1. Important information
This Privacy Statement describes how we, Moving Up Estates Limited (“Moving Up Estates”), collect personal information about you; how we safeguard the personal information we collect; how we use and share such personal information; and how you can contact us regarding our privacy practices. Moving Up Estates Limited is the owner of the website. Where reference is made to “we”, “us” and “our”, the definition should be taken as meaning Moving Up Estates Limited.
By providing us with your data, you warrant to us that you are over 18 years of age.
Your privacy is of paramount importance to us and this Privacy Statement explains when, why and how we gather personal information about website visitors, clients and others who communicate with us, how we use such personal information, the circumstances under which we may disclose it to others and how it is securely stored.
Please take the time to read this Privacy Statement (and any supplements we may issue in the future) so that you are fully aware of how and why we are using your data.
Controller
The Data Controller is Moving Up Estates Limited, 69 Farfield, Penwortham, Preston, Lancashire PR1 9YQ, United Kingdom, a limited liability company incorporated and registered in England and Wales with company registration number 11859944 and we are responsible for your personal data. If you have any questions about this Policy, including any requests to exercise your legal rights (as set out in paragraph 7 below), please contact us using the details set out below:
Full name of legal entity: Moving Up Estates Limited
Name or title of data privacy manager: Ruth Lunn (Chief Executive)
Email address: data@lujoinvestments.com
Postal address: 69 Farfield, Penwortham, Preston, Lancashire, PR1 9YQ
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) the UK supervisory authority for data protection issues (www.ico.org.uk) on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would, however, appreciate being given an opportunity to resolve any issues before you approach the ICO, so please contact us in the first instance.
Changes to this Policy and your obligation to inform us of changes to your details
Any change to this Policy will be on this page and a notice that the Policy has been updated will be clearly shown on the Website and, where we have your email address and a legal basis to contact you using that email address, emailed to you. Please check back frequently to see any changes to our Policy as continued use of the Website after such modifications will constitute agreement to the updated terms of the modified Policy.
It is very important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal information changes during your relationship with us by emailing us at info@movingupestates.com
Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data or personal information means any information about an individual which allows that person to be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have gathered:-
- Identity Data includes first name and last name.
- Contact Data includes email address and telephone numbers.
- Technical Data includes Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes enquiries made by you in respect of properties listed on the Website or that we have sent to you, information provided by you for listing on the Website, your interests and your preferences.
- Usage Data includes information about how you use the Website.
- Marketing and Communications Data includes your consent to receive marketing communications from us and our third parties.
- Sensitive Data this includes Anti-Money-Laundering (AML) and Know Your Client (“KYC”) procedures in order to comply with multi-jurisdictional law which will include proof of identity, proof of address and proof of source of funds.
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 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. 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 Policy.
We do not collect any Special Categories of Personal Data about you (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). Nor do we collect any information about criminal convictions and offences.
If you decline to provide personal data
If you do not provide us with the personal data that we need to fulfil a statutory or contractual requirement, or in order to provide you with information or services that you have requested from us, we may not be able to perform the contract we have or are trying to enter into with you, or provide you with information requested (for example, supply you with information concerning a particular property listed on our website). In this event, we may need to cancel our contract with you or not supply the information you requested; however, we will notify you at that time, if this should be the case.
3. The methods we use to collect personal information from you
We collate personal information using various methods. These include, but are not limited to: – our Website, registration forms, emails and other correspondence, phone conversations, documents that you provide to us, or when you contact us for any other reason by any media, for example when you:
- Enquire about properties for sale or register with us as a buyer or a seller
- Contact or interact with us through the Website
- Provide feedback to us
- Request marketing and/or other communications to be sent to you
This includes Identity, Contact, Profile, Usage and Marketing and Communications Data.
Personal information collected automatically
In addition to information that you provide to us, we collect other information using automated means such as cookies, web beacons, embedded scripts, and other kinds of technology.
Browsing and use information: such as pages, links, videos, products, and content viewed, applications used or viewed, and metrics surrounding those views including time, length of visit, the locations viewed before and after;
Device and technical information: such as the internet protocol (IP) addresses of computers or devices you use, device identifiers, browser characteristics, operating system details, language preferences, referring uniform resource locaters (URLs), services used, telecommunications data (source, metrics, logs), log files, audit trails, or cookie IDs.
This helps us enhance your experience of the Website and services and allows us to improve the Website.
4. Why is my information needed?
We use the personal information we collect about you for the purposes, and with their corresponding legal basis, referenced below. These legal bases are described in the context of the General Data Protection Regulation (GDPR), a general law of the European Union which came into effect as of 25 May 2018. The GDPR applies both to the online and the offline processing of personal data. However, the ePrivacy Directive is a separate law that addresses the uses of personal data specifically in the online environment. Although we are required to be compliant with the GDPR’s general legal framework, we also rely on consent under the ePrivacy Directive to the extent we are required to do so, and when we refer to “ePrivacy Consent” below, it is on this basis but without prejudice to the performance of some of our data processing activities on the basis of our legitimate interest, where possible.
Below is a list of the reasons we would use your personal data and the legal basis we rely on to do so:
Provide services and features you request, including to create and manage your account
Legal basis: To take steps prior to and to perform the contract
Data types: Contact information, preferences, financial information, communication information
Respond to requests, comments, or questions, and to provide customer support, including our managed social interactions and chat
Legal basis: To respond to a request coming directly from the interested data subject
Data types: Contact information, communication information, preferences, forum / review, financial information
Call recording and monitoring
Legal basis: Legitimate interest – customer experience, quality control, and communications
Data types: Contact information, communication information
Enable and improve website functionality
Legal basis: Legitimate interest – better customer experience
Data types: Contact information, preferences, device and technical information, browsing and use information
Personalise and improve your experience using the Services; Target marketing efforts to appropriate audiences, including use of retargeting ads across other websites, devices, and platforms
Legal basis: Legitimate interest (relevant advertising, better customer experience, efficiency). ePrivacy consent
Data types: Contact information, browsing and use information, device and technical information, preferences, demographic or interest information
Monitor and identify trends, usage, and activities of users of the Services, customise, and improve the Services’ content, products, and services
Legal basis: Legitimate interest – better customer experience, efficiency, providing tailored product offering
Data types: Contact information, device and technical information, browsing and use information, demographic or interest information
Send you marketing materials and offers for products and services that we think may interest you
Legal basis: ePrivacy and GDPR consent, without prejudice to legitimate interest where possible.
Data types: Contact information, preferences, browsing and use information, demographic or interest information
Contact you regarding your use of the Services, your transactions
Legal basis: Legitimate interest – improving transparency and awareness
Data types: Contact information, order information
Contact you at our discretion regarding changes to our policies
Legal basis: Compliance with legal obligation
Data types: Contact information
Prevent fraud or other misuse
Legal basis: Legitimate interest – protect customer and business information
Data types: Contact information, financial information, device and technical information, browsing and use information
Conduct research and analysis, including focus groups and surveys
Legal basis: Legitimate interest (relevant advertising, better customer experience, efficiency). ePrivacy Consent
Data types: Contact information, browsing and use information, device and technical information, preferences, demographic or interest information Enforce our policies, comply with legal obligations
Legal basis: Compliance with legal obligation
Data types: Especially contact information, financial information, device and technical information, browsing and use information; potentially all data types
Adhere to industry standards, and otherwise manage our business
Legal basis: Legitimate interest – comply with the law, standards, and Terms and Conditions
Data types: Especially, contact information, financial information, device and technical information, browsing and use information; potentially all data types.
5. Disclosure of personal data
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service you have requested, and they are obliged to keep your information safe and secure and to use your information in accordance with applicable data protection law.
We may in a few other limited cases need to disclose your information to third parties:
- As required or permitted by applicable law, for compliance with a legal obligation; establishment, exercise or defence of legal claims, or if we believe in good faith that such disclosure is necessary;
- At the request of government authorities conducting an investigation;
- With our third-party service providers for processing payments, account servicing, customer research, marketing, provision of information technology services, and records maintenance;
- If we believe there has been a violation of our terms or policies, or to protect anyone’s rights, property, life, health, security, or safety;
- In connection with any proposed or actual merger, purchase, sale (including a liquidation, realisation, foreclosure, or repossession), lease, amalgamation, or any other type of acquisition of all or any portion of our assets, financing, disposal, conveyance, or transfer of all or a portion of our business to another company;
- With third parties that conduct analytics or data appending to help us offer you more relevant products and services; or
- For other purposes disclosed elsewhere in this Privacy Statement, or at the time you provide your personal information.
- All third parties are obliged to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and they are only permitted to access your personal data for specific purposes and in accordance with our instructions.
6. Security measures in place to protect your information
We maintain appropriate security measures to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration or destruction, taking due account of the nature of the data and the risks involved in its processing. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who, for reasons of business, need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have processes and procedures to deal with any suspected personal data breach and will notify you (and any applicable regulator) of a breach, where we are legally required to do so.
We cannot guarantee the security of data sent over the internet, whether unencrypted or inadequately encrypted, as data sent in this way is inherently insecure.
Transfer of data abroad
We do not transfer your data abroad unless you have purchased an overseas investment or where the developer of the investment you have transacted, is based overseas. If your data is shared with an overseas entity, they are under an obligation to store it securely and treat it as strictly confidential – only contacting you in the case of any legal requirements.
Marketing
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We never share your personal data with any third party for marketing purposes without your express consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@movingupestates.com at any time
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
We will only use your personal data for the purposes for which we gathered it unless, in our considered opinion, it is reasonable to use it for another compatible purpose.
Please note that we may process your personal data without your knowledge or consent, in accordance with the above rules where this is required or permissible in law.
7. Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at info@movingupestates.com
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 clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to 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.
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 several requests. In this case, we will notify you.
8. How long do we keep your personal information?
Personal information is retained based on legal, business and contract requirements. The information will be deleted, anonymised, or be limited to specific purposes and kept for no longer than is necessary, taking into account the limitation periods for potential claims. If a type of personal information is used for more than one purpose, then the personal data would be restricted, but kept for the longest applicable period. In some circumstances we may anonymise your personal data (so that it can no longer identify you) for research or statistical purposes; this information can be used indefinitely without further notice to you.
Your right to be forgotten
You have the right to request the deletion or removal of personal data where there is no compelling reason for its continued processing.
Requests for deletion will be limited by their continued necessity under Article 5(1)(e) of the GDPR, as required or permitted by applicable law, for compliance with a legal obligation; establishment, exercise or defence of legal claims, or if we believe in good faith that such disclosure is necessary; at the request of government authorities conducting an investigation; if we believe there has been a violation of our terms or policies, or to protect anyone’s rights, property, life, health, security, or safety; to resolve outstanding disputes; or to troubleshoot existing problems, such as submitted security or functionality issues.