Privacy Policy

CONSUMER PRIVACY POLICY 2021

WHO WE ARE:

This Privacy Policy covers Seek and Buy Ltd any of Our subsidiary companies under Section 1159 Companies Act 2006 (referred to as “We” or “Us” or “Our” or “Seek and Buy”). Seek and Buy LTD (company number 4848951) registered address is Hereward Offices, Cherry Holt Road, Bourne. Lincolnshire PE10, VAT number is 844522235.

We are the providers of the Seek and Buy the website www.Seek and Buy.co.uk, (referred to as the “Site”) and any other Services We may operate in the future.

“Partners” include estate agents, commercial agents, letting agents, managing agents, landlords, new homes developers, housing associations, overseas property owners, surveyors, currency service providers, banks, building societies, insurance companies, other lenders and financial institutions, Government departments, executive agencies, and quangos.

We provide Our Website so that:

We can advertise property details for You to view

We, or Our Partners, can provide services to You.

References to “Users”, “You” or “Your” is a reference to individuals using Our Website or Services.

References to “Personal Information” means information that will allow Us to identify You and is set out in more detail in the “What We collect” sections below.

INTRODUCTION

We are committed to protecting Your privacy. This privacy policy (referred to as the “Policy”) explains how and for what purposes We use the Personal Information collected about You when You use the Site, please read this Policy carefully.

In the information below We set out the types of Personal Information We collect, where it comes from, why We collect it, Our lawful basis for processing the Personal Information and how long We will keep it for.

Our Website is not intended for children.

If You have a query about Personal Information, please contact Us alan@sandbpropertiesdirect.com.

CONTACTING US

If You would like to stop receiving direct marketing and communications from Us please contact Us via email at alan@sandbpropertiesdirect.com or please write to the Customer Services Team at Hereward offices, Cherry Holt Road, Bourne, Lincolnshire. PE10 9LA and where possible include a copy of the communications You have received.

If You have any questions about this Policy or Our use of Your Personal Information or would like to submit a subject access request or exercise Your other data subject rights, please contact Our Data Protection Officer Alan via email at alan@sandbpropertiesdirect.com or please write to The Data Protection Officer, Hereward offices, Cherry Holt Road, Bourne, Lincolnshire. PE10 9LA.

PROPERTIES ADVERTISED ON OUR WEBSITE

What We collect and where it comes from

In the course of providing Our services, We collect property data such as images of properties, including videos and virtual tours, property asking prices, sales history and sold prices, property addresses, property locations and property descriptions.

The property data is provided to Us by Our Partners or other third parties on behalf of those Partners.

Why We collect it

We will use this information for a number of reasons including:

• To provide Our Website.
• To enable Our Partners to advertise their properties to the largest online audience available.
• To enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in.
• For Our own commercial purposes such as to identify trends in the property market and to build property databases as well as automated survey and valuation tools for Our Partners to use.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:

• Providing a service to Our Partners by helping them to market properties and understand changing market dynamics and evolving trends.
• Providing a service to Our Partners by advertising properties to potential purchasers or tenants.
• Providing a service to potential purchasers and tenants so that they know what properties are currently on the market and the price of those properties.

How long We will keep it for

We will stop advertising a property when We are instructed to do so by Our Partners.

PERSONAL INFORMATION YOU GIVE TO US

What We collect and where it comes from

We will collect the Personal Information that You give to Us when using Our Services:

Enquiries to Our Partners:

If you choose to access a particular search feature, request information, or fill in a form on the Website You may be asked to provide Personal Information about yourself, such as:

• Your name, address and contact details;
• details of the sort of property You are interested in;
• the cost and location of the property; and
• Your current residential address.

If you choose to book an appointment to view a property via the Website, You may be asked to provide more details, including:

• Your availability to view the property;
• Your preferred moving date;
  details of Your household income as a proxy for calculating affordability in relation to the advertised monthly rental value of a property;
• an indication of whether You are moving alone or with others; and
• Your feedback on a property that You have viewed.

If You choose to contact us using the telephone number on Our Website, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.

Registered Users and Property Alerts:

Personal Information that You provide to Us when You register as a User and/or request property email updates such as Property Alerts about when a property is marketed in Your chosen area and meeting Your search parameters;

General Use of the Website:

• Personal Information that You provide when using Our Website
• Personal Information that You provide when participating in discussion boards or other social media functions on Our Website;
• Entering into competitions, promotions or surveys available on Our Website; and
• Personal Information that You provide when engaging with additional Services that are available on Our Website, such as the Mortgage Calculator.

Communications:

Personal Information that You provide by corresponding with Us by phone, e-mail, video calls or otherwise;

If You choose to contact Us by phone or video calls or We call You, calls may be recorded for training, monitoring and quality assurance purposes. Phone calls may be monitored in real time. We may also keep a record of call activity, including missed calls.

Enquiries to Our Partners:

To make sure that You receive the benefit of the Service. This may include:

• transferring Your property enquiry to Our Partner who is advertising that property so that they can respond to Your enquiry. Some of Our Partners may use lead handling agencies who handle and process Your enquiry on their behalf; or
• sending Your request to book a property viewing to Our Partner who is advertising that property and for Us to confirm Your booking by email or text on Our Partner’s behalf;
• sending Your name, address and contact details to Our Partner when You request information or a brochure on a property they are advertising, so that they can contact You;
• transferring other relevant information to Our Partner so that they can assess whether the property is suitable for You;
  enabling Us to send You a link to access an online viewing of the property You have enquired about; and
• allowing You to provide Our Partner with feedback on the property once You have viewed it.
• For training and monitoring purposes where calls are recorded.
• To profile Your lead activity on Our Website or telephone calls to Our Partners for monitoring and training purposes and to enhance the service You receive from Our Partners. If You want to know more about this, see the “Lead Profiling” section below.

Registered Users and Property Alerts:

• To provide You with the benefit of Services for registered Users only.
• To provide Property Alerts to You for properties marketed on Our Website that meet Your search criteria.
• General Use of the Website:
• To provide the Website to You and enable You to download the App.
• To enhance the Services that You select on Our Website.
• To process any queries that You have about Seek and Buy or its Partners.
• To customise and enrich Your experience on Our Website.
• To contact You for Your views on Our services and to notify You occasionally about important changes to Our Terms of Use or this Policy or developments to Our Website or Services.
• To deliver relevant advertising to You whilst You are on the Website.

Communications:

• To process and resolve any queries that You may have.
• For training, monitoring and quality assurance purposes where calls (which may include video calls) are recorded.
• To allow You to subscribe for relevant Seek and Buy alerts.
• To process and respond to any queries that You might have.

Our lawful basis for processing this Personal Information

We have a legitimate business interest to process this Personal Information. These legitimate interests are:

• Enquiries to Our Partners: To provide a service to Our Partners and/or to provide a service to You.
• Registered User and Property Alerts: To provide You with Our services.
• General Use of the Website: To enable you to gain information about the use of Our Website and any improvements that can be made as well as providing advertising space to Our Partners and third parties.
• Communications: To ensure that Your queries are addressed and for training, monitoring and quality assurance purposes where calls (which may include video calls) are recorded.
• We have a contractual reason to process this Personal Information:

How long We will keep it for

We will store the Personal Information summarised above for the following periods:

Enquiries to Our Partners:

• All enquiry data will be kept for two years from the date on which You last used Our Website or Our Services. After that it will be erased or anonymised so that the data no longer identifies You.
• Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted.
• Profiling data will be kept for a shorter time period, as described in “Lead Profiling” below.

Registered Users and Property Alerts:

• Personal Information that You provide to Us when You register as a User will be kept for as long as You have an active registration with Seek and Buy.
• The Personal Information relating to Your account will be deleted when You delete Your account or if Your account has been inactive for 5 years (from May 2018), whichever is earlier.

General Use of the Website:

• Personal Information that You provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years.
• Personal Information that is provided when You interact with Us through social media functions will only be retained on the social media Website which You use to contact Us. We will not copy or store it separately. This Personal Information will be retained for as long as You keep it on Your social media accounts.

Communications:

• Personal Information that You provide to Us when We correspond by telephone or e-mail will be retained:
• for the later of 18 months from the date of communication or until Your query is resolved. The only exception to this is the original e-mail correspondence which may be retained for 2 years; or

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:

• Enhancing the service that You receive on Our Website.
• Providing a service to Our Partners so they can respond to enquiries.
• Providing information necessary to enable Us to provide a competitive, cost-effective service.

How long We will keep it for

We will store this Personal Information for two years from the date on which You last used Our Website or Services at which point it will be erased or anonymised so that the data no longer identifies You.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

What We collect and where it comes from

This is different to “Personal Information You give to Us” because it relates to technical data that We collect. We may:

• Collect technical information that has the potential to identify You, including the type of Device You use, a unique identifier (for example, Your Device’s IMEI number), the internet protocol (IP) used to connect Your computer to the internet, the MAC address of the Device’s wireless network interface, or the mobile phone number, Your login by the Device, mobile network information, Your Device operating system, the type of browser You use on Your Device and its time zone setting, the browser plug-in types and versions, operating system and platform; browser type and version and Your login data.
• Collect Personal Information about Your visit to Our Website, including the full uniform resource locators (URL) clickstream to, through and from Our Website (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and how You use Our Website, products or Services.
• Combine technical information with other information that We have about You to help Us with Our processing of Your Personal Information as set out in this Policy.

Why We collect it

We will use the information summarised above:

• To provide Our Website to You.
• To customise and enrich Your experience on Our Website.
• To deliver relevant content and advertisements to You on Our Website and measure or understand the effectiveness of the advertising We serve to You.
• To use data analytics to improve Our Website, Services, marketing, customer relationships and experiences.
• To conduct reviews that assist Us in the improvement and optimisation of Our Website.
• To ensure that content from Our Website is presented in the most effective manner for You and for Your device.
• As part of Our efforts to keep Our Website safe and secure.
• To administer Our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To respond to and deal with Your queries or complaints and to provide or improve Our customer service to You.
• For internal training purposes.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:

• To help ensure the on-going security of the Website.
• To enhance the service that You receive on the Website.
• To provide information necessary to enable Us to provide competitive, cost-effective Services.
• To provide customer support including dealing with Your complaints, enquiries and to improve customer service.
• To monitor quality and conduct staff training.
• To study how Our Website are used, including how customers use Our Services, to develop them, to develop and grow Our business, to inform Our marketing strategy, to define types of customers for Our Services and to keep Our Website updated and relevant.
• To operate Our business and Website (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, provision of administration and IT services, network security and to prevent fraud).
• If You wish to use a location data service which engages Your Device’s GPS tracker, You will be asked to consent to Your Personal Information being used for this purpose upon registering to use the App. You can withdraw Your consent at any time by turning off the location services settings for the App on Your Device.

How long We will keep it for

We will store this Personal Information for two years in order to allow Us to review and monitor normal traffic patterns and trends on Our Website at which point it will be erased or anonymised so that the data no longer identifies You. We will store the unique application number for as long as the App is installed.

PHOTOS, IMAGES AND VIDEOS OF YOU

Where You have agreed to participate and feature in videos, images and photos for Us, these will be used for the purpose outlined to You at the time, which can include to promote Seek and Buy or its subsidiaries. This will be retained for no more than 3 years after the purpose has ended. We have a legitimate interest to use these on any of Our Website or 3rd party social media Website.

REMOVING PROPERTY DATA FROM OUR WEBSITE

If You have any concerns about the properties advertised on the Website, please contact Us at alan@sandbpropertiesdirect.com and We will endeavour to resolve the issue promptly.

If You are a vendor of a property that is being actively marketed on Our Website and You want this removed, please contact Us directly in the first instance.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?

We retain access to all Personal Information that We have collected from You or about You. Once Your Personal Information has been passed to one of Our Partners in the course of providing Our Services the Seek and Buy Partner will have a copy of the Personal Information that You have provided within Your enquiry and Your contact details which they will use to get in touch with You.

Property data, it is provided to Us by Our Partners (or third parties that act on their behalf). Our Partners (or any third party that acts on their behalf) will be responsible for Personal Information in their possession and that Personal Information will be subject to any privacy terms or policies that the Partner has in place. We are not responsible for use (or misuse) of Your Personal Information by any of Our Partners.

When Our Services are available via the websites of Our partners, those partners may have access to Your Personal Information. We may also have links to other third-party websites from Our Website. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Information about You.

We are not responsible for the content, security, privacy policies and practices of any other third-party websites, even if You access them using links from Our Website or if You can access Our Website or use Our Services from them. We recommend that You check the policy of each website that You visit and make sure that You are comfortable with the terms of such policies before You visit them or provide any Personal Information to them.

If Our business is sold or merged, or if We sell or buy any business or assets, We may disclose Your Personal Information to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If We offer or supply a service to You that is provided on Our behalf by a third party, We may have to pass Your Personal Information to them in order to deliver the service. The categories of third parties (who are acting as Data Processors which means they are responsible for processing Personal Information on behalf of Us) include:

• Telephone call recording;
• Our support ticketing systems;
• IT providers who provide systems to Us for the purposes of hosting and supporting Our Website; and Marketing agencies and systems that allow Us to send marketing communications to You and to make sure the marketing communications are relevant.

We may also use third parties to provide services on Our behalf which may include processing (but not using themselves) Your Personal Information; for example, to complete partial addresses or to augment the Personal Information We hold about You. In either case, We will not pass Your Personal Information to anyone who is not also subject to adequate privacy commitments in Our contract with them.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Police or other such regulatory authority as part of an investigation or otherwise for legal or regulatory purposes.

Dispute Resolution agencies for the purposes of dealing with any complaints.

UK law enforcement agencies and third-party security companies for the purposes of ensuring that We comply with the law and have adequate security measures in place.

We will disclose Your Personal Information to other third parties if We are under a duty to disclose or share Your Personal Information in order to comply with any legal or regulatory obligation or request. This includes exchanging Personal Information with other companies for the purposes of fraud protection and credit risk reduction.

We require all Our third parties service providers to respect the security of Your Personal Information and to treat it in accordance with the law. We do not allow Our third-party service providers to use Your Personal Information for their own purposes and only permit them to process Your Personal Information for specified purposes and in accordance with Our instructions.

WHERE DO WE STORE YOUR PERSONAL INFORMATION?

The Personal Information that We collect from You may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA, but We are under a duty to make sure that Our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that Your Personal Information is treated securely and in accordance with this Policy. By submitting Your Personal Information to Us, You agree to this transfer, storing or processing.

Unfortunately, the transmission of Personal Information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to Our Website; any transmission is at Your own risk. Once We have received Your Personal Information, We will use strict procedures and security features to try to prevent unauthorised access.

We follow strict security procedures to ensure that Your Personal Information is not damaged, destroyed or disclosed to a third party without Your permission and to prevent unauthorised access to it. The computers that store the Personal Information are kept in a secure facility with restricted physical access and We use secure firewalls and other measures to restrict electronic access. If We are working with third parties, We will require them to have in place similar measures to protect Your Personal Information.

Only employees who need access to Your Personal Information to perform a specific job are granted access to personally identifiable Personal Information. In addition, We limit access to Your Personal Information to those agents, contractors and other third parties who have a business need to know. They will only process Your Personal Information on Our instructions and they are subject to a duty of confidentiality.

We may require You to co-operate with Our security checks before We disclose Personal Information to You. If You are a registered User, You can update the Personal Information held in Your My Seek and Buy account (that You give Us) at any time by viewing Your My Seek and Buy page.

Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Website, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

We have procedures in place to deal with any suspected Personal Information breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

YOUR RIGHTS

You have the right to ask Us not to process Your Personal Information at any time.

You have the right to use Our Website without consenting to direct marketing and the communication services that We provide. We will inform You (before collecting Your Personal Information) if We intend to Use Your Personal Information for such purposes or if We intend to disclose Your Personal Information to any third party for such purposes. We always use the most recently submitted form to be Your current consent status. If You are a registered User, but not signed in when You submit a form, We will not be able to Use Your saved settings so will deem Your consent choice to be as per the form You submit at the time. You can exercise Your right to prevent such processing by selecting the specific options in the fields or forms when You become a registered User.

You also have a right to:

• Request access to or rectification of the Personal Information which We hold about You;
• Request erasure of Your Personal Information in certain circumstances;
  Restrict the processing of Your Personal Information;
• Receive Your Personal Information that You have provided to Us;
• Object to or restrict Our processing of Your Personal Information in certain circumstances; and
• Request that We transmit Your Personal Information to another data controller.

Where We process Your Personal Information because You have given Us Your consent to do so, You have the right to withdraw Your consent at any time.

To exercise any of these rights:,

Please contact the Data Protection Officer whose contact details are provided earlier in this policy. We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information 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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

You have the right to complain to the Information Commissioner’s Office if You feel unhappy with the way We process Your Personal Information. Please visit www.ico.org.uk for more information.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the Personal Information We hold about You is accurate and current. Please keep Us informed if Your Personal Information changes during Your relationship with Us.

COOKIES AND TRACKING

Like many website and App providers, We use “cookies” to enable Us to personalise Your visits to Our Website, simplify the signing-in procedure, keep track of Your preferences and to track the usage of Our Website. For full details about what cookies We set and why We use them, please see Our Cookie Policy available here.

AGGREGATED DATA

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from Your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal Your identity. For example, We may aggregate Your usage data to calculate the percentage of users accessing a specific feature on Our Website. However, if We combine or connect aggregated data with Your Personal Information so that it can directly or indirectly identify You, We treat the combined data as Personal Information which will be used in accordance with this Policy.

CHANGE OF PURPOSE

We will only use Your Personal Information 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. If We need to use Your Personal Information 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 Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CHANGES TO THIS POLICY

We may change the terms of this Policy at any time. Any changes We may make to this Policy in the future will be posted on Our Website and displayed on-screen when You use Our App.

You may be required to read and accept any revised Policy to continue Your use of Our Website. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App.

Please check back frequently to see any updates or changes to this Policy, as You will be deemed to accept such changes from Your continued use of Our Website.

Issue date: 16 September 2021