Property Collection – Privacy Policy
1. Important information and who we are
Purpose of this privacy notice
Name of data privacy manager: Claire Cook
Email address: claire.cook@property-collection.co.uk
Postal address: The Property Collection, Tinwell Business Park, Steadfold Lane, Stamford PE9 3UN
We also operate the website at www.property-collection.co.uk
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Processor
Please note that much of the personal data we process is provided to us by the estate agents to whom we provide our services/products. We process this data on the estate agent’s behalf for the purpose of performing our contract with them. We use this personal data to send information, web-based tools, and other products on the estate agent’s behalf to the estate agent’s customers. We refer to this data as “Third Party Personal Data”.
We process Third Party Personal Data as a data processor on behalf of our estate agent clients (who will be the data controller in these circumstances). Where we process Third Party Personal Data as a data processor we do so strictly in accordance with our contractual obligations to the relevant data controller (i.e. the estate agent), and in accordance with the legal requirements upon data processors. Note that the lawful basis on which we process Third Party Personal Data (for the purposes of performing our contract with the estate agent) may be different from the lawful basis on which the estate agent processes that personal data (which may be on the basis of consent, or some other basis).
Where we are acting as a data processor, we do not use or engage sub-processors of personal data, without the relevant data controller’s prior authorisation. Furthermore we will, upon the relevant data controller’s direction, either return to them or destroy the Third Party Personal Data we have processed on their behalf, at the end of our contractual relationship with them.
Generally, however, this privacy policy deals with the personal data that you may give to us direct, and in respect of which we are the data controller (rather than the Third Party Personal Data provided to us by our estate agency clients).
Changes to the privacy notice and your duty to inform us of changes
We reserve the right to make changes to this privacy notice at any time.
2. The data we collect about you
· Identity Data includes first name, last name and title.
· Contact Data includes home address, email address and telephone numbers.
· Financial Data includes bank account and payment card details, and details about payments to and from you.
· Transaction Data includes details of services/products you have purchased or otherwise received from us.
· Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
· Marketing and Profile Data includes your preferences in receiving marketing from us and your communication preferences, your interests, feedback and survey responses.
We may 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. 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 collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
Please also note that we do not knowingly collect data relating to children.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or to provide you with services/products you have requested, and you fail to provide that data when requested, we may not be able to perform the contract we have or to provide you with the services/products you have requested from us. In this case, we may have to cancel the contract in question that you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your data by corresponding with us by post, phone, email or otherwise. This includes for example personal data you provide when you complete a registration form or complete an enquiry form on our website.
· Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. This includes for example Technical Data from analytics providers such as Google, and Financial and Transaction Data from providers of technical, payment and other services.
· Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns by using cookies, and other similar technologies.
4. How we use your personal data
· Where we need to perform the contract we are about to enter into or have entered into with 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.
· Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for
processing including basis of legitimate interest |
To process and deliver any contract you have with us |
(a) Identity (b) Contact (c) Transaction (d) Technical (e) Financial |
Performance of a contract with you |
To recover costs due to us |
(a) Identity (b) Contact (c) Transaction (d) Financial |
Necessary for our legitimate interests (in respect of recovering monies or debts due to us) |
To respond to enquiries or requests from you, and communicate with you in relation to those enquiries or requests |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Profile |
Necessary for our legitimate interests (response to enquiries or requests) |
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy, and to enable you to give feedback or complete a survey |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Profile |
(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 and the administration and management of our business, and to study how customers use our products/services, to develop them and grow our business) |
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) Technical (e) Transaction |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network, premises and asset 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, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Marketing and Profile |
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services/products that may be of interest to you |
(a) Identity (b) Contact (c) Transaction (d) Technical (e) Marketing
and Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We will not share your personal data with any third party for marketing purposes.
Our Website - Third-party links
Software & System Providers including but not
limited to;
BriefYourMarket, Reapit Software, Sage, Iam-Sold and The Property Collection
Website Hosts and analytics platform providers
including but limited to;
The Property Collection, BriefYourMarket and Google Analytics
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.
5. Disclosures of your personal data
· Service providers who provide services to us, including; (i) IT service providers (in particular for systems maintenance and Cloud database provision); (ii) Bailiffs and debt collection agencies; and (iii) Payment processing service providers.
· Professional advisers including bankers, lawyers, accountants and insurers who provide banking, consultancy, legal, insurance and accounting services.
· HM Revenue & Customs and other authorities who may require reporting of processing activities in certain circumstances.
· 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 share your personal
data within the Rackspace Group (who provide cloud
database services). This will involve transferring your data outside the
European Economic Area (EEA) to the USA. Rackspace
are part of the Privacy Shield programme, which requires them to provide
similar protection to personal data shared between Europe and the US.
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.
How long will you use my personal data for?
We keep personal data relating to suppliers for longer, as it is in both our interests and theirs that they remain on our system.
In some circumstances you can ask us to delete your data: see below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the further information towards the bottom of this privacy policy. If you wish to exercise any of these rights, please contact our data privacy manager.
10. Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.