At Foxtons we are committed to ensuring that your privacy is protected. This privacy notice, explains how we collect and use your personal data when you apply for a role with us.
We will collect use and store the following categories of personal data about you:
As a business we collect, use, store and transfer different types of personal data depending on who you are.
If you are purchasing, renting, selling or letting a property through Foxtons, or purchasing, renting, selling or letting a property from one of our clients, we collect and use your personal data to provide you with our services. The personal data we collect and use may include:
Where you apply for a role with us and/or are successful we may collect use and store the following categories of personal data about you:
We also may collect and use Aggregated Data. For example, when you visit our website we may aggregate data about your usage to tell us about how certain features on our website are used. This is not usually classified as personal data as whilst it derives from personal data (in the example, it is derived from your Usage Data) the aggregated way that we typically collect and use this data means that it does not reveal your identity to us. If we do link this Aggregated Data to your personal information, it will be treated as personal data in line with this policy.
We use different methods to collect data from and about you including through:
This is the most common source of your personal data. You may give us personal data when you fill in forms of correspond with us by post, phone, email or otherwise. For example, when you:
Third parties or publicly available sources
As well as by direct interactions with you, we may receive personal data about you from various third parties and public sources. For example, from:
Where you apply for a role with us we collect use and store the following categories of personal data about you:
We may use your personal data for some or all of the purposes listed below. We will only use your personal data for the purposes for which we collected it. If we need to process your personal data for a different purpose that is not compatible with the original purpose we will let you know. However, we may process your personal data for a different purpose without your consent where it is necessary for us to comply with our legal obligations.
With your consent (Article 6(1)(a) GDPR)
We may process your personal data where you have given us your permission to do so or have actively engaged in a means of contact with us
Examples of ways in which we use your data on this basis include referring you to third party companies who provide other services you may require or be interested in, for marketing purposes, using video or photographic images, messaging or other communications and applications through which you have chosen to engage with us
Where we are performing our obligations under a contract with you (Article 6(1)(b) GDPR)
This processing is necessary so that we can perform our obligations to you where you are a customer (or a potential customer).
Examples of the ways in which we use your personal data on this basis include carrying out your instructions according to your signed terms and conditions, or where you use our services before you sign terms and conditions (e.g. when you request a market appraisal of your property, or when you view a property).
Where we are under a legal obligation (Article 6(1)(c) GDPR)
We may be required to process your personal data so that we comply with laws or court orders to which we are subject.
Example of the ways in which we use your personal data on this basis include data protection, anti-money laundering, estate and letting agency; other laws, regulations and/or codes of practice by which we are regulated, and/or orders of court to which we are subject or with which we are required to comply
Where the processing is in our legitimate business interests (Article 6(1)(f) GDPR)
We may process your personal data to help us operate, grow and protect our business, develop our products and services, help improve our efficiencies, manage our client base, provide training, monitor our customer service standards and/or help resolve disputes.
Examples include network security and monitoring, auditing, call recording (which we also ensure takes place in accordance with the Investigatory Powers Act 2016 by informing callers that the calls may be recorded, training and awareness including compliance, referencing, verification of identity, fraud prevention, risk assessment, utility switches, due diligence, marketing, analytics, debt recovery and other claims, the improvement and optimisation of advertising, marketing material and content (including providing you with information about goods or services which we feel may interest you as a result of any previous sale or purchase we have negotiated on your behalf), our website and other applications or platforms through which you interact with us, ensuring that content from our website is presented in the most effective manner for you and your computer, customer support, notifying you about changes to our services and other important notices, managing suppression lists, profiling, cloud storage, when we purchase another business
In some circumstances we may, to protect our entitlement to a commission and to avoid a dispute, disclose your name to another agent, landlord or vendor.
How we use Special Category Personal Data
Special Category personal data by its nature requires extra protection.
Type of special category personal data we may collect include ethnicity and race, religion, sexual orientation, details of criminal offence / convictions, details about children in households (ages and dates of birth, etc). We process this data where we have one of the following additional bases of processing:
Your explicit Consent (Article 9 (2) (a))
For example: you have provided your consent (including by interacting with us)
For the purposes of employment and social security (Article 9 (2) (b) GDPR)
For example, we need to comply with employment law
You had already made the personal data publicly available (Article 9 (2) (e) GDPR)
For example, the Electoral Roll or bankruptcy register
To establish, exercise or defend a legal claim (Article 9 (2) (f) GDPR)
For example, where we need to take or defend legal action
Where we have reasonable suspicion of money laundering Schedule 1, Part 2, Paragraph 15 DPA 2018 Suspicion of money laundering:
For example, during our compliance with Anti-Money Laundering laws
We may also process Criminal conviction data under • Schedule 1, Part 3, Paragraph 33 DPA 2018 Legal claims and/or under the list of exemptions under Schedule 2 DPA 2018
Further information about the ways in which we may process special category personal data can be found in our Appropriate Policy Document
You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. You also have the right to withdraw consent for us to pass your information to third parties for marketing purposes. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.
You can ask us to stop sending you marketing messages at any time by:
Where you withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data until you withdrew your consent.
We will get your express opt-in consent before we share your personal data with any company outside the Foxtons Group of companies for marketing purposes.
If you no longer wish to be contacted by any such third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies about how to unsubscribe.
The Foxtons website and applications may automatically collect data about how you use our services in order to help us improve future functionality of our website and to assist with advertising and targeting. We use Google Analytics, which is a web analysis service provided by Google.
The cookies on the Foxtons website do not track, collect or upload data such as your name, email address or billing information, but it may collect data about your equipment and browsing activities. We may collect and report on the adoption and usage of specific features, crashes and exceptions and other useful, anonymous metrics.
Certain devices can detect your approximate location, via latitude and longitude. The accuracy of this data is not in the control of Foxtons. If this feature is requested, Foxtons will prompt you to provide your permission to access your location data for the purposes of providing you with results or directions based on your current location. You can disable location settings within your browser or app..
We may disclose your personal data for related third parties. For example (where you have consented for us to do so)
We may disclose your personal data to external third parties. For example:
We may disclose your personal data to other parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Where you apply for a role with us we may disclose or share your personal information with group companies or our service providers in order to process your application. They are required to take appropriate security measures to protect your personal information and process your personal data only for specified purposes and in accordance with our instructions.
We are, through technical and organisational means, committed to ensuring the security of, and prevention of unauthorised access to, your personal data. For example, we limit who can access your personal data to those individuals and third parties who need to know it and who are subject to a duty of confidentiality. We also systematically monitor outbound emails for the purposes of protecting confidential and personal data and assisting in our ability to identify potential data breaches. If we become aware of a data breach we will, where we are required to, notify the Information Commissioner's Office. If we believe that the data breach is serious, we may notify you as well.
We will retain your personal data whilst you use our services (or whilst we provide services connected to you) and/or are in communication with us and for at least seven years thereafter, for legal, regulatory and accounting purposes. If we need to retain your personal data for longer, we will take into consideration the potential risks in continuing to store your data against why we might need to keep it. In some circumstances we might anonymise your personal data so it is not associated with you, and we may then use this information indefinitely.
Where you apply for a role with us if your application is unsuccessful, we will retain your personal information for a period of 6 months after we have informed you of our decision so that we can show that we have not discriminated against candidates on prohibited grounds. We will retain your personal data on our file for a further period of 18 months after we have informed you of our decision so that we can consider you for future Foxtons vacancies. If you would prefer we did not, please email us at firstname.lastname@example.org