exercise the right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see section 8: Your rights in relation to your personal information).

• You exercise your right to require us to retain your personal information for a period longer than our stated retention period (see section 8: Your rights in relation to your personal information).

• We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible.

• We archive the information, in which case we will delete it in accordance with our deletion cycle, or

• In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

8. Your rights in relation to your personal information

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.

  • You have the following rights, some of which may only apply in certain circumstances: 

    • To be informed about the processing of your personal information (this is what this statement sets out to do).

    • To have your personal information corrected if it is inaccurate and to have incomplete personal information completed. The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us using any of the details listed in section 10: Contact and legal information.

    • To object to processing of your personal information. Where we rely on our legitimate interests as the legal basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

    • To withdraw your consent to processing your personal information. Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

    • To restrict processing of your personal information. You may ask us to restrict the processing of your personal information in the following situations:

      • where you believe it is unlawful for us to do so

      • you have objected to its use and our investigation is pending, or

      • you require us to keep it in connection with legal proceedings

    • To have your personal information erased. In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

    • To request access to your personal information and information about how we process it. You have the right to ask for a copy of the information we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

    • To electronically move, copy or transfer your personal information in a standard, machine readable form. Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

    • Rights relating to automated decision making, including profiling. You have the right to contest a decision made about you based purely on automated processing. We do not currently do this and will notify you if this changes.

     To exercise these rights, please contact us using the details at the end of this policy.

    You have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (ICO) where your personal information has or is being used in a way that you believe does not comply with data protection laws. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have. The contact details for the ICO are available on the ICO website.

9. Changes to our Privacy Policy

We will email you with changes if we hold a valid email address for you.

  • We may review this policy from time to time and any changes will be notified to you by posting an updated version on our Website and/or by contacting you by email. Any changes will take effect 7 days after we post the modified terms on our Website or after the date we notify you by email. We recommend you regularly check this page for changes and reviews to this policy each time you visit our Website.

10. Contact and legal information

You can contact us with your queries in relation to this policy or for any other reason by post, email or phone.

  • To contact us in relation to this policy, including to exercise any of your rights in relation to your personal information, please contact our Data Protection Officer by post at Venta Court, 20 Jewry Street, Winchester, United Kingdom SO23 8FE or by email at privacy@welborne.co.uk.

    For anything else, including general enquires, please contact us by post at Venta Court, 20 Jewry Street, Winchester, United Kingdom SO23 8FE or by phone using a number on the ‘Contact’ page of our Website.

    WGVT’s company registration number is 12333608 and registered office address is Venta Court, 20 Jewry Street, Winchester, United Kingdom SO23 8FE.