How do we use your personal information?
We use your personal information for the following purposes (or otherwise described at the point of collection):
- to create and administer records about your online account (if any), to provide online services to you, including facilitating your participation in any discussion forum, and for Website and system administration;
- to improve our Website(s) and our products and services;
- for due diligence purposes, in accordance with applicable law, to assess financial, reputational, credit or insurance risks arising from any relationship or prospective relationship with you/your organisation and/or to carry out any necessary anti-money laundering checks;
- to provide you/your organisation with information or products and services that you have requested and deal with invoicing and payment;
- to send you service-related communications, to deal with communications you send us and request feedback;
- to facilitate your participation in events or competitions for which you have registered/which you have entered;
- to identify trends in the real estate sector;
- to ensure that the content, services and advertising that we offer are tailored to your needs and interests (or those of your organisation) and for business development purposes;
- to contact you directly or via our agents by mail, telephone, fax, email, SMS or other electronic messaging service with offers of goods and services or information that may be of interest to you (including information about other organisations’ goods and services). If you do not wish to receive marketing information from us, please indicate this if requested on the registration or contact form or contact us using the contact details at the bottom of this Privacy Notice. We will obtain your consent to the provision of direct marketing material to you, if required to do so by law.
Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
- group companies or affiliated entities, third party services providers and partners:
- who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or other IT infrastructure, to assist us with carrying out due diligence checks, to carry out marketing, analytics or research on our behalf or to support the delivery of services to our clients in general or pursuant to a particular engagement);
- with whom we arrange joint promotional events (for the purposes of ensuring that you do not receive direct marketing information about the event from multiple sources); or
- in the case of group companies or affiliated entities, who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to our clients and bid participants, in relation to bids and transactions with which you are involved.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
Legal basis for processing personal information.
Under applicable data protection law, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we process your sensitive personal information, we do so: (i) in the context of know-your-counterparty checks as required by applicable law; (ii) on the basis that the processing is necessary for reasons of substantial public interest; (iii) on the basis of your explicit consent; or (iv) to establish, exercise or defend legal claims.
You can choose not to provide personal information to us. However, unless otherwise indicated, the information that we request is necessary for the purposes of entering into and performing a contract with you or your organisation and/or providing services to you or your organisation and failure to provide it will impede the contracting process and/or the provision of the relevant services.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be: to provide our services to you, respond to your queries, improve our Website(s), undertake marketing, or for the purposes of detecting or preventing illegal activities.
Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards that we take to protect your personal information, our legitimate interests are not outweighed by any prejudice to your individual rights and freedoms. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who provide services to us or otherwise have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Privacy Notice and that the security and confidentiality of the information is maintained.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Our group companies, affiliated companies and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries. For example, we use a third party customer relationship management platform that entails the processing of personal information in the US.
However, we take steps to safeguard your personal information in accordance with this Privacy Notice. These include, for example, reliance on a third party service provider registration with EU-US Privacy Shield (pursuant to Article 45 of the General Data Protection Regulation).
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. If you are a client or vendor (or a representative of a client or vendor) then the information will be retained for a period of time to allow us to provide our services, to comply with applicable legal, tax or accounting requirements and, if necessary, for the establishment, exercise or defence of legal claims.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
If data protection laws apply, you have the following rights:
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Links to other websites
We link to other websites. We are not responsible for the content or privacy policies of these websites for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers nor are we authorised to make representations on their behalf. In any event, you should explore the privacy practices of those third parties.