Privacy Policy
(Transaction Counterparties)

Privacy policy for property transaction counterparties

The Bricklane Group (“We” or “Our”) is committed to protecting and respecting the privacy of counterparties in property transactions that we deal with. A list of Bricklane Group entities is in the Appendix

This policy sets out the basis on which any personal data we collect from counterparties (i.e. property buyers or vendors (“You”)), or that you provide to us, will be processed.

Information you give us:

You, or your appointed estate agent, conveyancer or other nominated representatives, may give us information about you by corresponding with us by phone or e-mail. The information you give us may include:

• Contact details and information to confirm your identity, such as name, address, date of birth, e-mail address and phone number
• Registered company information, such as company name, registration number, registered office, operating and trading activities, shareholders information, details on directors (current and previous) and contact details for these individuals
• Nationality and personal identification numbers e.g. driving licence number
• ‘KYC’ information, such as identification documents or other verification documents, as well as information in relation to or documents to evidence your source funds

We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.

Uses made of the information

We are only allowed to use your personal information if we have a lawful reason for doing so. We will use your information if we can satisfy that processing it is necessary:

• to arrange a property transaction with you for performance of a contract;
• in order for us to comply with a legal or regulatory obligation; and/or
• when it is in our ‘legitimate interests’. This is where we have a business or commercial interest to use your information as long as it does not overly prejudice you). This may include:

• to enable us to carry out our services
• to help identify suspicious purchasing activity – however, we do not make automated decisions on the basis of such automated profiling
• to deal with complaints or subject access requests

Please note that more than one reason for processing may apply at any given time

We use information held about you in the following ways:

To arrange a property transaction with you: Where you are seeking to buy or sell a property with a member of the Bricklane Group, we will need to process your personal data . Our use of your personal data in this way enables us to:

• take necessary steps to enter into the transaction between you and us; and
• carry out our obligations arising from any contracts;
• communicate with you in relation to the above.

To fight against fraud and meet our anti-money laundering obligations: We/our business partners have legal and/or regulatory obligations to verify your identity and perform other verification procedures to protect against fraud and comply with applicable laws.

Who do we share your information with?

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

• Another member of the Bricklane Group, or where necessary, their parent companies or contractual fund managers and appointed administrators.
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, such as our conveyancers and estate agents.
• Credit reference agencies and third party providers for the purpose of confirming your identity to meet anti-money laundering and sanctions regulations.
• Tax authorities, regulators, law enforcement bodies, government agencies, courts or other third parties where we have a duty or we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights, or to protect the rights, property, or safety of Bricklane Group entities.
• Our business service providers, including:

• e-mail, workflow and contract management and document storage providers;
• technical and support partners related to the above service providers.

• Other people where we have your consent.

We also may disclose your personal information to third parties:

• If a Bricklane Group entity, or substantially all of its assets, is acquired by a third party, in which case personal data held may be transferred.

We do not sell your data to any third parties.

How long do we keep your personal information for?

We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this policy and in order to comply with our legal and regulatory obligations. We will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.

Where do we store your personal information?

We may store or transfer some or all of your personal data in countries that are not part of the UK or European Economic Area (the “EEA”) if we consider it necessary or desirable for the purposes set out in this notice. If we do store data outside the EEA, we will take reasonable technical, organisational and/or contractual steps and put in place reasonable safeguards to ensure that your data is treated as safely and securely as it would be within the UK.

What are your rights?

As a data subject, you have various rights to protect your data, which are:

1. The right to be informed about our collection and use of personal data;
2. The right of access to the personal data we hold about you;
3. The right to rectification if any personal data we hold about you is inaccurate or incomplete;
4. The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained above, but if you would like us to delete it sooner, please contact us using the details below);
5. The right to restrict – i.e. prevent the processing of your personal data;
6. The right to data portability – i.e. obtaining a copy of your personal data to re-use with another service or organisation; and
7. The right to object to us using your personal data for particular purposes.

These rights are subject to certain limitations that exist in law. You can find out more about how and when you can exercise your rights by visiting the ICO website https://ico.org.uk. If you wish to proceed or to know more, you can do so by contacting us at info@bricklane.com.

How to complain

If you want to make a complaint about how we have handled your personal information, please contact us at info@bricklane.com and we will investigate the matter and report back to you. If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the UK’s data protection regulator – the Information Commissioner’s Office – https://ico.org.uk.

Links on our website or email communications

The website or emails that we send you may, from time to time, contain links to and from the websites of third party service providers. 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 data to these websites.

Changes to our privacy policy

We may amend this privacy policy at any time. You should check this notice on our website from time to time in order to ensure you are aware of the most recent version.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@bricklane.com.

Data Protection Officer

We have appointed a data protection officer (“DPO”), David Dixon. Our DPO has a number of important responsibilities including:

• Monitoring our compliance with the GDPR and other data protection laws;
• raising awareness of data protection issues, training staff and conducting internal reviews; and
• cooperating with supervisory authorities such as the ICO on our behalf.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO by emailing info@bricklane.com.

Appendix

Bricklane Group includes the following entities, each of which is either a data controller or data processor for its own activities