This Privacy Notice is v4.1 and is valid from 6th December, 2023. It replaces and supersedes all other Privacy Notices associated with Express Estate Agency.

We take your privacy very seriously. This Privacy Policy details what personal data we collect and how we shall use it.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Our Name & Contact Details.

The Data Controller of your personal data is Express Estate Agency. This means that Express Estate Agency decides how your personal data is processed and for what purposes. Our contact details are:

Email: Compliance@expressestateagency.co.uk

Web: https://expressestateagency.co.uk

Telephone: 0333 016 5458

In writing: Express Estate Agency, St George's House, 56 Peter Street, Manchester M2 3NQ

Data Protection Officer Contact Details.

In observance of the UK /General Data Protection Regulation and the Data Protection Act 2018, Express Estate Agency have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing Compliance@expressestateagency.co.uk or writing to:

Data Protection Officer,

St George's House,

56 Peter Street,

Manchester,

M2 3NQ

For what purposes do we process personal data, and what are the lawful bases by which we process data?

Express Estate Agency processes your Personal Data for the following purposes:

For What Purposes Do We Process Personal Data? "Express Estate Agency processes your data to..."	What is the lawful basis by which we process the data?
Supply, perform, manage and fulfil our products and services to you	Contract
Make and manage customer payments	Contract
Manage fees and charges due on customer payments	Contract
Communicate with customers to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications;	Contract
Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail and push notifications;	Consent
Communicate with customers on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications;	Legal Obligation
Communicate with customers on matters where we have a legitimate Interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications;	Legitimate Interest
Direct market our new products and services to existing Express Estate Agency's customers;	Consent Legitimate Interest where appropriate
Request specific consent to share your personal data with specific fulfilment partners for them to direct marketing specific aligned/similar products/services;	Legitimate Interest
Share your personal data with specific fulfilment partners for direct marketing purposes about specific aligned/similar products/services;	Legitimate Interest
Verify the identity of individuals where necessary including for Subject Access Requests (SAR);	Legitimate Interest
Conduct credit, fraud prevention and anti-money laundering checks	Legal Obligation
Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail;	Legal Obligation
Respond to your Individual Rights requests and other requests regulated by data protection law;	Legal Obligation
Gather feedback for service and product improvement via email, telephone, SMS text, postal mail;	Legitimate Interest
Share testimonials, case studies and feedback on Express Estate Agency on website and future marketing;	Consent
Resolve complaints and/or disputes;	Legitimate Interest
Request continuation of Consent prior to consent expiry;	Consent
Exercise our rights as set out in agreements or contracts	Contract
Collect payments or arrears should we have the need to do so;	Legitimate Interest
Protect our organisation, staff, associates, suppliers, partners and clients;	Legitimate Interest
Prevent, detect and investigate fraud;	Legal Obligation Legitimate Interest
Prevent, detect and investigate crime;	Legal Obligation Legitimate Interest
Comply with the law;	Legal Obligation
Fulfil our statutory or regulatory obligations;	Legal Obligation
Maintain our own accounts and records;	Legal Obligation
Provide reporting, analytics and product/service improvement (including training);	Consent Legitimate Interest
Improve and maintain data accuracy or completeness;	Legitimate Interest Legal Obligation
Track your email engagement;	Legitimate Interest
Personalise your online experience;	Consent Legitimate Interest
Conduct market research.	Consent Legitimate Interest

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may use your personal data to:

• Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services, if your details were received during the course of a sale/contract and for which you have been offered a simple means to opt out of direct marketing;
• Maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
• Prevent, detect and investigate fraud and crime;
• Reporting, analytics and product/service improvement, (including internal training);
• Resolve complaints and/or disputes;
• Improve data accuracy or completeness;
• Track your email engagement;
• Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
• Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service.

What personal data do we collect?

We use various kinds of personal information, and group them together like this.

Type of Personal Information	Description
Contact	Where you live and how to contact you.
Financial	Your financial position, status and history.
Contractual	Details about the products and services we provide to you.
Behavioural	Details about how you use our products and services.
Communications	What we learn about you from conversations, emails and letters between us.
Open Source Data and Public Records	Details about you that are in public records and information about you that is openly available on the Internet.
Usage Data	Other data about how you use our products and services.
Documentary Data	Details about you that are stored in documents in different formats, including copies. This could include things like your passport, drivers licence, birth certificate or utility bill.
Socio-demographic	This includes details about your work or profession, nationality, education and where you fit into general social or income groups..
National Identifier	A number or code given to you by a government to identify who you are, such as a national insurance number or passport number.

Sharing your personal data

Express Estate Agency may choose to share your personal data internally and/or externally to the business. Where we choose to share your personal data, we shall do so for the following reasons:

• Where we have your "Consent" to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to "Your Right to Withdraw Consent" section below;
• Where necessary to fulfil the services and/or products we are "Contracted" to provide to you;
• Where we have a "Legal Obligation" and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
• Where we have "Legitimate Interest" to do so, including:
  • For the purposes listed in the "What are our legitimate interests for processing your data?" section above.
  • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should Express Estate Agency establish or become part of a group.
  • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with Express Estate Agency's aim of helping their customers buy, sell and/or create the house of their dreams in a fair, lawful and transparent manner that we do not currently provide ourselves.
  • Where 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case we would contact you using Legitimate Interest to request specific Consent to share your personal.
  • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
  • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:

Categories	Who we use	Privacy Notice
Childcare Vouchers Provider	KiddiVouchers	TBC
	Mayflower Disclosure Services LTD	TBC
IT Provider	8x8	8x8 Privacy Notice | 8x8
	Dynamologic	TBC
Email Management Service Provider	Mailchimp	TBC
Printing Services Provider	Vista Print B.V.	TBC
Compliance Providers	CSS Assure	Privacy Policy | CSS Assure
Electronic Signature	Adobe eSign	Adobe Privacy Centre
Board Erecting	Boards Online	BoardsOnline | National Board Erecting (boards-online.com)
Payroll Services Provider	Charities Trust	Giving feels good | Charities Trust
	Cycle to Work	https://www.cycle2work.info/privacy
	BizNus Payroll	https://biznuspayroll.co.uk/privacy-policy-main-v-1-0/
	CallCredit	TBC
	Credas	Credas platform privacy notice
	CSM Talent	TBC
	Pingdom	https://www.pingdom.com/security/
	PropertyPal	https://www.propertypal.com/privacy
	ReachPub	TBC
	Homelet Connect	https://homelet-letting-agents.co.uk/privacy-policy
	S LIS	TBC
Pension Provider	Now Pensions	https://www.nowpensions.com/legal-information/privacy-policy/
	Complete Business Solutions	https://www.complete.co.uk/documents/PD05_Data-Protection-Policy.pdf
Digital Document Storage Provider	Dropbox	https://www.dropbox.com/privacy
Marketing (COS)	eHouse	ehouse
	Meero	Privacy Policy Meero - 2021 EN.docx
	O2	O2 | Terms and Conditions | Privacy Policy
Marketing	FLOW	TBC
	Frama	https://framacph.com/pages/privacy-policy
	Gas-Elec Safety Systems	https://www.gas-elec.co.uk/privacy-policy-2/
	Grade-A Alternative Properties Ltd.	TBC
	HillSide	TBC
	HouseViz	https://houseviz.com/privacy-policy
	Answer4U	TBC
	Residential Support Ltd.	TBC
Admin	Datashred	https://www.datashredders.co.uk/privacy-policy/
	DezRez	https://www.dezrez.co.uk/policy-information
	EHouse	https://www.ehouse.co.uk/privacy
	Elements Property	https://elementsproperty.co.uk/privacy/
	Enterprise	https://enterpriseuk.co.uk/privacy-policy/
	Essential Hygiene	https://essential-hygiene.com/it-policy/
	Everything Lettings	https://www.everything-lettings.co.uk/
	No Letting Go	TBC
	Rentshield Direct	TBC
	Pinstripe Inventory Specialists	TBC
HR	Indeed	https://www.indeed.com/legal/indeed-jobs
	Jupix	https://jupix.com/privacy-policy
	Magda	TBC
	M24Seven	https://m247.com/privacy-policy/
	NewsQuest	https://www.newsquest.co.uk/privacy-policy/
Finance	Sage	https://www.sage.com/en-gb/legal/privacy-and-cookies/
	Smart Numbers	https://smartnumbers.com/privacy-notice/
	TextMagic	https://www.textmagic.com/privacy-policy/
	The Kiosk	TBC
	TravelLodge	https://www.travelodge.co.uk/about/privacy-policy/
	TrustPilot	https://uk.legal.trustpilot.com/for-businesses/business-privacy-policy
	Viewber	https://viewber.co.uk/privacy-policy
	Viking	TBC
	Virgin Media	https://www.virginmedia.com/legal/privacy-policy
	Virtual 360 (HouseViz)	TBC
	Access2View	TBC
	Weightmans	Privacy Policy
	Whereby	https://whereby.com/information/tos/privacy-policy/
	WorldPay	https://online.worldpay.com/terms/privacy
Digital Conferencing Provider	Zoom	Zoom Legal Compliance
	Media Temple	TBC
	SENGRID	TBC
	Sherweb	TBC
	Twilio	https://www.twilio.com/legal/privacy
	Zoopla	Zoopla Privacy
Insurance	Policy Bee	Privacy Policy - Bee-Ethical
	The Property Ombudsman	Privacy policy | Ombudsman Services (ombudsman-services.org)
	Rightmove	Rightmove Privacy Policy
	S1Homes	S1 Homes NewsQuest
	Amazon	https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ
	Arkline Legal Agency	https://www.arklineuk.co.uk/
	Andrew Wilson & Co	TBC
	Hill Dickinson	TBC
	Longespe	TBC
	JS	TBC
	DC	TBC
	Birchall Blackburn	TBC
	PLS	TBC
	JMW	TBC
	Wallace Hodge	TBC
	Strefford Tulip	TBC
	Oakley IFA	TBC
Delivery Service Provider	Evri (Previously known as Hermes Parcelnet Ltd.)	https://www.evri.com/privacy-policy
	UPS	https://www.ups.com/gb/en/support/shipping-support/legal-terms-conditions/privacy-notice.page
Travel Services Provider	Easyjet Airline Company Limited	https://www.easyjet.com/en/policy/privacy-notice
Accommodation Service Provider	Premier Inn	https://www.premierinn.com/gb/en/terms/privacy-policy.html
	Travelodge	https://www.travelodge.co.uk/about/privacy-policy/

Selling your personal data

Express Estate Agency may choose to sell your personal data.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

Where we choose to sell your information, we shall do so in the following circumstances:

• Where we have your "Consent" to do so;
• Where we have a "Legitimate Interest" to do so, including;
• • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

Financial Services
Banking	Breakdown and Recovery Services	Car Insurance	Claims Management Services	Financial Products	Funeral Plan
Home & Contents Insurance	Legal Services - Conveyancing, Wills, Trusts etc	Life Insurance	Mis-Sold Financial Products	Mortgages	Pre-paid Funeral Plans
Private Medical Insurance	Travel Insurance
Other
Charities	Cosmetic Surgery	Entertainment, Gaming, Leisure	Gambling and Lotteries	Health and Beauty	Mail Order
Marketing services	Public Sector	Publishing/Media	Retail & lifestyle	Trace, Asset Repatriation and Debt Collection	Travel
Home, Property & Related Industries
Bathroom Fitters	Blacksmith	Childcare, creche and playgroups	Cleaning companies	Do It Yourself businesses	Doctors
Dentists	Door, window and conservatory suppliers and services	Drainage & Damp Specialists	Driveway Specialists	Employment & Recruitment	Electrical Services
Fast Moving Consumer Goods	Floor fitter	Garden Decking, Improvement, Landscaping, Management, Maintenance & Equipment		Gas & Heating Services	General Building & Home Improvement Services
Gyms & Health Clubs	Health Providers	Handy man services	Home Entertainment Providers / Installation	Home Furnishings	Window Cleaners / Bin Cleaners / Drive & Patio Cleaners
Home / Purchase Survey Services	Home Removal Companies	Home Security Services – incl CCTV & Alarms	Joiner & Carpentry Services	Kitchen Designer and Fitter Services	Locksmiths

Home, Property & Related Industries
Loft conversion services	Log burner services – wood supplies and chimney sweep	Mobile Telecommunication	Optometrists	Painting & Decoration Services	Pest control services
Pets Services: kennelling, catteries, groomers & vet services	Plaster / renderer services	Plumbing Services	Renewable Energy Services	Roofer	Schools & Education facilities
Septic tank & waste removers	Sports, recreation and social clubs	Stonemason	Storage Providers	Swimming pool, swim spa and hot tub services – incl installation, maintenance	Tilers
Tree Surgery	Utilities Providers – Gas	Wine cellar services	White Goods & Appliance Providers	Waste Removal & Skip Hire

International Personal Data Transfer

Express Estate Agency may transfer personal data to countries outside of the UK and/or EEA. Specifically, we use data processors based in Pakistan, Canada and the United States. If data is transferred outside of the EEA, Express Estate Agency will put appropriate transfer mechanisms in place.

Personal Data Retention Period

Express Estate Agency has the following data retention policies:

• Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
• Where you have purchased, or enquired about purchasing, an Express Estate Agency product or services, we shall retain any personal details applicable to the contract delivery for a period of 15 years (name, email, telephone, postal address). During this time, we may contact you using legitimate interest to market additional products or services.
• Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number, company, job title) for a period of 7 years. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you
• Where you have signed up to receive information emails from Express Estate Agency, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 7 years, or until you withdraw your consent.

When we no longer need this information, we will erase or anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

• Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here. In most cases Express Estate Agency will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 30 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
• Your right to rectification.You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about your Right to Rectification here.
• Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. You can read more about your Right to Erasure here.
• Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about your Right to the Restriction of Processing here.
• Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. You can read more about your Right to Object to Processing here.
• Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your individual rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing compliance@expressestateagency.co.uk or writing to:

Data Protection Officer, Express Estate Agency, St George's House, 56 Peter Street, Manchester, M2 3NQ

Automated decision-making, including profiling.

Express Estate Agency does not use currently use automated decision-making tools or profiling in the processing of your personal data.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK's Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, Express Estate Agency would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing compliance@expressestateagency.co.uk, or writing to:

Data Protection Officer, Express Estate Agency, St George's House, 56 Peter Street, Manchester, M2 3NQ

If your complaint has not been resolved, you can lodge a complaint with the Information

Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire.
SK9 5AF.

Or by telephone on 0303 123 1113.