1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of our Site;
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and here.
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our site is operated by Complete Moves Sales Limited, a company operating in the United Kingdom.
Trading address: 91 Wimpole Street, London W1G 0EF
Email address: email@example.com
Telephone number: 020 3640 7111
Postal Address: 91 Wimpole Street, London W1G 0EF
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
• Property Address
• Proof of ID and Land Reg
• Date of Birth
• Email address;
• Telephone number;
• Business name;
• Job title;
• Payment information;
• Information about your preferences and interests;
• IP address;
• Web browser type and version;
• Operating system;
• The pages you use on our site;
• The source of your visit to our site;
• The activity you engage in on our site;
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for the performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for [one of] the following purposes:
• Providing and managing your Account;
• Providing and managing your access to our Site;
• Personalising and tailoring your experience on our site;
• Supplying our products AND/OR services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products AND/OR services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time.
• Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam.
We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
• The following automated decision-making method(s) may be used:
o Anti Money Laundering checks, Credit Checks, ID Checks
o Marketing automation processes, used to influence the types of marketing content we sent you.
• The following automated profiling may take place:
o Lead scoring processes, either by consent or legitimate interest, to decide how likely you are to purchase products or services from us
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• A period of 12 months, unless we need to process your data for longer in order to service your account or send marketing content based on consent;
9. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
And where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
10. Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain products AND/OR services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
• Partners in Payment Processing
• Partners in Mortgage Services
• Partners in IT/Hosting/Web Development
• Partners in Local Property Consulting
• Partners in HR/Office/Sales/General Business Processing
• Partners in Estate Agency and Marketing (Pattinson and Brief Your Market)
If you would like more details on the Partners we use to deliver our services, please email us at firstname.lastname@example.org (only Partners trading names can be provided).
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details and by managing your Account).
11.1 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Compliance):
Email address: email@example.com
Telephone number: 020 3640 7111
Postal Address: 91 Wimpole Street, London W1G 0EF
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.