PERSONAL DATA WE COLLECT

This privacy notice, together with our Terms and Conditions and any other notice referred to in it, explains how we collect and use your personal data when you visit our website or use our services. This website is not intended for children, and we do not knowingly collect personal data from children. This privacy notice was last amended in July 2022 and supersedes any earlier version.

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 Pinkertons, 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:

  • Identity Data (name, marital status, title, date of birth, gender, username and password, purchases made by you, your interests and preferences, property ownership details or other evidence of your ability to sell or let the property, nationality, references, credit checks, details of your immigration status, feedback and survey responses)
  • Contact Data (billing address, delivery address, email address and telephone numbers)
  • Financial Data (bank account and payment details)
  • Transaction Data (details about payments to and from you and other services you have purchased through us)
  • Technical Data (internet protocol address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, identification number, online identified, location data and other similar identifying information required for the customer's device(s) to communicate with websites and applications on the internet)
  • Usage Data (how you use our website products and services, the full uniform resource locators clickstream to, through and from our site (including date and time), download errors, lengths of the visit to certain pages, page interaction information, methods to browse away from the page and any phone numbers you use to call us)
  • Marketing and Communications Data (your marketing preferences from us and our third parties and your communication preferences)
  • Call recordings (recordings of your conversations with us)


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; whilst it derives from personal data (in the example, it is derived from your Usage Data), it does not reveal your identity to us. If we link this Aggregated Data to your personal information, it will be treated as personal data in line with this policy.

HOW WE COLLECT PERSONAL DATA

We use different methods to collect data from and about you including through:

DIRECT INTERACTIONS

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • contact us through social media;
  • Walk in to or telephone one of our branch offices;
  • enter a competition, promotion or survey;
  • give us some feedback;
  • speak with us on the telephone, and we record the call


THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We may receive personal data about you from various third parties and public sources, for example:
  • Contact, Financial and Transaction Data from providers of payment services such as Mastercard based inside the EU.
  • Identity and Contact Data from data brokers or aggregators such as Property Pal and Property News (based inside the EU), or Facebook, Instagram, YouTube or LinkedIn (based outside the EU).
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  • Credit referencing agencies

HOW WE USE YOUR PERSONAL DATA

We use your personal data for the purposes shown in the table below. We will only use your personal data for the purposes for which we collected it. We will let you know if we need to process your personal data for a different purpose incompatible with the original purpose.

We may process your personal data for a different purpose without your consent, where we must comply with our legal obligations.
Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest
To contact you Identity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you

Necessary for our legitimate interests (for running our business, to recover debts due to us, to keep our records updated and to study how customers use our products/services)
To carry out our obligations arising from any contracts entered into between you and us and to provide with you the information, products and services you request from us Identity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you

Necessary for our legitimate interests (for running our business and to recover debts due to us)
To provide you with information about other goods and services that we offer which we feel may interest you Identity
Contact
Technical
Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)
To permit selected third parties:
  • to provide you with information about goods or services which we feel may interest you
  • to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website
Identity
Contact
Technical
Usage
Consent (in relation to SMS and email marketing communications)

Necessary for our legitimate interests (to develop our service offering)
To assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website Identity
Contact
Financial
Transaction

Marketing and Communications
Call Recordings
Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services, for training and monitoring of our customer service standards and to help resolve disputes
To notify you about changes to our service Identity
Contact
Performance of a contract with you

Necessary to comply with our legal obligations

Necessary for our legitimate interests (to keep our records updated)
To ensure that content from our website is presented in the most effective manner for you and your computer Identity
Contact
Financial
Transaction
Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)
To verify your identity Identity
Contact
Financial
Transaction
Necessary to comply with our legal obligations

Necessary for our legitimate interests (for running our business and to prevent fraud and money laundering)
As part of our efforts to keep our site safe and secure and to prevent or detect fraud Identity
Contact
Financial
Transaction
Necessary to comply with our legal obligations

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To provide customer support Identity
Contact
Performance of a contract with you
To facilitate and to enable you to partake in a property viewing, open house event or visits to property marketing suites Identity
Contact
Performance of a contract with you

Necessary for our legitimate interests (for running our business and to develop and grow our business)
To comply with the requirements imposed by law or any court order Identity
Contact
Technical
Usage
Necessary to comply with our legal obligations
Where you have viewed through us, we may disclose your name to a landlord or vendor and/ or another estate agent where we have been dis-instructed, in order to avoid a potential commission dispute Your name Necessary for our legitimate interests (to protect our entitlement to a commission and to avoid commission disputes wherever possible)
We may disclose tenant references and any forwarding address to a landlord Identity
Contact
Necessary for our legitimate interests (to help protect our landlord customers' legal rights)
MARKETING
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 permission for us to pass your information to third parties for marketing purposes. If you withdraw your consent, we will cease to market goods and services to you.

You can ask us to stop sending you marketing messages at any time by:

  • logging into your 'Pinkertons' account (if you have one) and checking or unchecking relevant boxes to adjust your marketing preferences;
  • following the opt-out links on any marketing message sent to you; or
  • contacting us at any time by emailing info@Pinkertonsni.com or by calling 028 91 479393.


When you withdraw your consent to receiving marketing messages, we will still process your personal data to fulfil our contract with you in accordance with our legal, accountancy and regulatory obligations.

If you no longer wish to be contacted by third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies about how to unsubscribe.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside Pinkertons for marketing purposes.

COOKIES


The Pinkertons website and applications may automatically collect data about how you use our services to help us improve our website's future functionality and assist with advertising and targeting.

We use Google Analytics, a web analysis service provided by Google.

The cookies on the Pinkertons website do not track, collect or upload data such as your name, email address or billing information. Still, it may collect data about your equipment and browsing activities. We may collect and report on the adoption and usage of specific features, crashes, exceptions, and other useful, anonymous metrics.

Specific devices can detect your approximate location via latitude and longitude. The accuracy of this data is not under the control of Pinkertons. If this feature is requested, Pinkertons will prompt you to provide your permission to access your location data to provide you with results or directions based on your current location. You can disable location settings within your browser or app.

Please consult our cookie policy to read more about our use of cookies on the Pinkertons website.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties below for the purposes set out in the "How we use your Personal Data" table above. We have agreements with our third parties that restrict their use of your personal data. We only allow third parties to use your personal data for specified purposes and in accordance with our instructions.

Category Explanation
Related Third Parties First Complete Limited T/A Embrace Financial Services Limited (where you have consented for us to do so). Foster & Sons Removal Company (where you have consented us to do so.
External Third Parties Service providers acting as processors based in the United Kingdom who provide IT and system administration services, anti-money laundering service providers, tenancy deposit administrators (such as the Tenancy Deposit Scheme Northern Ireland) and services to enable us to perform our contract with you, or carry out surveys to help us improve our services.

Property developers acting as Processors or independent controllers based in the UK who process your personal data in order to arrange and facilitate your visit to their marketing suite or development site.

Advertisers and advertising networks (including social media) that require the data to select and serve relevant adverts to you.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accountancy services.

HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

If you are a tenant and we are helping you with the administration in moving, we will refer your personal data to Vouch Limited which acts on our behalf to provide these services. Vouch Limited may contact you about the other services that they provide if you consent for them to do so.

We may forward your present and future contact details to utility suppliers, local authorities and credit or reference providers, including for the purposes of debt recovery.

Where you are a landlord or a vendor we may forward your personal data to HM Land Registry for proof of property ownership purposes.
Other Third Parties Sometimes there may be third 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.

DATA SECURITY

Through technical and organisational means, we are 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. If we become aware of a data breach, we will notify the Information Commissioner's Office where we are required to. If we believe the data breach is serious, we may inform you.

INTERNATIONAL TRANSFERS

We will not transfer your personal data outside the European Economic Area except to a country offering the same level of protection for your personal data. For example, with certain service providers, we may use specific contracts approved by the European Commission, which ensures that your personal data has the same protection as it would have in Europe.

DATA RETENTION

We will retain your personal data whilst you use our services (or whilst we provide services connected to you) and for at least seven years after that 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 data so it is not associated with you, and we may then use this information indefinitely.

YOUR LEGAL RIGHTS

To the extent provided by law, you have the right to access a copy of the personal data we hold and process about you. You have rights to the following information:
Access a copy of the personal data that we hold and process about you. You have rights to the following information:
  • The purpose(s) for which we are processing your information;
  • The categories of personal information we hold about you;
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed;
  • The period for which we will store your information, or the criteria used to determine that period;


Object to the use of your personal data (including for marketing purposes) by
  • Informing a member of Pinkertons' staff; or
  • By ticking the relevant boxes on the data collection forms; or
  • By logging into your 'Pinkertons' account (if you have done) and checking or unchecking appropriate boxes to adjust your marketing preferences; or
  • By emailing info@Pinkertonsni.com


Please note that even if you refuse marketing, we will still contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions. You can request the following:

  • Rectification of any inaccurate information we hold about you;
  • Erasure of the personal data we hold about you (in certain situations);
  • Ask that we do not make decisions about you using completely automated means; and/or
  • Ask that personal data we hold about you is, where technically feasible, transmitted to a third-party chosen by you, in a commonly used, machine-readable format.


The rights listed above may not apply in certain circumstances. Therefore we may not always be able to comply with your request. We will tell you if this is the case. We will usually respond to a request from you to exercise your rights within one month of receipt, but it might take longer if your request is particularly complex or if you have made several requests. Please be aware that we may need to process your personal data and/or request specific information from you to help us comply with your request. Generally, you do not have to pay a fee to exercise these rights, but you may have to pay a fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request.

HOW TO CONTACT US

We are registered as a Data Controller with the Information Commissioner's Office, the UK supervisory authority for data protection issues. To contact us about how we handle your personal data, please contact our Data Protection Officer at info@pinkertonsni.com. Alternatively, please write to our Data Protection Officer, Pinkertons (NI) Limited, 125 Main Street, Bangor, Co. Down, BT20 4AE. If you have a complaint about how your personal data has been processed, you have the right to contact the Information Commissioner's Office. Still, you may be required first to complete our internal complaints procedure.

ANTI-MONEY LAUNDERING

Pinkertons is committed to operating its business transparently and openly, consistent with our legal and regulatory obligations. We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity. We always strive to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to the National Crime Agency.

As part of this commitment, we adopt strict compliance with all Anti-Money Laundering rules, with specific emphasis on the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010 and the Terrorism Act 2000.

Pinkertons policy commitment applies to all our customers, including vendors, buyers, landlords and tenants. As a result, we obtain and hold for at least seven years evidence about our customers' identity and, where appropriate, obtain proof of property ownership and source/destination of funds. We cannot proceed with any work on behalf of our customers if we cannot get this information. Customers' identities will be subject to an electronic identity check, including a credit check.

For a complete list of acceptable identity documents, please click here.

We are registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017. If you would like to speak to us about Anti-Money Laundering, please email info@pinkertonsni.com.

INDEMNITY

You acknowledge that you are solely responsible for the use to which you put this website and all the results and information you obtain from it and that all warranties, conditions, undertakings, representations and terms, whether expressed or implied, statutory or otherwise, are at this moment excluded to the fullest extent permitted by law.

Save in respect of liability for death or personal injury arising out of negligence or for fraudulent misrepresentation, we and all contributors to this website at this moment disclaim to the fullest extent permitted by law all liability for any loss or damage, including any consequential or indirect loss or damage incurred by you, whether arising in tort, contract or otherwise, and arising out of or about or in connection with your access to or use of or inability to use this website.

Whilst we take every care to ensure that the standard of this website remains high and to maintain its continuity, we do not accept any ongoing obligation or responsibility to operate this website (or any particular part of it).

If any part of our terms and conditions is deemed unenforceable (including any provision in which we exclude our liability to you), the enforceability of any other part of these conditions will not be affected.

These terms and conditions and your website use are governed exclusively by Northern Irish law.

This does not affect your statutory rights as a consumer.

Pinkertons (NI) Limited is registered in Northern Ireland (registration number NI615501). Our registered office is 125 Main Street, Bangor, Co. Down, BT20 4AE.
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