Privacy Policy

284PROPERTIES

CONSUMER PRIVACY POLICY 2022

1. WHO WE ARE
2. INTRODUCTION
3. CONTACTING US
4. PERSONAL INFORMATION WE COLLECT
   • a. PROPERTIES ADVERTISED ON OUR PLATFORM
   • b. HISTORICAL PROPERTY DATA
   • c. PERSONAL INFORMATION YOU GIVE TO US
   • d. PERSONAL INFORMATION WE RECEIVE FROM THIRD PARTIES
   • e. PERSONAL INFORMATION WE COLLECT ABOUT YOU
5. PROFILING
6. USE OF YOUR PERSONAL INFORMATION FOR MARKETING AND COMMUNICATIONS
7. PHOTOS, IMAGES AND VIDEOS OF YOU
8. REMOVING PROPERTY DATA FROM OUR PLATFORM
9. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION
10. WHERE WE STORE YOUR PERSONAL INFORMATION
11. YOUR RIGHTS
12. YOUR DUTY TO INFORM US OF CHANGES
13. COOKIES AND TRACKING
14. THIRD PARTY ADVERTISING
15. AGGREGATED DATA
16. CHANGE OF PURPOSE
17. CHANGES TO THIS POLICY

WHO WE ARE

This Privacy Policy covers 284Properties (referred to as “We” or “Us” or “Our” or “284Properties”). These include:

We are the providers of the 284Properties mobile application software (referred to as the “App”) and the website www.284Properties.com, (referred to as the “Website”) (together referred to as “Our Platform”) and any other Services We may operate in the future.

“Members” include real estate agents, online agents, property owners, or property developers.

“Third Parties” include overseas property owners, surveyors, banks, insurance companies, other lenders and financial institutions, Government departments and selected CRM software providers.

“Partners” are selected companies whom We choose to work with to offer complimentary Services.

“Services” or “Service” mainly include property advertising.

We are not an estate agency.

We provide Our Platform so that:

• Our Members can advertise property details for You to view;
• We can provide You with access to housing market trends and historical property data; and
• We can provide Our Members access to valuation and surveying tools.

References to “Users”, “You”, “Yourself” or “Your” is a reference to individuals using Our Platform or Services.

References to “Personal Information” means information that will allow Us to identify You and is set out in more detail in the “Personal Information We Collect” sections below.

INTRODUCTION

We are committed to protecting Your privacy. This privacy policy (referred to as the “Policy”) explains how and for what purposes We use the Personal Information collected about You when You use the website or download and use Our App on Your mobile device (“Device”). Please read this Policy carefully.

In the tables below We set out the types of Personal Information We collect, where it comes from, why We collect it, Our lawful basis for processing the Personal Information and how long We will keep it for.

Our Platform are not intended for anyone under the age of 18 (referred to herein as “Children” or “Child”). We do not knowingly collect or process Personal Information relating to Children. If You become aware that Your Child has provided Us with Personal Information without Your consent, please contact Us on Privacy@284Properties.com and We will, upon verification, delete such Personal Information.

If You have a query about Personal Information relating to Your property on the Platform, please contact Your estate agent directly or alternatively contact Us on Privacy@284Properties.com.

CONTACTING US

We recommend You contact Us at Privacy@284Properties.com.

If we’re unable to deal with your request in a satisfactory way, you can contact the Office of the Information Commissioner.

If You would like to stop receiving direct marketing from Us please contact Us via email at Hello@284Properties.com.

If You have any questions about this Policy or Our use of Your Personal Information, please contact Us at Privacy@284Properties.com. 

PERSONAL INFORMATION WE COLLECT ABOUT YOU

PROPERTIES ADVERTISED ON OUR PLATFORM

• What We collect and where it comes from
  • In the course of providing Our Services, We collect property data such as images and videos of properties, property asking prices, sales history and sold prices, property addresses, floorplans, property locations and property descriptions; and
  • The property data is provided to Us by Our Members or other third parties on behalf of those Members.
• Why We collect it  
  • We will use this information for a number of reasons including:
    • To provide Our Platform;
    • To enable Our Members to advertise their properties to the online audience available;
    • To enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in;
    • To allow Users to see current property trends such as the prices of houses for sale in their local area;
    • For Our own commercial purposes such as to identify trends in the property market, to build property databases and automated survey and valuation tools for Our Members to use and to promote Our Platform and Services on social media and other third-party Platform; and
    • To provide Our Members with updates on properties advertised on Our Platform.
• Our lawful basis for processing this Personal Information
  • We have a legitimate interest to process this Personal Information. These legitimate interests are:
    • Providing a Service to Our Members by helping them to market properties and understand changing market dynamics and evolving trends;
    • Providing a Service to Our Members by advertising properties to potential purchasers or tenants;
    • Providing a Service to potential purchasers and tenants so that they know what properties are currently on the market and the price of those properties;
    • To provide data services to Third Parties such as surveyors, banks, insurance companies and other financial institutions so that they can process this property data for their purposes and
    • To help Our Members benchmark their performance and identify requirements for additional services.
• How long We will keep it for
  • We will stop advertising a property when We are instructed to do so by Our Members. However, the property information will remain available on the Platform as historical property information to allow Users and Our Members to benefit from Services such as identifying previous for sale or sold prices (please see the “Historical property data” section below for further information).

HISTORICAL PROPERTY DATA

• What We collect and where it comes from
  • If a property has previously been actively marketed on the Platform, we will continue to display it on the Platform as historical property information. If You have any concerns about any historical property information available on the Platform, please see the section of this Policy entitled “Removing Property Data from Our Platform” (below); and
  • We also have data that relates to historical property listings on the Platform which We collect from other third parties.
• Why We collect it
  • We will use this information:
    • To assist potential purchasers and tenants when forming a view about historical market trends and potential property values;
    • To assist vendors when researching the approximate value of their property;
    • To enable Users to see detailed property descriptions and images of properties in areas that they may be interested in;
    • To allow Users to see property trends that they may be interested in, such as the previous sale and sold prices of properties in their local area; and
    • For Our other commercial purposes, such as to identify trends in the property market and to build property databases and automated survey and valuation tools for Our Members to use.
• Our lawful basis for processing this Personal Information
  • We have a legitimate interest to process this Personal Information. These legitimate interests are:
    • To enhance the Service that We provide on Our Platform and providing a Service that benefits Our Members, Users, Third parties, potential purchasers and tenants;
    • To provide a Service to Our Members by assisting them to more accurately value other properties;
    • To provide a Service to vendors and property owners which helps them form a view about the value of their properties;
    • Providing a Service to potential purchasers and tenants in understanding what properties have been on the market and the prices of those properties;
    • To provide data services to third parties such as surveyors, banks, insurance companies and other financial institutions so that they can process this historic property data for their purposes; and
    • To provide property valuation tools and surveyor comparison software to Our Members.
• How long We will keep it for
  • To the extent that property data is also Personal Information, it is generally the case that it ceases to be Personal Information over time. The historic property data is retained by Us whilst it is required by Us to provide the Services summarized in the “Why We collect it” box.

PERSONAL INFORMATION YOU GIVE TO US

• What We collect and where it comes from
  • We will collect the Personal Information that You give to Us when using Our Platform or Services:
    • Enquiries to Our Members:
      • If You choose to access a particular search feature, request information or fill in a form on the Platform You may be asked to provide Personal Information about Yourself, such as:
        • Your name, address and contact details;
        • details of the sort of property You are interested in;
        • the cost and location of the property;
        • Your current residential address;
        • what stage in the home moving process You are;
        • whether You are a first time buyer, a seller, a property owner, a tenant, investor etc.;
        • whether You are re-mortgaging
        • whether You have a property to sell or rent.
      • If You choose to book an appointment to view a property via the Platform, You may be asked to provide more details, including:
        • Your availability to view the property;
        • Your preferred moving date;
        • details of Your household income as a proxy for calculating affordability in relation to the advertised monthly rental value of a property;
        • whether You have any adverse credit history that could affect Your application;
        • an indication of whether You are moving alone or with others;
        • Your feedback on a property that You have viewed;
        • Your mobile number for the purpose of providing You updates via text regarding Your property viewing (includes sending reminders about Your booked viewings);
    • Registered Users and Property Alerts:
      • Personal Information that You provide to Us when You register as a User and/or request property email updates such as Property Alerts about when a property is marketed in Your chosen area and meeting Your search parameters; and
      • We may also ask what stage in the home moving process You are, whether You are a first time buyer, a seller, tenant, a property owner, investor, whether You are re-mortgaging etc.
    • General Use of the Platform:
      • Personal Information that You provide when:
        • participating in discussion boards or other social media functions on Our Platform;
        • entering into competitions, promotions, surveys and market research studies made available on Our Platform or if We contact You by email; phone or otherwise; and
        • engaging with additional Services that are available on Our Platform, where you will Provide Us the following Personal Information: location, home moving status (whether you are a first time buyer, buying your next home or buying an additional property/investing), re-mortgaging, are an investor and price of the property.
    • Communications:
      • Personal Information that You provide by corresponding with Us by phone, e-mail, video calls or otherwise; and
      • If You choose to contact Us by phone or video calls or We call You, calls may be noted/recorded for training, monitoring and quality assurance purposes. Phone calls may be monitored in real time. We may also keep a record of call activity, including missed calls.
    • Human Resources:
      • Personal Information You provide Us when applying for a job vacancy at 284Properties, such as Your CV and covering letter.
    • Journalists/Media:
      • Where You contact Us as a journalist/media, We will retain contact data and other Personal Information You may choose to provide Us with.
• Why We collect it
  • We will use this Personal Information:
    • Enquiries to Our Members:
      • To make sure that You receive the benefit of the Service. This may include:
        • transferring Your property enquiry to Our Member who is advertising that property so that they can respond to Your enquiry only. Some of Our Members may use:
          • third party systems to process and store Your enquiry to allow them to respond to and manage Your enquiry;
        • sending Your request to book a property viewing to Our Member who is advertising that property and for Us to confirm Your booking by email or text on Our Member’s behalf;
        • sending Your name, address and contact details to Our Member when You request information or a brochure on a property they are advertising, so that they can contact You;
        • where You book an appointment to view a property, We will create a calendar appointment in Our Members own email system (via calendar software) in order to manage Your booking;
        • transferring other relevant information to Our Member so that they can assess whether the property is suitable for You;
        • enabling Us to send You a link to access an online viewing of the property You have enquired about;
        • allowing You to provide Our Member with feedback on the property once You have viewed it;
        • Our Members must form their own legal basis for processing Your enquiry data if they are processing it for purposes other than responding to Your initial enquiry;
      • To profile Your activity on Our Platform, for more information please see the “Profiling” section below.
      • To enhance the service, you receive from Our Members.
      • Registered Users and Property Alerts:
      • To provide You with the benefit of Services for registered Users only;
      • To provide Property Alerts to You (which You have set up) for properties marketed on Our Platform that meet Your search criteria; and
      • To provide You customized content on Our Platform including suggesting properties or Services relevant to You.
    • General Use of the Platform:
      • To provide the Platform to You and enable You to download the App;
      • To enhance the Services that You select on Our Platform;
      • To process any queries that You have about 284Properties or it Members;
      • To customize and enrich Your experience on Our Platform;
      • To contact You for Your views on Our Services and to notify You occasionally about important changes to Our Terms of Use, this Policy or developments to Our Platform or Services;
      • To deliver relevant advertising to You whilst You are on the Platform;
      • To deliver targeted advertising to You depending on whether You are a first-time buyer, re-mortgaging or are an investor; and
      • To provide You customized content on Our Platform including suggesting properties or Services relevant to You.
    • Communications:
      • To process and resolve any queries that You may have; and
      • For training, monitoring and quality assurance purposes.
    • Human Resources
      • To enable You to apply for Our job vacancies at 284Properties.
    • Journalists/Media:
      • To respond to Your requests;
      • To add You to Our database of journalists to receive industry and company related press releases; and
      • To contact You by phone, email, video call or otherwise regarding stories that We believe may be of interest to You.
• Our lawful basis for processing this Personal Information
  • We have a legitimate business interest to process this Personal Information. These legitimate interests are:
    • Enquiries to Our Members: 
      • To provide a service to Our Members and/or to provide a service to You;
    • Registered User and Property Alerts: 
      • To provide You with Our Services;
    • General Use of the Platform:
      • To enable You to download and use the App;
      • To allow Us to gain information about the use of Our Platform and any improvements that can be made;
      • To provide providing advertising space to Our Members and third parties;
      • To provide You with relevant content on Our Platform;
    • Communications: 
      • To ensure that Your queries are addressed and for training, monitoring and quality assurance purposes;
    • Human Resources: 
      • To process Your job application and consider You for Our vacancies;
    • Journalists/Media: 
      • To enable direct communication between Us and relevant journalists;
• How long We will Keep it for
  • We will store the Personal Information summarised above for the following periods:
    • Enquiries to Our Members:
      • All enquiry data will be kept for two years from the date on which You last used Our Platform or Our Services. After that it will be erased or anonymized so that the data no longer identifies You;
      • Profiling data will be kept for as long as is required, as described in the “Profiling” section below.
    • Registered Users and Property Alerts:
      • Personal Information that You provide to Us when You register as a User will be kept for as long as You have an active account setup on 284Properties. The Personal Information relating to Your account will be deleted when You delete Your account or if Your account has been inactive for 3 years, whichever is earlier.
    • General Use of the Platform:
      • Personal Information that You provide when downloading the App, registering to use the App or for accessing in-App services will be retained for as long as You have the App installed on Your device;
      • Personal Information that You provide when participating in discussion boards, enter into competitions, promotions, surveys and market research studies will be retained for no longer than two years; and
      • Personal Information that is provided when You interact with Us through publicly available social media Platform will only be retained on the social media Platform which You use to publicly interact with Us (we will not copy or store it separately) and this Personal Information will be retained for as long as You keep it on Your social media accounts (for tweets and direct messaging via social media Platform, please see “Communications” heading below).
    • Communications:
      • Personal Information that You provide to Us when We correspond by telephone, e-mail, direct messaging or tweets through social media will be retained on Our systems:
        • For no longer than 25 months on Our ticketing system from the date of communication or until Your query is resolved.
        • For no longer than 24 months for the original e-mail correspondence.
    • Human Resources:
      • We retain Personal Information for as long as is required to fulfil the purpose (whether that be for the current job application or retaining on file for future job vacancies) or until You notify Us that You wish for Your Personal Information to be deleted.
    • Journalists/Media:
      • We retain Your Personal Information until You notify Us that You wish for Your Personal Information to be deleted or until Our records indicate You no longer undertake journalistic activities that relate to Our products or Services.

PERSONAL INFORMATION WE RECEIVE FROM THIRD PARTIES

• What We collect and where it comes from
  • We may receive Personal Information about You if You use the website or the other Services We provide via the App. In this case We will have informed You, when We collected the Personal Information, that it may be shared internally and combined with other Personal Information collected on Our Platform.
    • Our Members
      • Our Members may provide us Your Personal Information such as name, email address, property address, whether You purchased or rented a property or instructed Our Member to sell or rent Your property.
    • Human Resources:
      • When You apply for a job vacancy via a recruitment agency, they will provide Us Personal Information about You; or
      • Where Your job application is successful and prior to an offer of employment, We will request a reference from Your referees. They will provide Us Personal Information about You.
    • Journalists/Media:
      • Where You are a Journalist, We may receive Your Personal Information (email address, name, number, company You work for and whether You are a freelancer) from third party press services.
• Why We collect it
  • We will use Your Personal Information:
    • To allow You to participate in the interactive Services available on Our Platform or to participate in competitions or promotions via Our Platform;
    • To pass Your searches and messages on to Our Members to help them communicate with You directly and to provide a more personalized service to You. This may include contacting You about other relevant properties, adding You to their enquiry database for future contact and offering You their additional services, however they must form their Own lawful basis for doing so;
    • To provide Services and information to Our Members which they can use to benchmark their performance;
    • To customize and enrich Your experience on Our Platform;
    • To contact You for Your views on Our Services and to notify You occasionally about important changes to Our Terms of Use or this Policy or developments to Our Platform or Services;
    • Human Resources: To process Your job application and consider You for one of Our job vacancies;
    • Journalists/Media: To send You Press releases that may be relevant to You and correspond with You and
    • Our Members: from time to time Our Members may share Your personal data with Us for the purpose of evaluating their performance and identify training needs.
• Our lawful basis for processing this Personal Information
  • We have a legitimate interest to process this Personal Information. These legitimate interests are:
    • Enhancing the Service that You receive on Our Platform;
    • Providing a Service to Our Members so they can respond to enquiries;
    • Providing information necessary to enable Us to provide a competitive, cost effective service;
    • Human Resources: Enabling Us to recruit for Our job vacancies in order to provide Our Platform and Services;
    • Journalists/Media: To respond to Your enquiries and provide timely information and press releases; and
    • Our Members: To provide Our Members insights into the effectiveness of 284Properties, to evaluate Our Members performance and identify any training needs.
• How long We will Keep it for
  • We will store this Personal Information for two years from the date on which You last used Our Platform or Services at which point it will be erased or anonymized so that the data no longer identifies You;
    • Human Resources: We retain Personal Information for as long as is required to fulfil the purpose (whether that be for the current job application or retaining on file for future job vacancies) or until You notify Us that You wish for Your Personal Information to be deleted;
    • Journalists: We retain Your Personal Information until You notify Us that You wish for Your Personal Information to be deleted or until Our records indicate You no longer undertake journalistic activities that relate to Our products or Services; and
    • Our Members: We will only retain Your Personal Information for as long as necessary to fulfil the purposes We collected it for. Once the purpose has ended, We will anonymise Your Personal Information (so that it can no longer be associated with You) for research or statistical purposes and We may use this information indefinitely without further notice to You

PERSONAL INFORMATION WE COLLECT ABOUT YOU

• What We collect and where it comes from
  • This relates to technical data that We collect. We may:
    • Collect technical information that has the potential to identify You, including the type of Device You use, a unique identifier (for example, Your Device’s IMEI number), the internet protocol (IP) used to connect Your computer to the internet, the MAC address of the Device’s wireless network interface, or the mobile phone number, Your login by the Device, mobile network information, Your Device operating system, the type of browser You use on Your Device and its time zone setting, the browser plug-in types and versions, operating system and platform; browser type and version and Your login data;
    • Collect Personal Information about Your visit to Our Platform and/ or Your interactions with Our direct marketing using tracking pixels to identify device types, the full Uniform Resource Locators (URL) clickstream to, through and from Our Platform (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and how You use Our Platform, products or Services;
    • Collect details of Your use of Our App or Your visits via the App, the resources that You access and the advertisers and partners that You contact;
    • Use GPS technology on Your Device to determine Your current location. Some of Our location-enabled services require Your Personal Information for the feature to work;
    • Set a unique application number which is contained within the App. When You install or uninstall the App or when the App searches for automatic updates, that number and information about Your installation (for example, and the type of operating system) may be sent to Us; and
    • Combine technical information with other information that We have about You to help Us with Our processing of Your Personal Information as set out in this Policy.
• Why We collect it
  • We will use the information summarised above:
    • To provide Our Platform to You;
    • To customise and enrich Your experience on Our Platform;
    • To provide You with GPS enabled functionality;
    • To deliver relevant content and advertisements to You on Our Platform and measure or understand the effectiveness of the advertising We serve to You;
    • To use data analytics to improve Our Platform, Services, marketing, customer relationships and experiences;
    • To conduct reviews that assist Us in the improvement and optimisation of Our Platform;
    • To identify what versions of the App are being used or when the App is uninstalled from a Device;
    • To ensure that content from Our Platform is presented in the most effective manner for You and for Your device;
    • As part of Our efforts to keep Our Platform safe and secure;
    • To administer Our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • To respond to and deal with Your queries or complaints and to provide or improve Our customer service to You; and
    • For internal training purposes.
• Our lawful basis for processing this Personal Information
  • We have a legitimate interest to process this Personal Information. These legitimate interests are:
    • To help ensure the on-going security of the Platform;
    • To enhance the service that You receive on the Platform;
    • To provide information necessary to enable Us to provide competitive, cost effective Services;
    • To provide customer support including dealing with Your complaints, enquiries and to improve customer service;
    • To monitor quality and conduct staff training;
    • To study how Our Platform are used, including how customers use Our Services, to develop them, to develop and grow Our business, to inform Our marketing strategy, to define types of customers for Our Services and to keep Our Platform updated and relevant; and
    • To operate Our business and Platform (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, provision of administration and IT services, network security and to prevent fraud);
    • If You wish to use a location data service which engages Your Device’s GPS tracker, You will be asked to consent to Your Personal Information being used for this purpose upon registering to use the App. You can withdraw Your consent at any time by turning off the location services settings for the App on Your Device.
• How long We will Keep it for
  • We will store this Personal Information for two years in order to allow Us to review and monitor normal traffic patterns and trends on Our Platform at which point it will be erased or anonymised so that the data no longer identifies You. We will store the unique application number for as long as the App is installed.

PROFILING

We may from time to time profile Your activity when using Our Services or Our Platform.

This profiling is based on telephone and email enquiries You send to Our Members, properties advertised on Our Platform, cookies and information You either provide Us or We collect in the course of using Our Platform and Services. We may use this information both now and, in the future, to identify:

• any properties You may have for sale or rent;
• whether You are intending to sell or rent Your property;
• if You have subsequently instructed one of Our Members to advertise Your property;
• what stage in the home moving process You are;
• whether You have a mortgage in principle decision;
• whether You are a first time buyer, re-mortgaging, investing, a seller, tenant, a property owner etc.;
• if You may require a valuation of Your property; and

It takes place to help Us and Our Members:

• understand what sort of properties You may be interested in;
• identify opportunities to improve training;
• match enquiries sent to Our Members with properties advertised on Our Platform. This is to provide Our Members with market insights where Your property was subsequently advertised with another Member. This will be provided for training purposes only to help Our Members improve their processes for identifying where enquiries may have a property for sale or rent, either now or in the future;
• to categorize Your activity to help Us and Our Members determine how likely You are to require services from Our Members. Members may then contact You to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing Your Personal Information);
• use this information to customise Your experience on Our Platform such as:
  • suggest properties that may be of interest to You;
  • suggesting services from Our third party advertisers that may be relevant and of interest to You based on Your use of Our Platform.

You can always object to Our profiling by emailing Us here Privacy@284Properties.com. Any profiling data that We hold about You will only be kept for as long as is required to perform the Services to Our Members and provide Our Platform and Services to You.

USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING AND OTHER COMMUNICATIONS

Direct Marketing

Sometimes We may Use Your Personal Information to provide direct marketing messages to You; either directly from Us or on behalf of Our Members. You can opt out of direct marketing at any time by:

284Properties:

• Using the unsubscribe links located at the bottom of the direct marketing emails We send You. Please ensure You click through to manage Your full marketing preferences;
• Log into Your My 284Properties account to manage your marketing preferences; or
• Contacting Us directly on Hello@284Properties.com.

It may take up to 72hours from the time You receive confirmation from Us that Your preferences are being updated to unsubscribe You from direct marketing.

You can always make use of Our Platform and Our Services without having to agree to direct marketing. The types of things that We may do include:

• Providing direct marketing advertisements and communications to You via email, text, post or telephone;
• Making suggestions and recommendations to You and other Users of Our Platform and Our Services about goods or Services that may interest You or them;
• Communicating with You on third party social media Platform;
• Monitoring the effectiveness of Our direct marketing communications and Your responses to it which can help Us improve Our Services and communications;
• Using a clear image GIF to track results of an email campaign such as the device You use. You can turn this off for future emails by turning off images in the email itself;
• We will retain Your marketing preferences to ensure We comply with Your instructions.

You can request the list of Our Members from whom We send marketing by contacting Us at Privacy@284Properties.com.

Other Communications

When You opt out of receiving direct marketing from Us, You will still continue to receive transactional messages from Us regarding Our Platform and Services. We have a legitimate interest to send You these communications, examples of which include:

• Important updates to Our Services, Privacy Policy and Platform;
• Managing Your My 284Properties account;
• For security reasons;
• Receiving Property Alerts where You have set them up in Your My 284Properties Account (You can amend your Property Alerts at any time in Your My 284Properties account); and
• Where a home hunter shares a property with You via Our Platform;

PHOTOS, IMAGES AND VIDEOS OF YOU

Where You have agreed to participate and feature in videos, images and photos for Us, these will be used for the purpose outlined to You at the time, which can include to promote 284Properties. This will be retained for no more than 3 years after the purpose has ended. We have a legitimate interest to use these on any of Our Platform or 3rd party social media Platform.

REMOVING PROPERTY DATA FROM OUR PLATFORM

If You have any concerns about the properties advertised on the Platform, please contact Us at Hello@284Properties.com or Member@284Properties.com and We will endeavour to resolve the issue promptly.

If You are a vendor or property owner of a property that is being actively marketed on Our Platform via a real estate agent and You want this removed, please contact Your real estate agent directly in the first instance.

If You have concerns about historical property information on Our Platform and You can prove to Us that You have a valid association to that property, please contact Us at Privacy@284Properties.com.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?

We retain access to all Personal Information that We have collected from You or about You. Once Your Personal Information has been passed to one of Our Members in the course of providing Our Services (most typically when You communicate with a real estate agent through Our Platform) then Our Member will have a copy of the Personal Information that You have provided within Your enquiry and Your contact details which they will use to get in touch with You.

Property data, it is provided to Us by Our Members (or third parties that act on their behalf). Our Members (or any third party that acts on their behalf) will be responsible for Personal Information in their possession and that Personal Information will be subject to any privacy terms or policies that the Member has in place. We are not responsible for use (or misuse) of Your Personal Information by any of Our Members.

When Our Services are available via the websites of Our partners or Members, those partners or Members may have access to Your Personal Information. We may also have links to other third party websites from Our Platform. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Information about You. We are not responsible for the content, security, privacy policies and practices of any other third party websites, even if You access them using links from Our Platform or if You can access Our Platform or use Our Services from them. We recommend that You check the policy of each website that You visit and make sure that You are comfortable with the terms of such policies before You visit them or provide any Personal Information to them.

If Our business is sold or merged, or if We sell or buy any business or assets, We may disclose Your Personal Information to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If We offer or supply a Service to You that is provided on Our behalf by a third party, We may have to pass Your Personal Information to them in order to deliver the service. The categories of third parties (who are acting as Data Processors which means they are responsible for processing Personal Information on behalf of Us) include:

• Our support ticketing systems;
• SMS providers;
• E-signatory providers;
• Payment providers;
• Translation and transcription providers;
• Market research agencies;
• IT providers who provide systems to Us for the purposes of hosting and supporting Our Platform; and
• Marketing agencies and systems that allow Us to send marketing communications to You and to make sure the marketing communications are relevant.

We may also use third parties to provide Services on Our behalf which may include processing (but not using themselves) Your Personal Information; for example, to complete partial addresses or to augment the Personal Information We hold about You. In either case, We will not pass Your Personal Information to anyone who is not also subject to adequate privacy commitments in Our contract with them.

We may be required to share Your Personal Information with the following external parties:

• Inland revenue, regulators and other authorities acting as processors or joint controllers based in the Virgin Islands who require reporting of processing activities in certain circumstances;
• Police or other such regulatory authority as part of an investigation or otherwise for legal or regulatory purposes;
• Dispute Resolution agencies for the purposes of dealing with any complaints;
• We will disclose Your Personal Information to other third parties if We are under a duty to disclose or share Your Personal Information in order to comply with any legal or regulatory obligation or request. This includes exchanging Personal Information with other companies for the purposes of fraud protection and credit risk reduction.

We require all Our third party service providers to respect the security of Your Personal Information and to treat it in accordance with the law. We do not allow Our third party service providers to use Your Personal Information for their own purposes and only permit them to process Your Personal Information for specified purposes and in accordance with Our instructions.

You can request a list of Our third party partners and affiliates by contacting Us at Privacy@284Properties.com.

WHERE DO WE STORE YOUR PERSONAL INFORMATION?

The Personal Information that We collect from You may be transferred to, and stored at, a destination outside the Virgin Islands. Territories outside of the Virgin Islands may not have equivalent legal protections to those that apply within the Virgin Islands, but We are under a duty to make sure that Our suppliers and contractors located outside of the Virgin Islands continue to take all steps reasonably necessary to ensure that Your Personal Information is treated securely and in accordance with this Policy. By submitting Your Personal Information to Us, You agree to this transfer, storing or processing.

Unfortunately, the transmission of Personal Information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to Our Platform; any transmission is at Your own risk. Once We have received Your Personal Information, We will use strict procedures and security features to try to prevent unauthorised access.

We follow strict security procedures to ensure that Your Personal Information is not damaged, destroyed or disclosed to a third party without Your permission and to prevent unauthorised access to it.

Only employees who need access to Your Personal Information to perform a specific job are granted access to personally identifiable Personal Information. In addition, We limit access to Your Personal Information to those agents, contractors and other third parties who have a business need to know. They will only process Your Personal Information on Our instructions and they are subject to a duty of confidentiality.

We may require You to co-operate with Our security checks before We disclose Personal Information to You. If You are a registered User, You can update the Personal Information held in Your My 284Properties account (that You give Us) at any time by viewing Your account page.

Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Platform, You are responsible for ensuring Your password is unique and for keeping this password confidential. We ask You not to share Your password with anyone.

We have procedures in place to deal with any suspected Personal Information breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

We recommend You do not use public or shared devices where You are providing Your Personal Data to Us and take appropriate steps to ensure You have removed any local storage or session-based data from your shared/public Device.

YOUR RIGHTS

You have the right to ask Us not to process Your Personal Information at any time.

You have the right to use Our Platform without consenting to direct marketing and the communication services that We provide. We will inform You (before collecting Your Personal Information) if We intend to Use Your Personal Information for such purposes or if We intend to disclose Your Personal Information to any third party for such purposes. We always use the most recently submitted form to be Your current consent status. If You are a registered User, but not signed in when You submit a form, We will not be able to Use Your saved settings so will deem Your consent choice to be as per the form You submit at the time. You can exercise Your right to prevent such processing by selecting the specific options in the fields or forms when You become a registered User.

You also have a right to:

• Request access to or rectification of the Personal Information which We hold about You;
• Request erasure of Your Personal Information in certain circumstances;
• Restrict the processing of Your Personal Information;
• Receive Your Personal Information that You have provided to Us;
• Object to or restrict Our processing of Your Personal Information in certain circumstances; and
• Request that We transmit Your Personal Information to another data controller.

Where We process Your Personal Information because You have given Us Your consent to do so, You have the right to withdraw Your consent at any time.

Where We process Your Personal Information under legitimate interests, if You object to processing, this will not affect any processing which has already taken place. In some limited instances, objecting to processing of all Your Personal Information may mean You are not able to use some of Our Services or Platform.

To exercise any of these rights, please contact Us at Privacy@284Properties.com. We may need to request specific information or identification documents from You to help Us confirm Your identity and ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information 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.

We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

As part of Our Data Protection obligations and to help Us improve Our Service, We maintain a register of Data Subject Right Requests which contains limited Personal Information (email address, type of request, reason for request, resolution, reference number, application number etc.). These records are only available to Our Data Protection Team or would only be made available to the Office of the Information Commissioner upon request. We will retain these records for up to 6 years from the conclusion of the Data Subject Right Request, after which any Personal Information will be anonymised.

You have the right to complain to the Office of the Information Commissioner if You feel unhappy with the way We process Your Personal Information.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the Personal Information We hold about You is accurate and current. Please keep Us informed if Your Personal Information changes during Your relationship with Us.

COOKIES AND TRACKING

Like many website and App providers, We use “cookies” to enable Us to personalise Your visits to Our Platform, simplify the signing-in procedure, keep track of Your preferences and to track the usage of Our Platform. We use a mixture of third and first party cookies. Our lawful basis for using cookies are as follows:

• Strictly Necessary Cookies: We rely on legitimate interests as Our lawful basis for collecting and processing this data;
• Functional Cookies: We rely on consent as Our lawful basis for collecting and processing this data; and
• Targeting and Tracking Cookies: We rely on consent as Our lawful basis for collecting and processing this data.

For full details about what cookies We set and why We use them, please see Our Cookies Policy.

THIRD PARTY ADVERTISING

As well as providing the Services on Our Platform, We also feature advertising from third parties. We use a range of advertising partners and technologies to help deliver third party advertisements on Our Platform which may be relevant to You. To help ensure the advertisements are relevant, We match property listings data, information from cookies and clickstream data to create audience segments. We share Our audience segments with Our advertising partners and only allow certain companies to purchase advertising space on Our Platform. For example third parties may wish to display advertisements to Users of Our Platform which We deem as being renters and therefore We will offer space On Our Platform where renters visit.

You can request a list of the partners with whom We work by contacting Us at Privacy@284Properties.com.

AGGREGATED DATA

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from Your Personal Information but is not considered Personal Information 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 feature on Our Platform. However, if We combine or connect aggregated data with Your Personal Information so that it can directly or indirectly identify You, We treat the combined data as Personal Information which will be used in accordance with this Policy.

CHANGE OF PURPOSE

We will only use Your Personal Information for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. Please note that We may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CHANGES TO THIS POLICY

We may change the terms of this Policy at any time. Any changes We may make to this Policy in the future will be posted on Our Platform and displayed on-screen when You use Our App.

You may be required to read and accept any revised Policy to continue Your use of Our Platform. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App.

Please check back frequently to see any updates or changes to this Policy, as You will be deemed to accept such changes from Your continued use of Our Platform.

Issue date: 25 November 2022