1. ABOUT US

Alter and Cope Limited is an estate agency business. We are committed to conserving the privacy of the personal information provided to us or collected by us during the course of our business as well as the personal information we receive from visitors to our website.

We are the data controller of personal information collected by or provided to us in the circumstances described below in section 2.

This Privacy notice explains how we may collect and use any personal information we obtain about you and your rights in relation to that information. This applies to our business in the United Kingdom. If you have any questions about how this Privacy notice applies to you, please contact us.

2. SCOPE

This Privacy notice applies in the following circumstances:

• when we conduct searches on you in connection with our business;
• when we agree to provide goods or services to you or the organisation you work for;
• when you or the organisation you work for are a counterparty of one or more of our clients;
• when you request information from us or provide information to us;
• when you apply for a role or work experience opportunity with us;
• when you visit our office and our website;
• when you attend one of our seminars or other hosted events (including virtual events organised by us and hosted on third party platforms);
• when you register on one of our apps; and
• when you are entered onto our mailing lists to receive publications and other marketing emails (see section 3.2 for further information).

We also use cookies on our Websites. Cookies are small text files that are placed on your computer or mobile device when you visit our website. The use of cookies is to improve the functionality of our website and your experience when using it as well as improving our services for our clients.

3. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW?

3.1 Business development and business acceptance

We collect personal information about prospective clients and their beneficial owners, controllers and/or directors as part of business development initiatives and our business acceptance process. The type of personal information we may collect includes name, address, nationality, business interests, track record and employment history. We obtain this information from you or your employer directly and from publicly available open sources either directly or through a third party.

We may also collect personal information about other individuals who may be, or working for, counterparties of our clients or our prospective clients or otherwise involved on matters we may be acting on.

3.2 Keeping you up to date with relevant marketing and events

The type of personal information that we may collect includes current and historical information including your name and contact details (such as your address, email address and telephone numbers) and identifiers such as your organisation, employment history, professional and business expertise and positions held.

We will also collect personal information you choose to provide to us directly, or, for example, through your use of our apps or other online services, and information about your other dealings with us and our clients, including contact we have with you in person, by telephone, letter, email or online. This information may include access or dietary requirements which may reveal information about your health or religious beliefs. We obtain personal information from your IP address and the operating systems and web browsers that you use to access our Websites. It enables us to identify which organisations have visited our Websites and we use this information to compile statistical data on the use of those sites to help us to improve the user experience.

We collect personal information directly from you, from our clients or other parties to a matter and their authorised representatives. We may also collect personal information from third parties such as your employer, other organisations that you have dealings with, regulators, government agencies, credit reporting agencies, publicly available records (including electronic data sources to carry out checks to enable us to comply with applicable law), information or service providers (some of whom may process your personal information on our behalf), third party platforms that we engage to host our training and events, recruitment agencies and professional advisers. Your personal information may be collected in the firm’s contact database when you register to receive updates or we otherwise receive your contact details.

We use a third party service provider to manage the our contact database and deliver emails to inform you about our services, developments and updates and invite you to our events (including those we may jointly host with other organisations).

3.3 Recruitment

If you apply for a role with us we will collect personal information directly from you, or from recruitment agencies, recruitment websites and apps or other third parties involved in our recruitment and screening process.

We will use this information to consider your application for a position with us to help us better support a diverse and inclusive workplace and meet our requirements.

4. HOW WE USE YOUR INFORMATION

We will only use your personal information if and to the extent that applicable law allows. We will therefore only process your personal information if:

• it is necessary for the performance of a contract with you or the organisation you work for;
• it is necessary in connection with a legal obligation;
• you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us; or
• if we (or a third party) have a legitimate interest which is not overridden by your interests or your rights and freedoms.

We may use your personal information to:

• consider whether we can pursue certain business development initiatives;
• comply with our legal obligations to identify and verify the identity of our clients and their beneficial owners and to identify and assess the risks of money laundering and terrorist financing which may apply to our business;
• deliver services to you and/or the organisation you work for, if you are a client;
• carry out identity and security checks when you visit our offices (including capturing your image on CCTV);
• run our business;
• maintain and develop our business relationship with you;
• improve our services and products to you;
• identify services you may be interested in;
• send you marketing and invite you to events;
• monitor and analyse our business; or
• process and respond to requests, enquiries or complaints received from you.

5. HOW AND WHY DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your personal information with our offices, branches, in-house companies and associated partnerships due to, for example, our shared IT systems and/or cross jurisdictional working on a matter. We use third parties who provide services on our behalf and will share your information with them, for example a technology supplier may have access to your personal information when providing software support, or a company we use for a communications campaign or to host our events may process the personal information of our contacts or attendees for us.

During the course of working with you or the organisation you work for we may use certain third party technology services to assist with our work on the matter. Where these services are integral to our work for you, we deploy them as a matter of course. We also use various ancillary services, for example, software that is capable of effecting bulk data transfers and facilitating e-signatures. We may also have to share your personal information with regulators, government and enforcement agencies, courts and other third parties.

Some of your personal information may be stored in a cloud located within the UK and / or managed by a third party service provider. In adopting this approach, the confidentiality of your personal information is of key importance to us.

We may share your personal information with third parties where:

• you have consented to us doing so (where necessary) or the organisation that you work for has obtained your consent for us to do so (where necessary);
• we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements or in relation to our employment obligations);
• it is in our or a third party’s legitimate interest to share the information, and that legitimate interest is not overridden by your rights or freedoms; or
• it is appropriate to disclose the information to parties with whom we have promotional arrangements (such as jointly hosted events).

6. SECURITY

We use up to date data storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.

The transmission of information via the internet is not completely secure. Although we take appropriate and proportionate steps to manage the risks posed, we cannot guarantee the security of your information transmitted to our online services.

7. THIRD PARTY SITES

Our website may contain links to other sites which are controlled by third parties, for example in the Community and Environment section. We may also use social media sites, such as LinkedIn, Facebook and Twitter and third party platform to host events, training and seminars. You should review these other sites’ privacy policies. We do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information.

8. YOUR RIGHTS

You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold. These rights are to:

• request access to your personal information (known as a subject access request) and request certain information in relation to its processing;
• request rectification of your personal information;
• request the erasure of your personal information;
• request that we restrict the processing of your personal information; and
• object to the processing of your personal information.

In the limited circumstances where you may have provided your consent 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 basis for doing so in law.

You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Privacy notice. However, we may refuse to provide access and may charge a fee for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.

FURTHER INFORMATION

If you have any questions about this policy or how we handle your personal information, please contact us. We hope we can resolve any query or concern you raise about our use of your personal information. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.