Published 19 June 2022
A ‘controller’ is a party that determines the purposes and means of data processing. ‘Processing’ essentially means doing anything with Personal Data. This includes collecting it, storing it, accessing it, combining it with other data, sharing it with a third party, or even deleting it.
References in this Policy to ‘the Website’ shall mean, collectively, our website and portal available via the domain https://noagent.properties/ and all sub- domains to that domain (for example https://ads.noagent.properties).
Protecting your privacy is important to No Agent. We are committed to protecting all Personal Data provided to us, whether by individuals with whom we do business, visitors to and users of the Website, or otherwise. Personal Data is information which relates to an identified or identifiable living individual.
This Policy explains what Personal Data we collect, how we may use and manage it and the rights you have in relation to your Personal Data. Before you provide us with any Personal Data, including browsing and using the Website, you should read through this Policy in full and make sure that you are comfortable with our privacy practices.
Please note that the Website may contain links to other websites. These third party sites are not subject to this Policy and we recommend that you check the privacy and security policies of each Website that you visit. We are only responsible for the privacy and security of the data that we collect and have no control over the actions of any third parties (including agents, our third party partners and our business users) in relation to your data.
If you have any questions or comments about this Policy or No Agent’s use of your Personal Data, please contact us by email at email@example.com
No Agent collects Personal Data from a range of individuals in the context of its business activities, including:
We obtain Personal Data which you knowingly and voluntarily disclose to us, both in an online and offline context. We collect Personal Data when you:
We may also collect information received by us from third party sources. For example, if you register through an agent rather than registering directly with No Agent through the Website, we will receive confirmation from the agent that you have registered with them locally. We will then contact you by email to validate your registration with No Agent.
If you are registered with an agent at the time that an agent on-boards its property and customer databases to the Website, we will receive your Personal Data including your name, contact details, details of the property you are selling and the history of that property through the agent, e.g. how long your property has been on the market, how many viewings you have had etc. We will only process this data on behalf of the agent and will not use this data for our own purposes unless you register with us. If you do subsequently choose to register with us, this data will move into your No Agent central profile and No Agent will become a controller of that data for the purposes of applicable data protection and privacy laws.
If you purchase products or services from our business users or partners, having accessed their website through the Website, we may collect information from these third parties as to the value of any purchases you have made, for our commission purposes.
No Agent may collect and process a range of Personal Data from users of the Website, including:
When you click through to a third party site through the Website, for example in order to purchase an item featured on Property Playground, or to enquire about a service provided by one of our third party partners, we may collect Personal Data, including the third party site you access, the value of any purchases you make and, at your option, a purchase history of the products or services that you purchase.
When you are selling or letting a property through the Website, we will collect and process additional information from you and / or from any third parties you have instructed in connection with your sale, including:
When you are purchasing or looking to rent a property on the Website, we will collect and process additional information from you and / or from any third parties you have instructed in connection with your sale, including:
When we list a property on the Website, we will collect and process certain information relating to that property. We do not generally consider this to be Personal Data but there may be circumstances where some of this information is considered to be Personal Data. This information may include:
We may also process historical property data relating to properties which have previously been marketed on the Website, including data collected from third parties, for example sold prices collected from HM Land Registry.
If you represent an agent or one of our partners, suppliers or other business contacts, including business users registered on Property Playground, we may collect and process your Personal Data in a business context, including your name, gender, job title and employer, photographic ID, email address, phone number and other business contact details, details of your business and other interests and communications with you (including notes from meetings).
When you use the Website, we collect certain technical information that is sent by your browser to the Website. This includes your IP address, browser type, operating system and platform, language, time zone setting and device information. We will also collect certain information about your visits to the Website including login information, access times, URL clickstream to, through and from the Website (including dates and times), properties or other products / services viewed or searched for, page response times, download errors, length of visits to pages; page interaction information (scrolling, clicks) and methods used to browse away from the page.
We process your Personal Data for the following purposes:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data under applicable law as this data will not directly or indirectly reveal your identity.
We may use your Personal Data to provide you with marketing communications, including sending you:
We may also carry out lead profiling based of your use of the Website, for example, any indications of intention to book a valuation appointment or viewing.
We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences at any time, you can: (i) log into your central profile to adjust your settings; (ii) follow the opt-out links on any marketing messages sent to you; or (iii) contact us at firstname.lastname@example.org and request that we no longer send you marketing communications. Use of the Website is never contingent on your consent to marketing.
We also use your Personal Data to monitor the effectiveness of our marketing communications.
When you apply for a job via the Website or otherwise, we will collect additional more specific Personal Data about you, such as your qualifications, career history, third party references and interview notes. We may also ask you for other information, for example your interests and the types of jobs you are interested in. Any Personal Data you provide to No Agent in relation to a job vacancy will be processed in accordance with our Employment Candidate Privacy Notice.
In order to comply with applicable data privacy laws, No Agent is required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for No Agent processing your Personal Data will typically be one of the following:
We process your Personal Data where it is necessary for one or more of the following legitimate interests:
Agents and other parties instructed on a transaction
No Agent will share your Personal Data with specified agents as necessary in connection with your use of the Website, including when you book a property valuation or viewing with an agent, when you make or accept an offer on a property and to facilitate all necessary communications between purchasers / tenants, agents and sellers / landlords.
When you register an interest in properties via MatchMaker, Secret Property, Sneak Peek, ChainMaker or any enquiry that relates to a property on our site, your contact information will be shared with the relevant agent to enable them to contact you to discuss your interest. This includes making use of SmartVal to obtain a valuation on your property.
When you make a booking with a particular agent, your No Agent central profile data will be shared with that agent in order that the agent may create their own ‘local profile’ for you, whether within the No Agent platform or on the agent’s own system. Your central profile and any local profiles you hold with agents will be linked.
When you update your property search criteria in your central profile this Personal Data will be shared with all agents with whom you hold a local profile, in order that such local profiles may be updated on the same basis.
At your option, we may provide updates to parties instructed on your property transaction, such as solicitors, mortgage brokers etc., for example, ‘mortgage agreed’, ‘contracts signed’ etc.
No Agent may also use such reviews in other promotional material and media for our advertising and promotional purposes.
We use third party sign-in / authentication tools provided by Google for the purposes of you signing into the Website. Your login credentials (e.g. username and password) will be shared with Google for the purposes of verifying your sign-in only. We do not store your password.
Third Party Links Products and Services
Where you wish to enquire about or purchase third party products and services offered via the Website (including via Property Playground), we will share your Personal Data with the relevant third party provider, as necessary in connection with your enquiry or purchase. If you are a business user of Property Playground or you represent one of our third party partners offering services on the Website, we will share your business contact details with users who are potential customers for the products or services that you offer.
No Agent may share your Personal Data with people within our company who have a ‘need to know’ that data for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within No Agent.
We may disclose your Personal Data to third parties including the authorities, No Agent’s advisors, suppliers of IT services and third parties engaged by No Agent for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from No Agent’s Website; for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation; and to enforce No Agent’s Website Terms and Conditions of Use.
We may disclose your Personal Data to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets.
Finally, we may share non-Personal Data with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-Personal Data of numerous people together so that the data does not relate to any one person. De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.
Please note that any person to whom No Agent may disclose your Personal Data under this Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country.
Whenever we transfer Personal Data across borders, we take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated in accordance with this Policy. You can request a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances, by emailing us at email@example.com
No Agent takes all reasonable technical and organisational security measures to protect Personal Data from accidental or unlawful destruction, accidental loss and unauthorised access, destruction, misuse, modification or disclosure.
Your Personal Data is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records (including Personal Data) are destroyed or erased from our systems, or fully anonymised, when no longer required. The amount of time that records are kept for varies depending upon the type of Personal Data they contain, in accordance with our data retention policy. In particular:
Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.
We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Personal Data even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, email us at firstname.lastname@example.org
If you have a concern or complaint about how No Agent has used your Personal Data, as a first step, you should raise this in writing with No Agent, by contacting our Data Protection Officer at email@example.com
If you are not satisfied with the handling of your concern or complaint by No Agent, you can escalate this to your national Data Protection Authority.
We reserve the right to modify or amend this Policy at any time by posting the revised Policy on the Website. It is your responsibility to review the Policy every time you submit Personal Data to us.
noagent.properties includes social media features, such as sharing or following buttons. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly.
We think it is very important to hear what you have to say about our policies. If you have any feedback about this Policy, please e-mail us at firstname.lastname@example.org