Privacy Policy

Privacy Policy

Worldwide Property Company (UK) Ltd – Privacy and Cookie Policy

Last updated January 2021

Introduction

Your privacy is important to WORLDWIDE PROPERTY COMPANY (UK) LTD. This policy sets out information on the personal data we collect about you, and your rights in respect of this data. This policy applies whether you use or interact with our website http://worldwideproperty.co/ and our related or associated web pages, social media platforms, landing pages or other online platforms (the “Websites”).

Our Websites may contain links to third party websites that are not covered by policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

This policy contains the following information:

• Information about who we are
• The changes we may make to the policy
• Information on what we can collect
• How we store your personal data
• How we disclose your information
• Your rights regarding your personal data
• What happens when we link to other websites

1. Who We Are

Our company name is WORLDWIDE PROPERTY COMPANY (UK) LTD (09730667) (our registered address is 3rd Floor, 86-90 Paul Street London EC2A 4NE).

We are the data controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the contact details set out below.

Contact details

Our full details are:

Full name of legal entity: WORLDWIDE PROPERTY COMPANY (UK) LTD

Contact: Dylan Mitchell

We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018. If any of these laws are replaced or superseded, we will also comply with that.

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.

2. Changes to the privacy policy and your duty to inform us of changes 

We keep this privacy notice under regular review and, if we make any changes to this notice, we will place an updated version on our website and, where appropriate, notify you by e-mail. Regularly reviewing this page ensures you are always aware of what personal information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

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.

3. The data we collect

In the course of providing our services, we collect property data such as images of properties including videos and virtual tours, property asking prices, property addresses, property locations and property descriptions. The property data is provided to us by our partners or other third parties on behalf of those partners.  We have a legitimate interest to process this information to provide a service to our partners to enable them to advertise their properties and enable, you, the customer to view such properties.

Personal data, or personal information, is 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 when you use our Websites. Whenever we collect personal data about you, we must have a legal ground to do so.  We will ensure that your personal data is processed lawfully, fairly, and transparently without adversely effecting your rights. The type of data we collect is as follows:

Table 1

We may process your data for compliance with a regulatory requirement or legal obligation to which we are subject too. Your data will only be processed if processing the data to comply with such obligation is a reasonable and appropriate way of achieving compliance.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 Privacy Policy.

• Third Parties 

We work with third-party partners who help us provide and improve our products and services. We, acting under a lawful basis, (as set out in section 3) may have to share your personal data (as set out in Table 1) with the following third parties (but not limited to):

• Purple Box
• Active Campaign (an automatic email service provider)
• Proppy
• Alliotts
• Xero
• Google (an internet search engine, communications and analytical platform)
• Moneypenny
• Facebook (a social media platform)
• Twitter (a social media platform)
• LinkedIn (a social media platform)
• Instagram (a social media platform)
• YouTube (a social media platform)
• Zoom (a communications platform)
• Slack (a social media platform)
• Other professional service providers including (but not limited to): lawyers, accountants, construction firms, and our partners.

As noted above, we can pass your information to our partners in the course of providing our services (most typically when you communicate with introducers/ sales managers/ estate agents/ property owners through our website, then we shall have a copy of the information that you have provided the introducer/ sales manager/ an estate agent/ property owner and the contact details they will use to contact you.In addition to Table 1, we will collect information that you give us when using our website. For example if you wish to access a particular search feature, request information regarding a property or fill out a form on our website, you may be asked to provide personal data including:

• Details of the sort of property you are interested in
• The cost and location of the property; and
• Your current residential address.

If you choose to contact a partner using any number provided on the website, we may also keep a record of the call activity.The basis of processing the above information is under a legitimate business interest to process the information to facilitate property enquiries to our members and to provide the service to you.We may contract with third parties to supply services to you on our behalf. These include cloud services and other service providers used to send emails and technology providers that assist in providing the communication to you. This includes but is not limited to, providing you with property details of properties you have enquired about or other properties that you may be interested in. These third parties are acting as data processors which means they are responsible for processing personal data on behalf of us.We will not otherwise disclose your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.

• How we store your personal data

We store all your personal data on our servers within the United Kingdom.If we ever need to transfer your data outside the EEA, we will ensure that we have standard contractual clauses in place with these contractors before transferring data outside the EEA, and we will conduct regular due diligence on those contractors to ensure that they comply with the General Data Protection Regulation (2016/679).Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. 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 will still be responsible for protection of your personal data, even where we have transferred it outside the EEA.We regularly review our data retention obligations to ensure we are not retaining data for longer to fulfil the purposes we collected it for, including for the purposes of satisfying any legal accounting, or reporting requirements.

• How we disclose your information

We may disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer
• We can disclose it to other businesses in our group, as defined in the Companies Act 2006
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights
• We can exchange information with others to protect against fraud or credit risks
• Your Legal rights

When you provide us with personal data, you have certain legal rights, and these include:

• To request access to, deletion of or correction of, your personal data held by us at no cost to you
• To request that your personal data be transferred to another person (data portability)
• To be informed of what data processing is taking place
• To restrict processing
• To object to processing of your personal data
• To complain to a supervisory authority
• Right to withdraw consent

If you wish to access, rectify, erase or transfer your personal data, please contact us at info@worldwideproperty.co

• What happens when we link to other websites

This privacy policy only relates to our Websites. We might have links on our Website to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.As noted above, our Website includes links to other websites. We use a third party service provider called Proppy which feeds into our Website. Again, please note that our terms and conditions and our policies will not apply to any links fed into or on our Website.

• The changes we may make to this policy

We can update this policy from time to time as laws change or as Websites change. If we make material changes to the policy, and we need your consent to those changes, we will contact you by email to do so.

Type of data	Purpose/Activity	Lawful Basis
Identity Data	includes first name, last name, username,  or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number. We will use this information to carry out the contract with you and manage our relationship with you.	This information is necessary for us to perform our contract with you. This information is also necessary to comply with our legal obligation to inform you if we change this policy or our terms and conditions. We also have a legitimate interest to keep our records updated to ensure we are providing you with the best possible service.
Contact Data	includes email address and telephone numbers.	This information is necessary for us to perform our contract with you.
Financial Data	Includes any account details, billing address, and other financial data required to process payment.	This information is necessary for us to perform our contract with you, in order to take payment.
Technical Data	includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.	Necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract Necessary for our legitimate interest (or those of a third party) in relation to presenting relevant properties and services to you.
Marketing and Communications Data	includes your preferences in receiving marketing from us and our third parties and your communication preferences.	Necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract Necessary for our legitimate interest (or those of a third party) in relation to presenting relevant properties and services to you.
Interaction Data	includes any information that you might provide to any discussion forums on our websites.	Necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract Necessary for our legitimate interest (or those of a third party) in relation to presenting relevant properties and services to you. Necessary for out legitimate interest (or those of a third party) (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Third Parties and Information	We may receive information about you if you use any of the other websites we operate. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our websites or through our services. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them. Further information on these partners are noted in part 4 of this Privacy Policy.	Necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract Necessary for our legitimate interest (or those of a third party) in relation to presenting relevant properties and services to you.
Analytics	includes third-party analytics services (such as Google Analytics) to evaluate your use of the website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.	Necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract Necessary for our legitimate interest (or those of a third party) in relation to presenting relevant properties and services to you.