Privacy Policy

If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us using the contact details above.

In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.

Whose Information Do We Collect?

We collect personal data in different ways in the course of delivering our services.  This can belong to our corporate clients, partners, suppliers, associates, individuals identified from tracing and data matching, enquirers and customers of our clients where it is necessary as part of the process or service we provide.

Where we process customer personal data on behalf of our corporate clients (for example; when provide address matching services, perform data cleanse or provide analysis to establish trends or insights) as part of our services to them, we act as a data processor on their behalf and they act as the data controller. 

We maintain data processor agreements with all of our clients to ensure that each party is committed to their obligations under the UK GDPR, the Data Protection Act 2018 and all other legal and regulatory requirements to protect your personal data.

What Personal Data Do We Collect And Process?

We collect the following types of data of all corporate clients and enquirers:

• General Contact details such as, name, address, email address, telephone number
• General Communications between you and us
• Details of the Products and Services provided or negotiated
• Financial Details – such as payment or bank details
• Location Details such as address of premises
• Details of previous owners / occupiers
• Business Interests
• Information obtained through our use of cookies (please see our Cookie Policy)
• Your Marketing Preferences

 

We source and identify commercial properties and entities from various public sources and in the course of delivering these services this can also include some personal data where individuals are identified as connected to or contacts for these companies.   We may process the following personal data connected to these services:

• General contact details such as names, locations and telephone numbers of individuals connected to or related to commercial properties and entities.
  
  

Special Categories Of Personal Data That We Collect

We do not routinely collect any special category data, however if you voluntarily share this information with us it is processed only with your consent and retained as long as it is strictly necessary. 

How We Collect Your Information

In most cases we collect your data directly from you.  We collect data and process it when you:

• Complete an online ‘contact us’ form.
• Speak to us on the telephone or in person to discuss our services.
• Email or write to us.
• Enter into a contract of service with us.
  
  

We also receive your data indirectly from the following sources:

• If you are a customer of our corporate clients, we will receive your personal data in the course of delivering our professional services to them as a data processor.
• If you are nominated as a point of contact from one of our commercial customers, we may receive your details from them.
• Social Media Sites including LinkedIn, Facebook and Google.
• Public Sources and Registers.
  
  

Please Remember: Where you provide any of this information relating to or on behalf of another individual  please remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.

Why Do We Collect Your Information?

Where we collect and process personal data, we identify both the purpose and legal basis for doing so.  There are 6 possible legal bases which are:

Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose.

Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject.

Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person.

Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Legitimate Interests – Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in particular where the data subject is a child.

Our purpose and legal basis for the information we collect, and process allows us to:

Our Purpose for Processing	Our Lawful basis
To understand client requirements prior to entering into a contract of service.	The processing is necessary for the performance of an anticipated Contract.
To understand all requirements to ensure that any service provided meets our client’s needs.	The processing is necessary for the performance of a Contract.
To fulfil our contract by locating commercial premises owners or tenants and to provide clients and customers with the services agreed.	The processing is necessary for the performance of our Contract.
To manage our business operations and comply with any internal policies and procedures.	It is in our Legitimate Interests to use your personal information to ensure that we provide and adapt our services.
To utilise publicly available sources and registers of data engines to carry out or services for tracing and matching company information under contract.	It is in our Legitimate Interests to process this data to carry out our services.
To notify clients and enquirers about changes to our service.	It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you.
For Electronic Marketing of similar services to existing clients or previous clients or enquirers.	It is in our Legitimate Interests to use your personal information for marketing purposes where the services being marketed are similar and relevant to you.
For Electronic Marketing of services to new customers at incorporated companies via personal business email addresses.	It is in our Legitimate Interests to use personal business email addresses for marketing purposes where we can support individual’s rights.
To comply with our legal obligations, law enforcement, court, financial and tax requirements set by government bodies and executive agencies.	Processing is necessary to comply with our Legal Obligations.

Where we rely on your consent you have the right to withdraw this consent at any time by contacting us using the details at the beginning of this notice.

Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to source information available in the public domain to deliver our services to clients.

This is particularly relevant where we source publicly available information on commercial entities and premises as this can often include names and contact details of individuals connected to or operating from those locations.    Where we do so this is balanced towards protecting individuals personal data at all times and this is assessed on a regular basis.

Direct Marketing

We may send our clients details of our services if you have used these previously.   You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.

We do not provide our services to any client for marketing purposes or permit them to do so and we will never share or sell information to any other party for marketing purposes.

Who Do We Share Your Information With?

From time to time, we may share your personal information with the following third parties for the purposes set out above:

• For individuals identified as part of our services to clients we will share the information only with our clients.
  
  

For all other enquirers or clients, we share information with:

• Our Payment Service Providers
• Professional Services used to support us in operating an effective business such as lawyers and auditors
• Software and Cloud storage providers
• Local Councils / Authorities
• Selected Third Parties who require your information in order to attempt financial redress or initiate legal proceedings
• Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
• Governing Bodies and Executive Agencies such as Companies House, HMRC and Regulators where required
• Selected Third Parties in connection with any future sale, transfer or disposal of our business

International Data Transfers

With today’s modern technology including Cloud Storage and Software, some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country.   

Where this is the case, where, we have the option we ensure that resting data is always held in UK servers.  In addition, we make sure that additional safeguards are in place such as ensuring that those countries have a decision of adequacy under the UK GDPR, or those firms are registered with the UK-US Data Bridge or entered into standard contract clauses with us in their terms to support the ongoing protection of your data.

Automated Decision-Making Or Profiling

We do not process personal data for automated decision making or profiling.

How Long Do We Keep Personal Data For?

We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy.  We maintain and review a detailed retention policy which documents how long we will hold different types of data.  The time period will depend on the purpose for which we collected the information and is never on an indefinite basis.  Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).

The following details the criteria used to establish the retention period set out within our policy:

Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of 5 Years after the end of any contract with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records.  Most of our retention periods are determined on the basis of this general rule.  Personal Data identified as part of our company tracing, cleansing and matching services will be retained for 30 days after completion of the contract.

Where required by statutory, contractual, or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data regarding pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.  Where this is the case will retain the data in accordance with our obligations.

Your Rights As A Data Subject 

As a data subject, you have rights in relation to your personal data.  These are:

The Right to Access – You have the right to request details of personal information held or processed and to copies of this data.  We do not usually charge for this service.

The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.

The Right to Erasure – You have the right to request that we erase your personal information under certain conditions.

The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances.

The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.

The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.

You also have the Right to Withdraw Consent where you have previously provided this at any time. 

To exercise any of these rights, or if you have a complaint, please contact us using the contact details at the beginning of this notice.

If we cannot satisfy your complaint, you also have the right to complain to the Supervisory Authority.  In the UK, where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at: