Property Inside London Limited (“Property Inside London”) is committed to protecting and respecting your privacy. We are registered with the Information Commissioner’s Office, the UK supervisory authority for data protection issues.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Please note that all personal data sent to a Property Inside London email address (for whatever purpose) will be stored on our IT systems and email service providers systems and may be subject to wider systematic monitoring procedures which we have implemented for the purpose of our legitimate business interests to protect confidential and personal data and assist in our ability to identify potential data breaches.

For the purpose of UK data protection law, the data controller is Xiuyun Liu.

Information we collect from you

As a business we collect, use, store and transfer different types of personal data depending on who you are (for example, a client, customer, or supplier). The types of data we may collect include: identity data; contact data; financial data; details of your dependents; transaction data (including, for example, details of your property requirements); IP address; website usage data; marketing and communication preference data; call recordings; information in your application form and CV; proof of right to work; employment history; criminal convictions and offences.

We use different methods to collect data from and about you, including:

• Direct interactions (personal data you disclose when you fill in forms, surveys, or correspond with us by post, phone, email, live chat, web, social or otherwise; through the job application process; or through property portals when you enquire about our services).
• Indirect interactions (personal data you disclose to third parties such as payment service providers, data brokers or aggregators (e.g. TwentyCi, Rightmove, Zoopla (based inside the UK/EU), or Facebook (based outside the EU); or which is available through publicly available sources or registers such as Companies House, the Electoral Register, Government or Police Databases).
• Aggregated data (personal data, usually anonymised or aggregated to groupings, from systems such as our website, CRM or phone systems; or service providers such as credit check or profiling companies).

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

Uses made of the information

We collect information about you for the purposes of our business including:

• to process the purchase, rental, management, sale or let of a property through Property Inside London (or from one of our clients)
• to contact you about services and offers we think may be of interest to you in relation to the purchase, rental, management, sale or let of a property
• when you apply for a role with us and/or are successful
• where it is necessary for us to comply with our legal obligations (such as anti-money laundering and estate and letting agency laws, regulations and/or codes of practice) or where it is otherwise lawful for us to do so.

We may also process your personal data to help us operate, grow and protect our business, develop our products and services, help improve our efficiencies, manage our client base, provide training, monitor our customer service standards, help resolve disputes and/or to refer you to selected third party mortgage brokers or a conveyancing panel management provider.

Examples include network security and monitoring, auditing, call recording (which we also ensure takes place in accordance with the Investigatory Powers Act 2016 by informing callers that the calls may be recorded), training and awareness including compliance, referencing, verification of identity, fraud prevention, risk assessment, utility switches, due diligence, marketing (we may share an encoded version of your email address to third parties such as Facebook and Google to enable these third parties to display Property Inside London’ ads when you visit their websites), analytics, debt recovery and other claims, the improvement and optimisation of advertising, providing marketing material and content (including providing you with information about goods or services which we feel may interest you as a result of any previous sale or purchase we have negotiated on your behalf and enabling third parties such as Facebook and Google to display Property Inside London ads to you when you use their website) for our website and other applications or platforms through which you interact with us, ensuring that content from our website is presented in the most effective manner for you and your computer, customer support, notifying you about changes to our services and other important notices, managing suppression lists, profiling, cloud storage, when we purchase another business and/or referrals.

In some circumstances we may, where we deem it appropriate, to protect our entitlement to a commission and to avoid a dispute, disclose your name to another agent, landlord or vendor.

Our right to process your personal data falls under one of the following legal bases: your consent (Article 6(1)(a) GDPR); where we are performing our obligations under a contract with you (Article 6(1)(b) GDPR); where we are under a legal obligation (Article 6(1)(c) GDPR); where the processing is in our legitimate business interests (Article 6(1)(f) GDPR). The following additional grounds may also apply where we process special category data: where you provide explicit consent (Article 9(2)(a) GDPR); where you had already made the personal data publicly available (Article 9(2)(e) GDPR); to establish, exercise or defend a legal claim (Article 9(2)(f) GDPR).

Disclosure of your information

We may share your personal data with trusted companies outside of Property Inside London. Examples include: third parties with whom we have a contractual relationship to perform, or assist us in performing the purchase, rental, management, sale or let of a property; IT and system administration service providers; anti-money laundering verification service providers; tenancy deposit schemes (or deposit replacement service providers); utility switch companies; utility suppliers; trade contractors; survey companies; surveyors, EPC providers, inventory clerks, managing agents, property auctioneers, auction legal pack providers; local authorities and government law enforcement agencies; Government departments (e.g. HM Land Registry); property developers; third party data services who help us to segment and understand our audience so that we can send the most relevant and targeted communications possible; advertisers and advertising networks (including social media) to select and serve relevant Property Inside London adverts to you based on the fact that you use that third party network and are a contact of Property Inside London; professional advisers including lawyers, bankers, auditors who provide consultancy, banking, legal, insurance and accountancy services and insurers; credit or reference providers (including for the purposes of debt recovery); other agents with whom we have entered into a sub-agency agreement and where they have introduced a potential purchaser/vendor/landlord/tenant for your property; the counterparty to your transaction; property portals through which you request our services; other parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• As required to carry out the services that we provide to customers;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

We are, through technical and organisational means, committed to ensuring the security of, and prevention of unauthorised access to, your personal data. For example, we limit who can access your personal data to those individuals and third parties who need to know it. If we become aware of a data breach we will, where we are required to, notify the Information Commissioner’s Office. If we believe that the data breach is serious, we may notify you as well.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We will retain your personal data whilst you use our services (or whilst we provide services connected to you) and/or are in communication with us and for at least seven years thereafter for legal, regulatory and accounting purposes. If we need to retain your personal data for longer, we will take into consideration the potential risks in continuing to store your data against why we might need to keep it. In some circumstances we might anonymise your personal data so it is not associated with you, and we may then use this information indefinitely.

Your rights

To the extent provided by law, you have the right to:

• Subject to the payment of the reasonable costs, access a copy of the personal data that we hold and process about you. You have rights to the following information, subject to certain exemptions:

• • the purpose(s) for which we are processing your information;
  • the categories of personal information we hold about you;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
  • the period for which we will store your information, or the criteria used to determine that period;
• object to the use of your personal data (including for marketing purposes) by appropriately informing Property Inside London
• rectification of any inaccurate information we hold about you;
• request the erasure of the personal data we hold about you;
• ask that we do not make decisions about you using completely automated means; and/or
• Subject to the payment of reasonable costs, ask that personal data we hold about you is, where technically feasible, transmitted to a third-party chosen by you, in a commonly used, machine-readable format.

Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions.

The rights listed above may not apply in certain circumstances so we may not always be able to comply with your request. We will tell you if this is the case. We will usually respond to a request from you to exercise your rights within one month of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests.

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.

You have the right to tell us not to use your personal information for marketing purposes. Please write to us at our postal address or email us if that is the case. We will still process your personal data in order to fulfil our contract with you/ our clients and in accordance with our legal, accountancy and regulatory obligations. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data until you withdrew your consent.

We will comply with the law in responding to your requests. That means that there may be some legal reasons why we cannot comply with all requests.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contacting us

If you have any questions about this privacy policy or the way we handle your personal information, please contact us by post at our registered office address or alternatively by email.

We hope that we will be able to answer any questions or concerns that you have. You have the right at any time to raise your concern with the Information Commissioner’s Office at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF