- Important information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- Data security
- Data retention
- Where we store your personal information
- Your legal rights
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Name: Coen Geesing
Email address: firstname.lastname@example.org
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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- “Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- “Contact Data” includes billing address, delivery address, email address and telephone numbers.
- “Financial Data” includes bank account and payment card details.
- “Transaction Data” includes details about payments to and from you and other details of services you have purchased from us.
- “Technical Data” includes internet protocol (IP) address, your login data, 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 this website.
- “Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences.
- “Usage Data” includes information about how you use our site and services.
- “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
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, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our site;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Google and Linkedin based outside the EU; and
(c) search information providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal and Stripe based outside the EU.
- Identity and Contact Data from data brokers or aggregators such as Zoominfo and Discoverorg based outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 register you as a new site user||
|Performance of a contract with you|
|To process and deliver our services||
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) asking you to leave a review or take a survey
(d) Marketing and Communications
(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 to study how customers use our services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our site, services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our services and grow our business)|
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted-out of receiving marketing communication.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the site and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
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 at email@example.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; or
- analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms set out herein; or terms of business use for the Service Providers; or terms of business for the clients; or to protect our rights, property, safety or of our customers, or others.
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contacting firstname.lastname@example.org.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help us provide you with a better site, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
All Cookies used by and on the Site are used in accordance with the Data Protection Legislation. We may use some or all of the following types of Cookie:
- Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of the site, supporting functions such as logging in, your shopping basket, and payment transactions.
- Analytics Cookies
It is important for us to understand how you use the site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve the site and your experience of it.
- Functionality Cookies
Functionality Cookies enable us to provide additional functions to you on the site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
- Targeting Cookies
It is important for us to know when and how often you visit the site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make the site and advertising more relevant to your interests.
- Third Party Cookies
Third party Cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on the site, or by third parties providing analytics services to us (these Cookies will work in the same way as analytics Cookies described above).
- Persistent Cookies
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit the site.
- Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the site until you close your browser. Session Cookies are deleted when you close your browser.
We may use the following Cookies:
|Name of Cookie||Purpose & Type||Strictly Necessary|
|_ga||Used to distinguish users.||Yes|
|_gid||Used to distinguish users.||No|
Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
Used to throttle request rate.
Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.
- Where we store your personal information
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and will ensure that any third party receiving your personal data adopts such appropriate measures necessary to safeguard your personal data.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
We use Amazon Cloud for the purpose of storing personal data. Amazon Cloud servers may be located in the US or anywhere else in the world.
Amazon is responsible for security of its Cloud Server. Amazon implements security measures that we will implement and operate. At all times we remain responsible for security of the personal data stored in the Cloud Server.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Your legal rights
Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal information.
- right to rectification
if your personal information is incorrect or incomplete any way, you may notify a person dealing with your matter and where inaccurate or incomplete, we will correct it without delay.
- right of access
- you may request a confirmation from us that we are processing your personal information;
- access your personal information held by us and request a copy (unless providing a copy adversely affects the rights and freedoms of others);
- obtain certain information about how we process your personal information, categories of personal information processed, recipients or categories of recipients who receive personal information from us; and
- how long we store your personal information for and the criteria we use to determine retention periods.
- right to be informed
- how your personal information is being process;
- how long it will be stored for;
- the legal basis for processing;
- recipients (or categories of recipients) of your personal information; and
- whether personal information must be provided under statute or for another reason and the consequences of not providing the personal information to ensure the fair and transparent processing of your personal information.
- right to restrict processing under certain circumstances
- if you contest the accuracy of your personal information, we may restrict its processing, until we can verify its accuracy;
- if the processing is unlawful;
- if we no longer need to process your personal information, unless we still need your personal information for the establishment, exercise, or defence of legal claims; and
- if you object to processing that relies on public interest or our (or third party’s) legitimate interest as the lawful processing ground.
- right to data portability
- right to receive from us a copy of your personal information in commonly used and machine-readable format and store it for further use on a private devise; and
- right to transmit personal information to another third party; or have your personal information transmitted directly from one third party to another where technically possible.
- right not to be subject of automated processing
right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you. This does not apply when the automated decision is necessary for entering into or performing a contract with you; or it is authorised by EU or member state law applicable to us if the law requires suitable measures to safeguard your rights and freedoms and legitimate interests; or based on your explicit consent.
- the right to object to processing
you may object to direct marketing, including profiling related to direct marketing. We will stop processing your personal information once notified by you, except if we can demonstrate a compelling legitimate ground for processing the personal information that overrides your request; or processing is necessary to exercise or defend legal claims.
If you wish to exercise any of the rights set out above, please contact email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
“Clients” means the clients of the Company from time to time accessing and browsing the site from time to time, whether pursuant to a registration or not.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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 at firstname.lastname@example.org.
“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Service Provider” means any real estate service provider who accesses and browses the site, whether pursuant to registration or not in the course of business for the purposes of providing real estate services to the Clients.
“External third parties” means:
- service providers acting as processors based in the United Kingdom who provide reals estate services;
- cloud service providers essential for our business;
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; and
- HM Revenue & Customs, acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.