1.2 For the purposes of this policy “Total Buying Abroad”, “TBA”, “I”, “we”, “us” means Total Buying Abroad Limited.
1.3.1 all our dealings with you in any capacity; and
1.3.2 all information about you supplied to us whether supplied by you, a third party or through web server logs.
- About Us
2.1 Total Buying Abroad Limited is the data controller and responsible for your personal data.
2.2 You can contact us about privacy issues or comment or complain about our privacy practices by contacting our data privacy manager, Sara Janion, at email@example.com or at Office 2, Viscount House, River Lane, Chester, CH4 8RH.
2.3 If you do have a question or concern about our use of your personal data, we would be grateful for the chance to try to help you. Please contact us in the first instance using the data privacy manager’s contact details above.
2.4 You always have the right to make a complaint about our use of your personal data at any time to the Information Commissioner’s Office (“ICO”). The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk).
- The information we collect about you
3.1 The data we collect about you is made up from the information you and others give us during your use of the Website and our Services and during our communications with you.
3.2 When you use our site to obtain services, download our publications or make an enquiry with us we will ask you to provide various types of personal information, such as your name, e-mail address, telephone number and a summary of your reason for contacting us, to help us assist you. This information will enable us to provide you with relevant information and guidance and match you with an Overseas Property Specialist who can assist you and to enable them to contact you.
3.3 “Personal data” means any information about an individual from which the data controller can identify a specific, living person. Some personal data falls into “Special Categories” which are given greater legal protection (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).
3.4 We do not collect any Special Categories of Personal Data about you and we do we collect any information about criminal convictions and offences. We will never ask you for payment or credit card information.
3.5 We may collect, use, store and transfer different kinds of personal data about you. The personal data we collect will depend on the relationship you have with Us.
3.5.1 Employees: If you are an employee of TBA, someone working with us under a contract for services, or someone who has applied for employment or work with us, we will collect the following information about you:
- Details relating to your identity including your full name, title, job title, gender, proof of identity and your right to work in the UK;
- Contact details, which may include a contact address, email address and telephone numbers; and
- Financial information which includes Bank details, national insurance number and documents such as P45 and P60 in order to provide pay, benefits and conduct other financial transactions with you.
3.5.2 Business Contacts: If you are a business contact, a including any indiividual or any contacts at any company or organisation who supplies us with goods or services or to whom we supply services, we may collect the following types of data about you:
- Identity Data, including name, title, job title, role or similar identifier, and gender;
- Contact Data, including your contact address, email address and telephone numbers;
- Financial Data if we supply or purchase goods and services to or from you as an individual (including some sole traders and partnerships), we may record and retain details of those transactions.
3.5.3 Service Users: If you submit an enquiry, download one of our publications, request a call or contact us by email or telephone about a service offered by TBA or by one of our partner organisations, we may collect the following types of data about you:
- Identity data including full name, title, and details of your enquiry.
- Contact data, including email addresses and telephone numbers;
- Technical Data, including internet protocol (IP) address, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
- Usage Data including information about how you use our website, products and services;
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
3.7 We may also collect, use and share Aggregated Data on visitors to our website and anyone who downloads one of our publications, submits a query or requests information via our website. This may include statistical or demographic data for any purpose.
3.8 Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or evaluate the level of interest in a service or feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3.9 When you visit our website, we may track information about your visit and store that information in web server logs, which are records of the activities on our sites. Our servers automatically capture and save the information electronically. The information we collect in web server logs helps us administer the site, analyse its usage, protect the website and its content from inappropriate use, and improve the user’s experience.
- How we collect your information
We use the following methods to collect data about you:
4.1 Directly from you. You may give us your data by filling in forms or by corresponding with us, using our website, by post, phone, email or otherwise. This includes personal data you provide when you:
- download our publications;
- subscribe to mailing list;
- enquire about a product or service
- enter a competition, promotion or survey;
- give us some feedback.
4.2 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, server logs and other similar technologies.
4.3 Third parties and public sources. We may receive personal data about you from various third parties and public sources including Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- social media services
- advertising networks; and
- search information providers.
4.5 We may receive your identity and contact information from partner organisations whose products or services are offered or linked to from our website, including estate agents, surveyors, organisations providing legal or notarial services, currency conversion firms; tax advisers, mortgage brokers and providers, banking and financial service brokers and providers, moving companies, insurance companies, and specialist advisors on subjects relating to overseas property.
4.6 We may receive your identity and contact information from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- How we use your personal data
5.1 We may use your information, for the following purposes:
5.1.1 to provide you with our website and services;
5.1.2 to comply with legal and regulatory requirements;
5.1.3 to update and enhance our records;
5.1.4 for internal analysis and research;
5.1.5 to send you information and marketing communications about our services which we think may be of interest to you;
5.1.6 to offer you information about and recommendations for third party products and services that we believe may be of interest to you;
5.1.7 to help detect, prevent and deal with crime;
5.1.8 To manage our relationship with you, including notifying you about changes to our terms or privacy notice, asking you to leave a review, provide a success story or take a survey;
5.1.9 To enable you to partake in a prize draw or competition;
5.1.10 To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
5.1.11 To measure the effectiveness of the advertising we send to you;
5.1.12 To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
5.1.13 When you request information or services from our commercial partners we will pass your personal data on to them so that they may contact you to provide that information and service. We will get your express consent before we share personal data provided for that purpose with any other person, company or organisation;
5.1.14 To provide marketing communications to you from us, if you have opted to receive these communications when you requested information from us and you have not since opted out of receiving that marketing.
5.2 We will only process your personal data without your knowledge or consent where we are required to do so by law.
- Opting Out
6.1 You can tell us at any time if you would prefer not to receive our publications, event information and / or marketing communications. To Opt-out you can follow the opt-out links on any marketing message sent to you or by contacting firstname.lastname@example.org.
6.2 Your opt out of receiving marketing messages from us, will not prevent us from continuing to hold and process personal data for other lawful reasons, or to the extent necessary to ensure that our marketing database is kept up to date and that we respect your opt-out.
- Disclosure of your information
7.1 We take security issues seriously. We have implemented appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss or unauthorised disclosure of the information we collect. However we cannot guarantee that unauthorised persons will always be unable to defeat our security measures.
7.2. We will not sell, rent, or lease mailing lists or other personal information to others, and we will not make your personal information available to any unaffiliated parties, except:
7.2.1 to particular Overseas Property Specialists in accordance with our Terms and Conditions;
7.2.2 as required by law, in a matter of public safety or policy;
7.2.3 as needed in connection with the transfer of our business assets (for example, if we are acquired by another company or if we are liquidated during bankruptcy proceedings); or
7.2.4 if we believe in good faith that sharing the data is necessary to protect our rights or property.
7.3 We may give your information to third parties to allow them to market their products and services to you, but only if you specifically agree for us to do so.
7.5 This policy addresses only the use and disclosure of information we collect from you. If you give your information to others, whether they are third parties that we introduce you to or third party sites that you visit by clicking on a link on our web site, different rules may apply to their use or disclosure of the information you give to them. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
- Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
- International transfers of data
9.1 If you require services from service providers or our partners located outside the European Economic Area (“EEA”) we will send your personal data directly to the service provider or partner at your request and on your behalf so that they may contact you to provide you with further information about their services. This will involve transferring your data outside the EEA.
9.2 In many cases where we submit your data outside of the EEA, we may be unable to ensure a similar degree of protection for your personal data as exists within the EEA.
9.3 We will not send your personal data to any third party whether inside or outside of the EEA without your consent.
- Your Legal Rights
10.1 Under certain circumstances, you have the following rights in relation to your personal data:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us.
10.2 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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.3 If you wish to exercise and of your rights in relation to your data, we may 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.
10.4 We try to respond to all legitimate requests within 30 days. If it will take us longer than 30 days we will notify you and keep you updated.