Privacy Policy

1. Important information and who we are

The purpose of this Policy

We are Indlu Ltd, and we own the Website. In this privacy and cookies policy (“Policy”), Indlu Ltd is referred to as “we”, “us” or “our”, as appropriate.

We are committed to ensuring your privacy is protected. This Policy explains when and why we collect personal information about Website visitors, clients and people who contact or interact with us, how we use that personal information, the conditions under which we may disclose it to others and how we keep it secure. The Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

Controller

We are the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights (as set out in paragraph 8), please contact our data privacy manager using the details set out below:

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to this Policy and your duty to inform us of changes

This Policy was last updated on 13th September 2018. Any change to this Policy will be on this page and a notice that the Policy has been updated will be clearly shown on the Website and, where we have your email address and a legal basis to contact you using that email address, emailed to you. Continued use of the Website after such modifications will constitute agreement to the updated terms of the modified Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.

2. The data we collected about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

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 data but is not considered personal data 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 Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, or in order to provide you with information or services that you have requested from us, 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, or provide you with information requested (for example, to provide you information about a particular property listed on the Website). In this case, we may have to cancel our contract with you or not provide information to you, but we will notify you if this is the case at the time.

3. How do we collect personal information from you?

You may provide this to us through our Website forms, emails, phone conversations, documents that you provide to us or when you meet us in person, or when you contact us for any other reason by any media, for example when you:

This includes Identity, Contact, Profile, Usage and Marketing and Communications Data.

Automated technologies or interactions

We also obtain personal information relating to you (including about your equipment, browsing actions and patterns) using automated technical means when you visit the Website.  We collect this personal data by using cookies, server logs and other similar technologies. The Website uses cookies to distinguish you from other users of the Website. This helps us to optimise your experience of the Website and services and also allows to improve the Website. For detailed information on the cookies we use, and the purposes for which we use them, please paragraph 5 below.

Information we receive from other sources.

We may receive personal data about you from various third parties and public sources as set out below:

4. How we use your information

The table below describes all the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register your account for access to additional functionality on the Website

(a) Identity

(b) Contact

(c) Profile

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or this Policy

(b) Communicating with you where you have asked us to do so

(c) Arranging viewings for properties where you have asked us to do so

(d) Processing offers you make or receive for properties

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Usage

(f) Technical

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(c) Performance of a contract with you

To enable you to provide feedback

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website content to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve the Website, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about properties that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Change of purpose

We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Cookies

The Website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on the Website and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on the Website. 

We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of the Website. 

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that use cookies (which may be stored on your computer after you leave the Website) can store information about your visit.

6. Where we store your information

Your information may be transferred, stored and processed securely on servers based within the EU and subject to the EU standards and regulations on data protection. By using the Website, or otherwise submitting your personal information to us, you agree to this transfer, storing or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with data protection laws. We also take all reasonable steps to ensure that any personal information stored by us on site in non-electronic formats is done so securely.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Disclosures of your personal data

In order to provide an efficient service to our clients and other users of our services, we may pass your information to third party service providers, including but not limited to:

When we use third party service providers, we disclose only the personal information that is necessary to deliver the service you have requested and we have a contract in place that requires them to keep your information secure and otherwise use your information in accordance with applicable data protection law.

We may in a few other limited cases need to disclose your information to third parties:

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

We do not transfer your personal data outside the European Economic Area (EEA).

8. Your rights

Under data protection laws, you have the right:

To exercise any of these rights, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 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.

Time limit to respond

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.

9. How long do we retain your personal information?

We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about sellers for whom we sell a property (including Contact, Identity and Profile Data) for six years after they cease being customers. Otherwise, details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see paragraph 8 above for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Security precautions in place to protect your information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and for this reason we cannot guarantee the security of data sent between us over the Internet.

11. Further information

You can obtain further information about data protection laws by visiting the Information Commissioner's Office website at www.ico.org.uk

 

This Policy was most recently updated on 13th September 2018.

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