This Policy applies to any users of the services of Homelink Online platform, HomelinkOnline.com and other Homelink websites (collectively ‘Our Site’), and other interactions (e.g. customer service or social enquiries) you may have with Homelink.
This Policy is part of, and is governed by, our Terms and Conditions and other policies referred to on it.
The ICO Registration number of Homelink Property Services Ltd is Z1289949.
If you have any questions or comments about this Policy, please get in touch by writing to ‘Privacy Manager’, Homelink Property Services Ltd, 68 Midland Road, Bedford MK40 1HS or firstname.lastname@example.org
2. Information we collect
We collect information that you provide about yourself by filling in forms on Our Site, or corresponding with us by telephone, email, or otherwise. This includes information you provide when you register to use Our Site or purchase our Services, and any information that you input, store, transmit or communicate when using Our Site.
The information you give us may include the following:
2.3.1 Personal information:
Your name, address, date of birth, email address and telephone number, and information about your property and your personal circumstances.
We will use your contact information to provide you with pertinent messages as required for the use of Our Site and Services, including telephone calls, email, text message, messaging app or letter. This includes notifications, changes to our Services, features of Our Site, or material updates to our Terms and Conditions.
If you permit us to, we will also use your contact information to contact you to offer Services we provide that may be of interest to you. You may withdraw your consent for us to do this at any time.
2.3.2 Property information
If you are selling a property you may also upload, or ask that we upload, photos and floorplans of your property. These will normally identify your address.
We may use information about your property to promote our Services, including images and status. Only information that is publicly available will be used in this regard. For example, we may use the status of a Sold property to promote our presence in your local area through Direct Mail. If you would prefer that we did not use your property information in this way, please email email@example.com or notify your local agent.
If you request an instant, online estimated valuation of your home, the estimated value of your home will be provided by our partner, SmartlVal. The information you input into the form on the domain link smartval.co.uk/homelink-property-services/get-valuation is sent to SmartVal to calculate your property’s estimated value and is shared with Homelink. We will contact you by phone or email to offer you Services we provide, that may be of interest to you, such as a face-to-face valuation of your property. You may withdraw your consent for us to do this at any time using our Privacy details below.
2.3.3. Payment information
When you make a payment for the fees on Our Site or over the telephone with a Homelink representative, we will collect the necessary financial information from you (such as the name on your credit or debit card, type of card, card number, start date, expiry date, security code and/or issue number) as well as any additional personal information. This information will be transferred to our nominated payment processor, which is currently Stripe Payments Europe Ltd. (‘Stripe’), a company registered in Ireland under company number 513174, registered office 1 Grand Canal Street Lower, Grand Canal Dock, Dublin. Stripe is a certified PCI Service Provider Level 1 who will process your payment to us. Homelink does not store this financial information.
2.3.4. Due diligence information (to undertake checks of your identity to comply with Money Laundering Regulations 2007):
We are required to carry out additional checks on users of our Services who instruct Homelink to market their property or who have an offer accepted for a Homelink-marketed property. Your details will be shared with our credit reference provider Experian Ltd. (‘Experian’), a company registered in the United Kingdom under company number 653331, registered office The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham, NG80 1ZZ. The purpose of this check is to verify your identity; it does not affect your credit rating.
If the automated identity verification check fails, you will be required to provide Homelink with a copy of a legal document (e.g. ID, Driving Licence, Passport) that confirms your identity. Copies of your identity documents, and any other information you provide to us, will be stored securely by Homelink and Experian.
2.3.5. Marketing preferences:
If you book an appointment for a home valuation, we will use your contact information to provide you with information ahead of your appointment and useful advice on your next steps. These messages are optional, and you may choose to stop these messages at any time using the unsubscribe link.
Your preferences on which channels we may communicate with you (phone, text message, email, post) for marketing purposes;
Your preferences on what type of information you would like to receive from marketing, for example, market trend data or special offers.
You may change your marketing preferences at any time:
For Emails: using the unsubscribe or email preferences link at the bottom of the email;
For Direct Mail: by contacting our central team who will ensure that the information is passed onto marketing;
For Phone: by letting the agent know on the call;
For SMS: using the opt-out process provided in the text message.
Alternatively, you may use our Privacy contact details found at the bottom of the policy to notify us of any changes in your contacts details, or to stop future marketing through any of the above channels.
Please note, this will not change any communications that are required for us to fulfill the obligations of Our Service. This includes emails, SMS sent pertaining to updates on the status, for example, of any appointments, viewings, requests or reminders.
2.3.6. Records of your interactions with Homelink, our agents, sellers and buyers are stored for training, compliance and monitoring purposes. These may include information that you reveal during the exchange. This includes:
With Homelink, our agents, sellers and buyers are stored for training, compliance and monitoring purposes. These may include information that you reveal during the exchange. This includes:
Calls and SMS made to and from our central teams;
Messages within emails sent to and received by Homelink email addresses;
Messages that you send and receive through Our Site are retained and monitored in line with our Terms and Conditions
2.3.7. Other data you want to share:
We may collect your personal information or data if you submit it to us in other contexts, for example, where you provide us with a testimonial.
2.3.8. Sensitive information:
We only store sensitive information about you when you provide it. This will not be shared with any third parties. If you have disclosed information, such as the status of your health, that you would like us to remove from our notes, please notify us using our Privacy details found at the bottom of this policy.
Content Presented on our site:
2.4.1 To ensure that content from Our Site is presented in the most effective manner for you, and the device that you use toaccess Our Site, each time you visit, we automatically collect information which may uniquely identify your browser or account. This includes:
Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from Our Site; products you viewed or searched for; page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks or mouse-overs), and methods used to browse away from the page and any telephone number used to call our central team. We take steps to anonymise this information and use it to uncover collective insights about the usage of Our Site.
To improve Our Site and Services, we use the following facilities to collect and analyse information from you:
Live Person/Chat (used in collaboration with Google Analytics and Adwords to allow us to monitor the effectiveness of the advertising campaigns on Our Site and track the impact of live chats on sales of our Services)
Hotjar (this tells us how you are using Our Site and helps us monitor Our Site’s performance)
LeadPrimo (this is used to send and track email, push and SMS communications)
Hystreet (this is used to send and track pertinent automated email messages, such as confirmations of veiwings and password resets)
3. Information we may share about you
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
We work closely with third parties (including, but not limited to, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies). As part of our business processes, we may receive and share information about you.
To carry out our obligations arising from any contracts which we may enter into with you, and provide you with the information and Services that you request from us, we will share your information with (as appropriate):
Your local Homelink agent (and/or their companies), to provide you with Services requested via Our Site;
Independent contractors commissioned by Homelink to produce an Energy Performance Certificate (EPC), or take professional photographs for the marketing of your property, in the event that you request such services via Our Site;
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. We contractually bind these service providers to keep your information confidential and secure, and to use it only to provide you with the services requested.
We may also share your information with selected third parties, including:
At your request, our partners in Financial or Legal services, to assist you with a property sale or purchase;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
Analytics and search engine providers that assist us in the improvement and optimisation of Our Site;
With your consent, selected third parties to provide you with additional services or offers. Before any information is shared, we will ask for your permission.
4. Disclosure of your information
We may disclose your personal information to third parties not named here in the event that:
We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
Homelink or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property or safety of Homelink, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Storing your data
When you have registered for an account with us, you are responsible for keeping the login details confidential. We ask you not to share your password with anyone.
All information you provide us is stored on our secure servers. Data that we collect from you will be stored and processed at our data centre onsite and on SiteGround hosting.
Our Site is secured by Secure Sockets Layer (SSL) technology, which encrypts the connection between your browser and Our Site. However, unfortunately the transmission of information through the Internet is never completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Site, and consequently any transmission is at your own risk.
We restrict access to your personal information to Homelink employees, contractors and agents, who need to know that information in order to deliver the requested Service and are bound to strict contractual confidentiality obligations.
We use strict procedures and security features to guard against physical unauthorised access to systems. We also use software that allows us to monitor our services and infrastructure to protect them from threats, including malware, viruses and other forms of malicious code.
6. How long we will store your information
How long we retain information about you depends on the type of information provided, and your relationship with us:
Personal information: for as long as your account is active, and a reasonable period thereafter in case you decide that you require our services.
If you choose to sell your home or buy a home with Homelink, we have a legal obligation to retain some information about your transaction for six years from the date your transaction completes.
If you choose to have your home valued by Homelink, or view a property that is marketed by Homelink, we will also retain information about your appointment for six years from the appointment date.
We may also retain some information to resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our Services.
Publicly available information: we also use sources of public data to find out information about your property. If you request the removal of your data, we will retain publicly available information about your property but remove your personal association to it.
7. Access to your Information
You can update your information or change the settings of your account by logging into Our Site, or through the assistance of our central team who can be reached on 01234 320 040. We will retain an audit of these changes for monitoring purposes.
You have the right to ask us for access to all of your personal information that we hold about you.
In order to request this information, we need to receive your request in writing, including whether you would like to accept this information electronically or physically (where possible). You will also need to provide a scan of a legal document that confirms your identity, such as your passport or driving licence. You may do this by email or post; please use the details in our Privacy contact information at the bottom.
If there are changes required to your information, you have the right to ask us to stop processing (including collecting, sharing or deleting) your personal data until it is rectified.
There may be some information that we are unable to provide you, if it infringes the privacy of another individual, such as a buyer who has viewed a property you are selling. In this case, we will do our best to provide you with a redacted overview.
8. Removing your information / Cancelling your account
You may request for your personal information stored by Homelink, and your Homelink account to be deleted. Deleting your account will result in your personal information being permanently deleted from our databases within a reasonable time period and will disable your access to your account.
We will fulfil requests to delete personal data promptly, unless the request is not technically feasible or required to be retained by law (in which case we can block access to such data).
If we are unable to delete information, for example, because it has been stored in backup archives, then we will securely store and isolate your information from any further use until deletion is possible.
To have your details removed or account closed, please send your request to us in writing. Please see details below for our Privacy contact information.