THE SOCO WEBSITE PRIVACY POLICY

We respect your privacy and are committed to protecting your personal data.

This privacy policy will give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you contact us.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your data, your privacy rights and how the law protects you.

Who We Are

We are SOCO REAL ESTATE LTD of 35 Ballards Lane, London, N3 1XW.
We act as a data controller, which means that we are responsible for deciding how we hold and use personal information about you.

We have appointed data privacy managers who are responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact either of them using the details set out below.

Contact details

Names: Ben Harshak and Matthew Weiner
Email addresses: [email protected] and [email protected]
Postal address: 35 Ballards Lane,London, N3 1XW

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.

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

• Identity Data includes title, first name, last name and date of birth.
• Contact Data includes email address, postal address and telephone numbers.
• Financial Data includes bank account details.
• 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 this website.
• Transaction Data includes details about payments to you.

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.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Publicly available sources. We may receive Identity and Contact Data from publicly available sources such as Companies House, Land Registry and the websites for local councils.

Third-party links

This 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 our website, we encourage you to read the privacy notice of every website you visit.

How we use your personal data

We take your privacy very seriously and unless required to do so by law, we will never disclose, share or sell your personal information without your consent. Where you have consented to us processing your personal information, you are free to withdraw consent at any time.

We only use your personal data when the law allows us to. Most commonly, we will process the personal information about you that we collect, store and use for the following purposes:

• to enable us to comply with our contractual, legal and regulatory obligations;
• to pursue legitimate interests of our own or those of third parties, provided that your interests and fundamental right do not override those interests;
• to facilitate the sale and purchase of real estate;
• to manage our relationship with you;and
• to update and enhance our records.

We use cookies to:

• identify a unique session on the website;
• ensure that this unique session is recognised when moving from page to page within the site;
• ensure that any information entered is remembered;
• indicate a logged in user;
• customise a user’s view of the admin interface;
• check whethera user’s web browser is set to allow, or reject cookies; and
• track activities for website security and spam protection.

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

If you fail to provide personal data

You are not obligated to provide your personal information to us, however, as this information is required for us to be able to engage with you, or to comply with our legal obligations, we will not be able to do so without it.

Your Rights

By law you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables youto have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objectedto our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

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.

We try to respond to all legitimate requests within one month, but 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.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Ben Harshak or James Winstonin writing.

Sharing and Disclosing Your Personal Information

We will not share or disclose your personal information without your consent, other than for the purposes specified in this Privacy Policy or where the law requires us to do so.

We sometimes need to share your personal information, for the purposes specified in this Privacy Policy, with third parties such as IT and system administration services.

Where this is necessary, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy policy, the data protection laws and any other appropriate confidentiality and security measures.

As a result of us disclosing your personal information to any of the parties mentioned above, your personal information may be held by us and additionally by the parties mentioned above.

Safeguarding Measures

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

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

How long will you use my personal data for?

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.

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws.

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 if unsatisfied with how we have handled your information.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at anytime, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any queries or comments about our privacy practices, please contact our data privacy managers at [email protected] or [email protected].