Number One Real Estate Privacy Statement
Effective Date: 1 June 2020
This Privacy Policy describes how we collect, use, disclose, and otherwise process the personal information described in this Privacy Policy, as well as the rights and choices individuals have regarding such personal information. This Privacy Policy applies to the extent we process personal data on our own behalf, as a controller or business. Number One Real Estate are committed to privacy and to transparency in our information practices.
SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to disclosure, and other processing of personal information related to:
- Former, current, and prospective clients, independent agents, and customers.
- Other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services or our business.
- Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This Privacy Policy is intended to describe our overall privacy and data protection practices.
COLLECTION OF PERSONAL INFORMATION
We collect personal information when you voluntarily provide it. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services, or we may be unable to fully respond to your inquiry.
We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use). In some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Information we collect directly – we collect information that you provide to us, such as:
- When you create an account, provide contact information, or send other personal information to us.
- When you complete or submit a form or request through our Services, for example, “Contact Us” or other methods.
- When you participate in surveys, submit requests, or register for or use our Services, or otherwise contact us.
- Information you submit or provide such as property searches and preferences, whether you plan on buying or selling property, home search criteria, information about financing for the purchase of a property, and other information related to a purchase or sale.
Information we collect from third parties. We may collect or receive personal information about you and your property from third party sources, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), affiliated agents, and other property professionals, and third parties, for example:
Social media – If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.
Property professionals – If you interact or list a property with an independent agent, or other property professionals, we may receive personal information about you and your property from them, such as your name and property address, listing and contact information, among other things. These property professionals may be affiliated with independently owned, or under the Number One Real Estate Brand.
Property records – we may collect information about individuals and property through public databases, such as Land Registry.
PURPOSES AND LEGAL BASIS FOR OUR PROCESSING
Performance of contract – as necessary to enter or carry out the performance of our contract with you.
Compliance with laws – for compliance with legal obligations
Our legitimate interests – in furtherance of our legitimate business interests including, for example:
- Customer relationship management and improving our Services, including marketing and analytics.
- Marketing and advertising.
- Fraud prevention, including money laundering.
- With your consent: in some cases, we rely on your consent to collect and process your personal information.
- In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes of processing. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we collect, use, disclose and otherwise process personal information for the purposes set forth below, as well as the legal basis for such processing, as applicable under relevant laws (see above for further explanation of these legal bases):
Providing support and services: including, for example, to send or facilitate communications among you, independent property professionals, and other users of the Services, provide products and services you request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries, fulfil your requests and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
Analysing and improving our business – including to better understand how users’ access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys, and other evaluations, such as customer satisfaction surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests)
Personalising content and experiences – including to provide or recommend features, content, social connections, and referrals; tailor content we send or display on our Services; to offer location customisation and personalised help and instructions; and to otherwise personalise your experiences. (Legal basis: our legitimate interests and/or with your consent)
Advertising, marketing and promotional purposes – including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions. (Legal basis: our legitimate interests and/or with your consent)
Securing and protecting our business – including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate interests and/or compliance with laws)
Defending our legal rights – including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate interests and/or compliance with laws)
Planning and facilitating business transactions – related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate interests and/or compliance with laws)
Auditing, reporting, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; and our general business, accounting, record keeping and legal functions. (Legal basis: our legitimate interests and/or compliance with laws)
Complying with legal obligations: including to comply with the law, our legal obligations and legal process, regulatory requests. (Legal basis: our legitimate interests and/or compliance with laws)
DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect to third parties, as reasonably necessary for the purposes described above and as otherwise directed or consented to by you, including:
Service providers – to third-party service providers who use this information to perform services for us, such as solicitors and financial advisors.
Subsidiaries and affiliates– to our subsidiary and affiliated companies, such as Number One Property Management. Where required by applicable law, we will obtain your consent to such sharing.
Third parties: to third parties in order to provide our Services, respond to or carry out your requests, and/or with your consent, including to:
- Property sale: as part of any actual or contemplated sale, prior to the completion of sale, where necessary for due diligence, such as to lenders, third-party advisors, solicitors and financial consultants, where permitted by law.
- Legally required: where we are required to do so by law or legal process (e.g., to law enforcement, courts or others, or in response to a subpoena or court order).
- Protect our rights: where we believe it necessary to respond to claims asserted against us or comply with legal process, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers. Including personal information, related to legal action, claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
COOKIES, TRACKING, AND ANALYTICS
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associated with your usage of and activities on our Services.
We use the information for security purposes, to facilitate navigation, to improve, analyse and optimize our Services and their functionality, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns, and to better reach users with relevant advertising both on our Services and on third party websites.
Third party analytics tools. Our websites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyse information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices and opt-out of collection of your browsing data by Google Analytics at https://tools.google.com/dlpage/gaoptout.
SOCIAL FEATURES AND THIRD-PARTY PLUG INS
The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
DATA RETENTION
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients’ instructions.
YOUR RIGHTS AND CHOICES
We provide several ways for you to exercise certain privacy choices regarding your personal information processed by us, as described in this section. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us.
Marketing – you may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Cookies preferences – to review and update your preferences for most types of cookies (other than those that are necessary) for one of our Websites, Click “Cookie Preferences” link in the footer of that Website.
Deactivation – you can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfil this request.
Access, amendment and deletion – under applicable privacy laws, you may have the right to request to review, make amendments, have deleted or otherwise exercise your rights over your personal information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:
By submitting an email request to helen.west@numberonerealestate.co.uk or by calling us on 01633 492777
We will process in accordance with and where required by applicable law, and with respect to your personal information that is linked or linkable to the email that you use to send us your request and the verifiable information provided by you as a part of your request. We will take steps to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
THIRD-PARTY WEBSITES
The Services may contain links to third-party services. We do not own, operate, or control the websites of third parties, including those of independently owned and operated franchisees. Accordingly, this Privacy Policy does not apply to any services maintained or operated by third-parties. When you click on those links, you will go to a third-party website where you will be subject to that service’s privacy policy or similar statement and terms of use, and we encourage you to read that policy statement. We are not responsible for the privacy practices of other services, and we expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal information by those third parties.
GDPR
The GDPR and UK data protection laws (where applicable), gives data subjects the following rights regarding their personal information:
Right of access –you have the right to obtain from us confirmation as to whether or not personal information concerning you is being processed, and where that is the case, to request access to the personal information. The accessed information includes – among others – the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal information have been or will be disclosed. You have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectify and complete personal information – you can request the rectification of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if we are legally obliged to do so.
Right to erasure (right to be forgotten) – you have the right to obtain from us the erasure of personal information concerning you in limited circumstances where:
- it is no longer needed for the purposes for which it was collected.
- you have withdrawn your consent (where the data processing was based on consent).
- following a successful right to object.
- it has been processed unlawfully; or
- the data has to be erased in order to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation, or the establishment, exercise or defence of legal claims.
Right to restriction of processing: You have the right to obtain from us restriction of processing your personal information. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised, subject to certain limitations, where: (i) the accuracy of your personal information is contested; (ii) the processing is unlawful, but you do not want the personal information erased; (iii) it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or (iv) you have exercised the right to object, and verification of overriding grounds is pending.
Right to data portability: You have the right to receive the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us, but in each case only where the processing is (a) based on your consent or on the performance of a contract with you, and (b) also carried out by automated means.
Right to object: You have the right to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Right to withdraw consent: if you have given us your consent for the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to object to our use of your personal information for direct marketing: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
You may submit your GDPR request to us via: helen.west@numberonerealestate.co.uk
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Services. Any material changes to this Privacy Policy will be effective 10 days after our posting of the updated Privacy Policy or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy
CONTACT US
If you have any questions or concerns about this Notice, please use the following contact information:
Helen.west@numberonerealestate.co.uk
Address: 76 Bridge Street, Newport, NP20 4AQ
Phone number: 01633 492777
