Privacy Policy

This policy also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation and other legislation that relates to the use of personal data. Reading this Privacy Policy will help you understand your privacy rights and choices.

If you do not agree with our policies or practices, please do not use our Services. If you still have any questions or concerns, please contact our Data Protection Officer, Abigail Radford, at [email protected].

Table of Contents

1. How do we collect your personal information?
2. What information do we collect?
3. Cookie Policy
4. How do we process your information?
5. The legal basis for processing your personal information
6. When and with whom do we share your personal information?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Do we make updates to this policy?
12. How can you contact us about this policy?
13. How can you complain about the use of your personal data?
14. How can you review, update, or delete the data we collect from you?

1. How do we collect your personal information?

We will collect most of your personal information as follows:

• Verbally during telephone conversations or face to face in your own home (if you are selling a property) or at a property you are viewing (if you are buying a property)
• Written on our contract when you are instructing us to sell your property
• At a Number Twenty Four event when you speak to a member of our team and provide your details
• You may choose to submit your information to us directly via our website or in response to marketing or other communications.

2. What information do we collect?

We collect information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us. The personal information we collect may include the following:

• Full name and contact details (phone number, email address and postal address)
• Additional information relating to your identity in order to comply with ‘Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017’
• When required in order to conduct conflicts of interests under regulatory obligations we will need information on your close connections
• Information on any access requirements you have which is necessary to enable us to find suitable properties for you. This information may consist of special category personal data comprising details of any disability or other health information.

Other information provided by you. The information we collect may include the following:

• The locations you are interested in so we can send you information about similar products
• Your communications with us, including a record of the email or telephone correspondence created when you contact us.

Sensitive information. We do not process sensitive information.

All personal information that you provide to use must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Where we need to collect personal data by law, for example to meet our obligations to prevent fraud and money laundering, 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. As a result, we may have to cancel a Service you have with us. We will notify you if this is the case.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Please read our ‘Cookie Policy’ below for further details.

3. Cookie Policy

A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Functional cookies
Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;

2. Analytical cookies
Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc; and

3. Third-Party Cookies
Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

• Monitoring of website usage for optimisation;
• Processing payments; and
• Writing reviews.

We use the following cookies

4. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested Service. This includes:

• To fulfil our obligations to you when providing you with our property Services
• To share your information with others, where necessary, to fulfil our property Services for you or where acting as an agent for a third party on your behalf
• To comply with our statutory and regulatory obligations.

To respond to user enquiries/offer support to users. We may process your information to respond to your enquiries and will communicate with you during the course of providing our Services.

To send administrative information to you. We may process your information to send you details about our Services, changes to our terms and policies, and other similar information.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes. If this is in accordance with your marketing preferences. You can opt out of your marketing emails at any time. For more information, see ‘What are your Privacy Rights?’ below.

To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

To evaluate and improve our Services, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, marketing and your experience.

To identity usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

5. The legal basis for processing your personal information

The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these will apply whenever we process personal data:

Consent: you have given explicit consent for us to process your personal data for one or more specific purposes outlined above.

Contract: the processing of your information is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract.

Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

Vital interests: the processing is necessary to protect someone’s life.

Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

6.  When and with whom do we share your personal information?

We do not sell, or otherwise disclose personal information we collect about you, apart from what has been clearly outlined in this Privacy Policy or as indicated via the consent process at the time the data was collected from you. We will not share your information with third parties for marketing purposes without first obtaining your prior consent.

We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We will also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The third parties we may share personal information with are as follows:

• Vetted companies providing services directly related to the purchase or sale of a property
  Developers, Mortgage Advisors, Solicitors, Surveyors, Energy Assessors, Contractors, Identification Services, Removers.
• Regulated Governing Bodies
  Her Majesty’s Revenue and Customs (HMRC), National Crime Agency, The Property Ombudsman, Fraud Prevention Agencies.
• Retargeting Platforms
  Google Ads Remarketing and Google Analytics Remarketing
• Social Media Sharing and Advertising
  Facebook advertising and Instagram advertising and LinkedIn advertising
• Web and Mobile Analytics
  Google Analytics

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

7. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Statutory and regulatory obligations of Estate Agents require us to keep your personal data for a longer period than the process of selling or buying property therefore we will store your data for a minimum of 7 years.

8. How do we keep your information safe?

The security of your personal information is very important to us and Number Twenty Four is committed to protecting the data we collect. We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

Our client information is stored on our secure client management system. Access to this system is restricted only to staff who need it for legitimate business purposes. A hard copy of any personal information required to perform contractual tasks or those of legitimate business interest are stored in locked cabinets. All members of staff who need to access personal data to perform their roles have received appropriate training.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

10. What are your privacy rights?

Number Twenty Four recognises your rights in relation to your personal information. You have the right to:

• Be informed about how we store and use your personal information
• Obtain access to the personal information we hold on you and request a copy of the personal data that we have used to perform our agreement with you
• Ask for your personal information to be updated if you have additional information or you believe the information is not correct
• Withdraw your consent for us to process your personal information (see more below)
• Request for your personal information use to be restricted if you consider the personal data is incorrect, when it is not lawful, where you have raised an objection about the use of your data or where you need us to keep your data due to a legal claim
• Request for your personal information to be deleted.

Withdrawing your consent

You have the right at any time to withdraw any consent you have given us to process your personal data. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can withdraw your consent at any time by contacting us by using the contact details provided below.

How you can request erasure of your data

You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained above), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

How you can restrict or object to us using your data

You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Please note that if you want us to restrict or stop processing your data this may impact our ability to provide our Services. Depending on the extent of your request we may be unable to continue providing you with our Service.

Moving your information to another organisation

In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you. If you would like us to move, copy, or transfer your information please let us know by email to [email protected]. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send, or by contacting us using the using the details provided below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you have any questions or comments about your privacy rights, you may email us at [email protected].

11. Do we make updates to this policy?

We may update this Privacy Policy from time to time. We encourage you to review this policy frequently to be informed of how we are protecting your information. Should we make substantial changes to this policy, we may notify you either by prominently posting a notice of such changes, or by directly sending you a notification.

12. How can you contact us about this policy?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Abigail Radford by email at [email protected], by phone at 07398668274, or by post at:

Number Twenty Four Limited
5 Bartholomews
Hove
BN1 1HG

Number Twenty Four Limited is registered in England under Company No. 15285547. VAT No. 456581269. Our registered address is 5 Bartholomews, Brighton, BN1 1HG.

13. How can you complain about the use of your personal data?

If you wish to raise a complaint on how we have handled your personal data you can contact us, in writing, to have the matter investigated by Abigail Radford.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk.

14. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information please contact us.