1. Information About Us
We are Net An Agent Limited. Our registered office is at The Workshop, 32-40 Tontine Street, Folkestone, Kent, CT20 1JU and our registered company number is 07782918.
If you have any questions, our contact details are:
Net an Agent Ltd, The Workshop, 32-40 Tontine Street, Folkestone, Kent, CT20 1JU.
2. Information Collected
Personal data, or personal information, means any information about an individual who can be identified. It does not include data where an individual cannot be identified (anonymous data). We collect personal information from you in the following ways.
2.1 Form information.
This is information about you (such as your name, address, other information about your property, email address, telephone number, and date of birth) that you give us when filling in forms whether on our website or offline. This could include, for example, forms which you complete to register for our service.
2.2 Emails and records of other contact.
This is information you provide when you contact us (for example by email, post or SMS) or when you respond to correspondence from us. This may include enquiries about our services, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
2.3 Technical information.
This is information about you which is collected via technical means such as cookies, webpage counters and other analytics tools.
2.4 Visitor information.
We collect information about visitors to our premises. We may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, this may include an account of your accident.
2.5 Caller information.
We may collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
2.6 Employee information.
If you work for one of our suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you.
2.7 Job Applicants.
We will collect and hold information on job applicants, including information you provide to us in your application, as well as opinion information on you from any referees you provide. We may also obtain identity verification information from reference agencies.
This is information about you which you provide when you post content on our website. This may include estate agency reviews and other content which you post on our website.
2.9 Information we receive from third parties.
As well as the information listed above, we may also receive the following types of personal information about you from the following sources:
Your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy.
Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you.
Publicly available sources. We obtain information from the following publicly available sources: [insert list of sources and the data obtained from them.
3. How & Why Do We Use Your Information
3.1 Common uses of your information.
We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform a contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
We may also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest although these circumstances are likely to be rare.
3.2 Specific examples.
Ways in which we may use your personal information include:
Website administration. We may use technical information, information about your visit to our website, cookie data, content and other information gathers you’re your participation in discussion boards or other functions on our website. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely.
Website advertising. We, or third party advertisers, may serve adverts on you. Where those adverts are targeted, this may involve using technical information, information about your visit to our website, cookie data and information we (or our third party advertisers) have obtained from third parties. More information is available in our Cookie Notice. This won’t include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interests in marketing to you.
Customer Administration. We may use information about you including form information, content and other information you provide to us or which we collect about you as necessary to carry out our contracts with you (or your organisation), and for our legitimate interests in administering your (or your organisation’s) account and any subscriptions or competitions we operate, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes. In particular, where we send you emails with quotes from estate agents we have passed your property details on to, we do this as required to fulfil our contract with you. We will still provide an “opt-out” option on all of these messages, and if you “opt-out” of those emails, you will be added to our suppression list to ensure we do not accidentally send you further quotes.
Direct Marketing. We may send direct postal or electronic marketing to you using your contact details and information you have provided us. We use this as necessary for our legitimate interests in marketing to you and maintain a list of potential customers. If you are not acting as a business and have not provided your contact details directly to us in relation to our service, we will only send electronic marketing to you if you have consented to that marketing. We will always provide an “opt-out” option on any marketing messages we send you. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing.
Third Party Personnel Administration. If you work for one of our customers, suppliers or business partners, we may hold information on you. This includes information you provide when you correspond with us, as well as details of your employment, contact details, and our relationship with you. We use this as necessary for our legitimate interests in managing our relationship with your employer.
Job Applications. If you apply for a position with us, we hold and use information on you. This will include information you provide to us in your application, as well as opinion information on you from any referees you provide. We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
Record keeping to deal with legal claims. We may retain your personal information to ensure that we can properly bring or defend legal claims.
Former Employees. If you used to work for us, your information will be used in accordance with our employee privacy notice. If you are a former employee or contractor and require a copy of this, please contact us.
3.3 If you fail to provide personal information.
If we have (or are entering into) a contract with you, and you fail to provide certain information when requested, we may not be able to perform (or enter into) that contract, or we may be prevented from complying with our legal obligations.
If you are a user of our website, and wish to obtain a quote, the following information must be provided as a requirement of your contract with us: your name, contact details and details of your property. Failure to provide this will mean that agencies may not be able to provide you with a quote, or that we or they cannot contact you to take forward your transaction.
3.4 Change of purpose.
We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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.
4. Automated Decision Making
If you are a user of our site and submit information about your property to receive quotes from estate agents, we will use automated processing to match you with estate agents in your area who may be able to provide you with services. We do this as necessary to fulfil our contract with you. This process affects which estate agents receive information about your property.
We provide the user with proposals from agents based on location, value and type of property obtained during the listing process.
5. Sharing Your Information
5.1 Sharing your information with estate agents.
If you are a user of our site and request a quote, we will send details of your property, and pseudonymised information about you, to estate agents. They will then use that information to provide a quote to you through our website. We do not provide your email address or other contact details to estate agents at this stage. We will use our reasonable endeavours to ensure that your details will be in such a format so that estate agents cannot easily identify either you or your property but we offer no form of guarantee that this will be the case. We also require estate agents not to contact you other than through our website.
Once you accept a quote, we will provide your information to the estate agent, as requested by them, so that they can contact you directly to move forward with your transaction.
Any estate agents whom we provide your details to (whether pseudonymised or not) are data controllers in their own right, and have direct responsibilities to you regarding how they use and store your information. You should refer to their privacy policies for details of how your information will be used.
5.2 Why else might we share your personal information with third parties?
As well as any sharing listed above and in section 3 (How and why do we use your information) we may also share your information with third parties, including third-party service providers and other entities in our group. We require third parties to respect the security of your personal information and to treat it in accordance with the law. We never sell your data to third parties.
We may share your personal information with third parties 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 agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.3 Which third-party service providers process your personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other organisations within our group. [The following activities are carried out by third-party service providers: [administration, IT services].
5.4 How secure is your information with third-party service providers and other entities in your group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
5.5 When might we share your personal information with other entities in the group?
We will share your personal information with other entities in our group [as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data [describe other known activities]
5.6 What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
6. Where We Store Your Information
Our office headquarters are based in Folkestone and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for one of our service providers. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
[We may transfer data to the following countries outside of the UK and the EU which the EU considers to have an adequate data protection regime in place [Andorra, Argentina, Faroe Islands, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay, and organisations in the United States which are certified under the EU-US Privacy Shield framework].]
[We may transfer data to countries outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place. Where we do this, we will ensure that appropriate safeguards are put in place. To obtain more details of these safeguards, please contact us.]
7. Data Security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, 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 have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
8. How Long Will We Keep Your Information For?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of our typical retention periods for different aspects of your personal information are set out below. If you would like details of our retention periods for a particular aspect of your personal information which is not detailed below, please contact us:
Form information including information about you such as your name, address, email address, telephone number, property details and other correspondence with us are kept for a period of up to 6 years after completion to enable us to deal with any enquiries or claims.
Contact information such as your name, email address and telephone number is kept for marketing purposes for a period of up to 6 years after you last contacted us.
Employee information where you work for one of our customers, suppliers or business partners is kept for up to 6 years after the end of our relationship with your organisation.
Content which you post on our website such as reviews, photographs, videos, blog posts, discussion board posts, survey responses and other content is kept for as long as you have an account with us and may be retained for a period of up to 6 years after you close your account. You are able to remove or delete any content which you post at any time while your account is active by contacting email@example.com.
Technical information which is collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to 24 months.
Visitor information which is collected about visitors to our premises is kept for a period of up to 12 months. If you have an accident on our premises, our accident records are retained for a period of up to 6 years.
Telephone recordings which we make of your telephone conversations with us may be kept for a period of up to 36 months.
CCTV recordings may be kept for a period of up to 14 days (unless there an incident occurs and it is necessary for us to keep recordings for longer to properly deal with it).]
Emails and records of other contact which don’t fall into any of the categories above will generally be kept for up to 6 years after we have received them.
9. Your Rights
Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us firstname.lastname@example.org
9.2 Marketing Purposes.
In addition to the rights set out above, you also have the right to ask us not to process your personal information for marketing purposes. We will usually 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 information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can exercise the right at any time by contacting us email@example.com
in writing. You can also use the unsubscribe option in our marketing emails to unsubscribe from further marketing emails. Please note that where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns.
9.3 No fee usually required.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9.4 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
11. Third Party Websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.