This policy was last updated on 20th July 2016.
1. WHO HOLDS YOUR INFORMATION?
1.1 We shall hold your information and for the purpose of the Act, the Data Controller is Click To Purchase No 2 Limited of 2nd Floor, Titchfield House, 69-85 Tabernacle Street, London EC2A 4RR. We are registered as a Data Controller with the Information Commissioners Officer under Registration Number Z2976715. Click To Purchase No 2 Limited is registered as a company in England and Wales under Company Number 07133312.
2. INFORMATION WE MAY COLLECT FROM YOU
2.1 We may collect and process data about you including, without limitation, your name, email address, phone number and other personal information provided by you when you:
2.1.1 fill in forms on our site;
2.1.2 request further information relating to our service;
2.1.3 register to enable you to view full information relating to a property which is listed as for sale by Click to Purchase on the site;
2.1.4 report a problem with our site;
2.1.5 correspond with us in writing, by emai or, otherwise, or contact us by other means (we may keep a record of such communications);
2.1.6 respond to our surveys that we use for research purposes, which we have asked you to complete (although you do not have to respond to them);
2.1.7 make any offers and bids, and any transactions you carry out through our site to the fulfilment of your purchases.
2.2 With regard to each of your visits to our site we may automatically collect including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
2.3 Other third party sources, such as business partners, sub-contractors in technical and payment services, banks, credit reference agencies, advertising networks, analytic providers and search information providers may also provide your information to us. We may combine the information from third party sources with the information we may collect about you. We may use this information and the combined information for the purposes set out below (depending on the types of information we receive).
3. IP ADDRESSES AND COOKIES
3.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
4. WHERE WE STORE YOUR PERSONAL DATA
4.1 Like many companies, we store data on Amazon Web Services servers using their European Union cloud. For additional information, please visit Amazon Web Services EU Data Protection FAQ
4.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
5. USES MADE OF THE INFORMATION
5.1 We use information held about you in the following ways:
5.1.1 To ensure that content from our site is presented in the most effective manner for you and for your computer.
5.1.2 As part of our efforts to keep the site safe and secure.
5.1.3 To administer our site and for internal operations, including, without limitation, troubleshooting, data analysis, testing.
5.1.4 To notify you about changes to our service and to our site.
5.1.5 To administer your account or registration you may have with us.
5.1.6 To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
5.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you, and we or they may contact you about these by post or e-mail.
5.3 If you have previously supplied us with your data we will only contact you by e-mail with information about services similar to those which were the subject of your original communication with us.
5.4 On the first occasion you supply us with your data, and where we permit selected third parties to use your data, we (or they) may contact you by electronic means.
5.5 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please advise us by email at email@example.com
5.6 Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our site in order to measure interest in the various areas of our site and to inform advertisers as to how many consumers have seen or “clicked” their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you.
6. DISLOSURE OF YOUR INFORMATION
6.1 We may disclose your personal information to third parties:
6.1.1 To assist us in the improvement and optimisation of the site we may share your information with analytics and search providers.
6.1.2 To prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you.
6.1.3 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
6.1.4 If Click to Purchase No 2 Limited, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about those who have supplied their data to us will be one of the transferred assets.
6.1.6 In the event that you refer any dispute between us to the ODR Platform http://ec.europa.eu/consumers/odr, and/or we agree to engage in any alternative dispute resolution (ADR) procedure with you through the ODR Platform, then to the extent that your personal data is relevant to the dispute we may disclose it to the European Commission, as operator of the ODR Platform, and to any ADR provider appointed to deal with the dispute.
7. SALE AND SUPPLY
7.1 We shall comply with the following restrictions in relation to your personal information:
7.1.1 We shall not sell your personal information to anyone else;
7.1.2 Subject to the exceptions in point 7 above, we shall not supply your personal data to anyone else so that they can use it for their own purposes.
8. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
8.1 We aim to keep your personal data for a period no longer than we deem necessary. This period may depend upon the marketing preferences you have selected and may be unlimited.
8.2 In particular, we may keep your personal data for as long as we have your consent to receive marketing information from us, and for as long as necessary for us to comply with the law and to respond to any disputes or queries that may arise during that period.
9. YOUR RIGHTS
9.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us at Click to Purchase No 2 Limited, 2nd Floor, Titchfield House, 69-85 Tabernacle Street, London EC2A 4RR or by sending an email to firstname.lastname@example.org
9.2 Our site may, from time to time, contain links to and from the websites of our advertisers and affiliates. 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.
10. ACCESS TO INFORMATION
10.1 The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.