GDPR & Privacy Policy

1. Who we are

Noagent Properties LTD, referred to in this policy as No Agent, we, us, or our, is the controller for the personal data described in this policy. We are registered in England and Wales under company number 16170848 and our registered office is 52 Stirling Rd, London E17 6BT.

A controller decides why and how personal data is processed. Processing includes collecting, storing, accessing, combining, sharing, and deleting personal data.

This policy applies to our website and portal available at https://www.noagent.properties/.

If you have questions about this policy or our handling of personal data, contact us atsupport@noagent.properties.

2. What this policy covers

This policy explains what personal data we collect, how we use it, the lawful bases we rely on under the UK GDPR and Data Protection Act 2018, who we share data with, how long we keep it, and what rights you have.

We aim to keep this notice clear and detailed so you can understand how your information is used when you browse the site, create an account, add a listing, use NOVA search, contact us, or use the admin and moderation tools.

3. Who we collect personal data from

We collect personal data from the following groups of people:

• users of the website;
• representatives of agents, partners, suppliers, and other business contacts;
• contractors;
• people who contact us by any means; and
• job applicants.

In some cases we may also receive data from third parties, for example from agents who onboard property and customer data to the platform, or from business partners where you interact with them through the website.

4. How we collect your personal data

We collect information that you knowingly and voluntarily provide to us, both online and offline. This includes when you:

• register with the website;
• visit and use the website or complete one of our web forms;
• contact our customer service team or request information from us;
• communicate with us by telephone, email, social networking websites, third party applications, and other technologies;
• create or edit a property listing;
• use NOVA search and related property search tools;
• open the add listing page at /property/new/;
• use a location based search such as near me, if you choose to allow device location access; and
• interact with our support, moderation, or admin teams.

We may also receive information from third party sources. For example, if you register through an agent rather than directly through the website, we may receive confirmation from the agent that you registered with them locally. If you are registered with an agent when they onboard property and customer databases to the website, we may receive the relevant personal data and property history through that agent.

We may also receive data from Google when you use Google sign in. We do not store your password.

5. What personal data we collect

We may collect and process the following categories of personal data.

General user data

• registration information including name, login credentials, address, phone number, and email address;
• your property search criteria, including property type, cost, and location, which we use to return the results you ask for;
• photos, images, videos, likes, comments, pins, and other interactions you post within Property Playground;
• information you provide through surveys, competitions, discussion boards, or social media features;
• recordings of calls with us where applicable;
• property alerts you set up on the website; and
• communications you send to us.

Seller and landlord data

• the agent you have instructed to sell or let your property;
• property status such as on the market, sold subject to contract, not on market, or currently rented;
• price or rent expectations;
• availability for viewings;
• feedback from viewers or other users;
• offers received on the property;
• chain related information, solicitors, or other transaction details where relevant;
• expressions of interest regarding your property;
• your or your tenants proposed move out date; and
• the status of the sale or let following acceptance of an offer.

Purchaser and tenant data

• any agents you have registered with;
• property buying or renting status such as cash, mortgage, investment, live in, or first time buyer;
• feedback you provide on properties you view;
• offers you make on properties;
• chain details, mortgage provider details, or solicitor details where relevant;
• expressions of interest in certain areas or property types;
• availability to view properties and preferred move in date;
• the names and relationship of anyone moving with you; and
• the status of your purchase or rental after acceptance of an offer.

Property data

• images and floor plans;
• asking price or rent;
• sales history or sold price;
• property address or location;
• property description;
• property type such as detached or terraced;
• tenure such as freehold or leasehold;
• local area information including nearby schools and amenities;
• digital valuation; and
• agent valuation.

We do not generally treat property data as personal data, but some of it can become personal data depending on the context.

Business contact data

• name, gender, job title, and employer;
• photographic ID where needed for business or verification purposes;
• email address and phone number;
• other business contact details;
• details of your business and other interests; and
• communications with you, including notes from meetings.

Technical data

• IP address, browser type, operating system, platform, language, time zone setting, and device information;
• login information and access times;
• URL clickstream data to, through, and from the website;
• properties or products and services viewed or searched for;
• page response times, download errors, length of visits, and page interaction information such as scrolling and clicks; and
• methods used to browse away from the page.

Under UK GDPR, IP addresses, location data, and online identifiers can be personal data. We treat them carefully and only use them for clear and limited purposes.

We do not use your search queries for marketing or unrelated profiling, and we do not maintain a separate searchable database of your search terms as a customer history record. Search terms are used to process the search you ask us to run. They may still appear in your browser history or in short term technical logs that are needed to operate and secure the site.

Location based search data

If you choose to use a location based search such as near me, we may ask the browser for permission to access your device location so we can search for nearby properties. This is optional and only used for the search you requested. We do not use precise device location for marketing, and we do not store exact GPS coordinates for the telemetry feature.

Security and listing telemetry

We collect limited security telemetry when someone visits the add listing page or submits a listing. This is designed to help us prevent spam, scams, abuse, and unauthorised activity, and to support moderation and security investigations.

We do not use this telemetry for marketing, selling to third parties, or unrelated profiling. We also do not use it to make solely automated decisions that produce legal effects or similarly significant effects about you.

• submission identifier;
• timestamps for the start and completion of the submission;
• submission status such as started, completed, draft, or failed;
• property ID once a listing is created;
• contact email where available to help correlate the submission with the listing owner or account;
• masked IP information and hashed IP fingerprint;
• approximate country and region where available from request headers;
• user agent;
• page or flow information necessary to correlate the submission; and
• retention metadata such as expiry timestamps.

We do not collect exact GPS coordinates for this telemetry feature. Where geo headers are not available, country and region may not be recorded.

6. Why we process personal data

We process personal data for the following purposes:

General purposes

• to provide the website and our services;
• to register you as a user, maintain your account, and save your preferences;
• to distinguish you from other users;
• to link your central profile with any local profiles held with agents;
• to process and respond to enquiries, complaints, and other communications;
• to communicate with you about property transactions and potential property transactions;
• to allow you to update personal data we hold about you;
• to enable you to search the website for properties and update search criteria;
• to provide service updates and notify you of changes;
• to provide information about products and services that may interest you;
• to identify and show property trends, historical market trends, and valuations;
• to allow access to previous house sale prices in your area;
• for commercial purposes, including building and improving a property database;
• to improve the relevance of search results and customise the website experience;
• to contact you for feedback and to notify you about policy changes;
• to provide a faster and more useful service and facilitate direct communication between users and agents;
• to enable access to products and services offered by partners and business users;
• to allow participation in competitions and promotions;
• to improve and optimise the website, including security measures;
• for internal operation, troubleshooting, testing, analysis, statistics, and surveys;
• to provide services to agents that register with us;
• to communicate with third party contacts and manage our relationships with agents and partners;
• to calculate and recover commission where due;
• to carry out analytics on website use;
• to comply with laws and regulations; and
• for other business related purposes such as contract management, records management, legal, regulatory, and internal investigations.

Seller and landlord purposes

• to notify you that we have received your details from an onboarded agent and activate your central profile at your request;
• to notify you that buyers or tenants are interested in properties in your area;
• to provide agent recommendations and introductions;
• to allow you to book property valuations;
• to advertise your interest in selling or letting your property;
• to create a high level ad for your property before it goes live;
• to advertise your property on the website;
• to introduce you to prospective purchasers or tenants;
• to notify purchasers or tenants of your availability for viewings;
• to notify you of viewings booked at your property;
• to provide feedback from viewers;
• to inform you of offers made on your property; and
• to enable negotiation with purchasers or tenants through the platform.

Purchaser and tenant purposes

• to register expressions of interest or buyer ads regarding properties or areas that interest you;
• to notify you of properties that may interest you and invite you to view them;
• to notify agents, sellers, or landlords that you may be interested in viewing a property;
• to transfer enquiries or requests to book a viewing to the relevant agent and enable booking;
• to collect your feedback and share it with relevant agents and sellers or landlords;
• to invite you to a second viewing or to make an offer;
• to pass offers to the relevant agents and sellers or landlords; and
• to update you on properties you have viewed and offers you have made.

Marketing and communication purposes

• to send direct marketing communications about our products and services and those of partners and trusted businesses where allowed;
• to send communications on third party social media platforms where permitted;
• to profile leads based on use of the website, for example where someone indicates interest in a valuation or viewing;
• to manage marketing preferences and opt outs; and
• to monitor the effectiveness of marketing communications.

Recruitment purposes

If you apply for a role, we may collect qualifications, career history, third party references, interview notes, interests, and job preferences. We process recruitment data in accordance with our Employment Candidate Privacy Notice where applicable.

Security purposes

We process technical data and security telemetry to secure our network and systems, detect abuse and fraud, prevent spam, investigate incidents, and protect the website and our users.

7. Our lawful bases

Under the UK GDPR, we rely on one or more of the following lawful bases depending on the activity:

• consent;
• contract;
• legitimate interests; and
• legal obligation.

For example, we may rely on contract to provide services you ask for, consent for certain cookies or device location access, legitimate interests for security, fraud prevention, platform improvement, and moderation, and legal obligation where the law requires us to keep or disclose information.

Where we rely on legitimate interests, we apply a balancing test and record the relevant interests, necessity, and impact on your rights. The ICO guidance on legitimate interests recognises security, fraud prevention, and service improvement as common examples where legitimate interests may apply.

8. Who we share personal data with

We may share personal data with the following types of recipients where necessary and proportionate:

• agents and other parties instructed on a transaction;
• service providers who host the site, run databases, send email, provide analytics, or help with moderation and security;
• Google, where you use Google sign in or where we use Google services to support the website;
• third party providers when you enquire about or purchase their products or services through the website;
• our professional advisers, such as lawyers and accountants;
• authorities, regulators, courts, or law enforcement where required or allowed by law;
• buyers or sellers in the event of a sale, merger, or transfer of assets;
• our internal staff and contractors on a need to know basis; and
• selected partners or business users where the service you request requires it.

We may also share aggregated or de identified data that does not directly identify you.

Once we share data with an agent or partner, their privacy policy will govern how they use it. We recommend checking their policy before providing further details.

We do not sell your personal data.

9. Google sign in and third party services

We use third party sign in tools provided by Google for website authentication. Your login details are shared with Google only as necessary to verify sign in. We do not store your password.

The website may also link to third party sites. Those third party sites are not governed by this policy. Please read their own privacy notices before sharing personal data with them.

10. International transfers

Some of the people or service providers we share data with may be outside the UK. When personal data is transferred across borders, we take legally required steps to ensure that appropriate safeguards are in place.

Where required, you can ask us for more information about the safeguards used for international transfers by emailing support@noagent.properties.

11. Security

We use reasonable technical and organisational measures to protect personal data from accidental or unlawful destruction, accidental loss, unauthorised access, modification, misuse, or disclosure.

We keep limited security telemetry separate from the main listing records and restrict access to authorised users only.

12. Retention

We keep personal data for no longer than is necessary for the purposes for which it was collected.

• property data may remain on the website as historical data once a property is sold, let, or otherwise archived;
• user enquiry and correspondence data is retained for 2 years;
• telephone call recordings are retained for 3 months;
• registration information is retained while your central profile remains open and is deleted when you close your account;
• general website use data such as competitions, promotions, surveys, and third party site interactions is retained for 2 years;
• interactions on social media platforms are retained for as long as they remain on the relevant platform, and we do not copy or store them separately; and
• listing telemetry is retained for up to 60 days unless we need to keep it longer for security, dispute resolution, or legal reasons.

Where possible, we anonymise, de identify, or aggregate data rather than retaining it in identifiable form.

13. Your rights

Depending on the circumstances, you may have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data in some circumstances;
• request restriction of processing in some circumstances;
• object to processing based on legitimate interests, including direct marketing;
• request portability in some cases;
• withdraw consent at any time where processing is based on consent; and
• complain to the ICO if you are unhappy with how we handle your data.

We may need to ask for proof of identity before responding to a request. In some cases, exemptions under the law may mean that we cannot comply with a request in full.

To exercise these rights or contact our data protection contact point, email support@noagent.properties.

14. Cookies and similar technologies

We use cookies and similar technologies when you visit the website. Under PECR, we explain what these technologies do and why we use them. Where required, we ask for consent before placing non essential cookies.

Cookies may be used for authentication, preferences, analytics, and security. You can control cookies through your browser settings and any consent tools we provide.

The ICO guidance says this information should be clear and comprehensive, so we aim to explain our purposes in plain language.

15. Social media features

The website may include social media features such as sharing or following buttons. These features may collect your IP address, the page you are visiting, and may set a cookie or similar identifier so the feature can work properly.

These features are either hosted by a third party or directly on our website. The privacy policy of the relevant third party will apply to those features.

16. Concerns and complaints

If you have a concern or complaint about how we use your personal data, please contact us first at support@noagent.properties.

If you are not satisfied with our response, you can raise the matter with the ICO, which is the UK data protection regulator.

17. Changes to this policy

We may update this policy from time to time. The latest version will always be posted on this page. It is your responsibility to review the policy when you use the website or submit personal data to us.

18. Related documents

For the full terms that govern use of the website, please see our Terms of Use.

19. Your feedback

We welcome feedback about this policy. If you think anything should be clearer, please email support@noagent.properties.