Last updated: 10 May 2018
To provide you with our overseas property guides and help with your enquiries about listed properties, we need to collect information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.
This includes consenting to the processing of any sensitive personal information you provide, as described below in section 2. It also includes information you provide when you browse our website, request a guide, ask a question, enter a competition, promotion or survey and when you contact us for other reasons.
A special note about children
Children are not eligible to use Foremost Property Group Services. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use Foremost Property Group Services.
2. What information we collect
Information we may collect from you
We may collect and process the following information about you:
- Information you provide to us
You may provide us with information by filling in forms on our website, our partners’ websites or by talking with us by over the phone or corresponding with us via email or otherwise.
This includes information you provide when you browse our website, enter a competition, promotion or survey and when you contact us for other reasons.
- Initial information
To request information on a property on www.foremostpropertygroup.co.uk, you must provide your name, phone number and email address.
- When we communicate
When you communicate with us, including by phone, email or using other methods, we retain that information and our responses to you.
We may record calls on our telephone lines for quality control purposes. Any information you disclose to us will be held on these recordings. We also record any phone number used to call us where a call is connected and the number not withheld.
We ask that you do not disclose sensitive personal information, including the state of your health, in any communication, however if you should do so voluntarily, you consent for us to hold that information in our communication records and phone recordings (see further details below).
- Information we collect when you use our website
When you arrive at or leave the Foremost Property Group website, whether connected by a fixed line or wirelessly, we receive the web address of the site that you came from or are going to.
While you are using our site we collect information on the services you search for or view, page response times and length of visits to specific pages, how you interacted with each page (including scrolling, clicks and mouse-overs), and methods used to browse away from the page.
We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our website/app and the time zone setting, mobile network information and unique device identifier, which may include your Device’s IMEI number and/or MAC address, or the mobile phone number used by the Device. We do not capture GPS information about you.
If you give us permission, our app may collect information stored on your Device, including contact information from your address book, photos, videos or other digital content. The app may periodically re-collect this information in order to stay up-to-date.
- Social media
If you allow us to, we will collect information from other third parties such as Twitter, Facebook and Google – the app will periodically re-collect this information in order to stay up-to-date – and we may collect other information you have chosen to make publicly available on social media sites. Where we are one of your connections on a social media site, we may also connect information you have chosen to share with your connections on that site.
- Information about you from other sources
We may also collect information about you from other sources, including other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control.
We may receive information about you if you use any of the other websites we, or our group companies, operate or the other services we provide. We are also working closely with third parties (including, for example, business partners and affiliates, service providers, advertising networks, analytics providers, and search information providers) and may receive information about you from them. This may be combined with the information you provide to us.
We will use information we receive from business partners for marketing purposes only if you have provided your consent to do so, either to the third party which collected the information, or to us.
- Sensitive data
Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent.
Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.
To avoid infringing these restrictions, it is Foremost Property Group’s policy that we do not ask for or collect any of the above data from you or any other party, so we therefore ask that you please do not reveal any sensitive data about yourself or others in any communication with us.
If you do reveal sensitive data, for example by phone or in an email, you will be giving express consent for us to process that information by storing the recording of the telephone call, or the email or other communication.
3. How we use your information
Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient and customised experience. By submitting your information to Foremost Property Group and using Foremost Property Group you agree that we may use your information for the following purposes:
- Fulfilling your requests
We will use your information to:
• provide you with the information, products and services that you request from us, including providing you with overseas property guides and details about properties listed on our site; and
• administer any promotion, survey or competition that you enter via our website(s) or at property shows.
- Communication and customer service
We communicate with our users on a regular basis via email and phone to provide requested services and help you manage your account. These activities include:
• responding to requests for customer service;
• resolving customer complaints; and
• conducting customer surveys.
We use your email and physical address to:
• send your requested guide(s);
• respond to any questions you ask us;
• send you information about important changes to our Service, including notice of any times that our services may not be available; and
• send notices and other disclosures required by law.
Users cannot opt out of these communications, but they will be primarily service-oriented rather than promotional. If you do not wish to receive these communications at all, then you must contact us to advise this.
We also use your email address to send you other types of communications that you can control, including newsletters, customer surveys and special promotions. These communications are to:
• provide you with information about services we offer that are similar to those that you have already enquired about;
• provide news and interesting articles about property markets, marketing and advertising messages, updates on the services we offer, and promotional offers based on your activities when using the Foremost Property Group;
• measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or third parties’ websites;
• make suggestions and recommendations to you and other users of our website(s) about services that may interest you or them, which may be based on your activity on our website(s);
• keep you informed about market events and news; and
• tell you about new products and features we are developing that you may find useful.
You can choose whether to receive some, all or none of these communications and the methods by which you receive them when you request a guide, ask a question or talk to us over the phone.
- Service improvements and account management
We will use your information to deliver and improve Foremost Property Group Services and manage your account, including:
• detecting, preventing or remediating violations of our policies;
• providing you with customer support services including notifying you of changes to our service, including any outages;
• improving our existing, and developing new, products, services, websites, apps and capabilities;
• administering our website(s) and for internal business administration and operations purposes, including storage, backup, archiving, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
• as part of our efforts to keep our site safe and secure, including managing and protecting our information technology infrastructure.
- Device information
We will use this information to:
• administer our website(s) for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• improve our website(s) to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so; as part of our efforts to keep our website(s) safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our website(s) about goods or services that may interest you or them; and
• to comply with our regulatory obligations.
- Location information / IP (Internet Protocol) address:
We will use information about your location, derived from your IP address:
• to deliver relevant advertising to you, for example, information on tailored property guides for your region; and
• to protect against fraud.
- Questionnaires, surveys, competitions and profile data
From time to time we may offer you optional questionnaires, surveys and competitions. If you choose to answer these questionnaires, surveys or competitions, we may use your information to improve Foremost Property Group, send you marketing or advertising information, manage the competitions and for such purposes as collecting demographic information or assessing users’ interests and needs. You will be given notice of how the information will be used prior to your participation in the survey, questionnaire or competition.
- Accessing and changing your information
You can review the information you have provided to us and make any desired changes at any time by calling us on +44(0)1442 892060 or emailing us on email@example.com.
5. Sharing information with third parties
Where required by law
We may disclose necessary information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies, departments, regulatory authorities, self-regulatory authorities or organisations, and other third parties, including Foremost Property Group companies, where we are legally compelled and/or permitted to do so.
Mergers and acquisitions
Analytics and search engine providers
Affiliated property agents advertise their properties on our site. When you complete property enquiry form and provide your name, address and/or telephone number, we will pass these details on your instruction to the agent concerned so that they can contact you with more details about the property.
Third party websites
Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates.
If you enquire on a third-party website or via a third party application, any information that you enter on that website or application (and not directly through Foremost Property Group’ website) may be shared with the owner of any such third party website.
Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.
6. Transferring data overseas
Foremost Property Group is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.
The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries).
We will do our best to protect your information, however we cannot guarantee the security of your information transmitted to our site or sent to us by email or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorised access.
7. Data Retention Policy
We will retain your data for 5 years after the download of a guide or from your request for property details. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.
8. Systems Security Policy
System security and monitoring
To ensure data privacy, confidentiality and integrity, all information disclosed, shared, stored or used and any transactions performed by you through our website and app are encrypted.
To provide a secure environment for our website, we hold your data in secure data centres with high levels of physical and technical security, including using firewall systems, data encryption and anti-virus protection. We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems. External security experts conduct regular security reviews on our systems and we work with them to keep abreast of information security technology developments and implement relevant enhancement.
9. Customer rights
You have the following rights:
To ask us to correct any information we hold about you if it is incorrect.
Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. If you would like to make any changes, please contact us calling us on +44(0)1442 892060 or emailing us on firstname.lastname@example.org. We may ask you for additional verification information if you are changing certain details such as your name or your email address.
To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.
Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.
To ask us to return to you information you provided to us, also known as ‘data portability’.
You can ask us to send you in electronic format the information you provided to us under our Terms and Conditions or under consent.
To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.
To ask not to be subjected to automated decision making and profiling.
Foremost Property Group puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.
To ask for a copy of the information we hold about you.
We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.
To ask us not to process your information for marketing purposes.
You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by logging onto your account and managing your contact preferences, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional email.
You may exercise any of the above rights by contacting us at email@example.com.
10. Contacting us
The Data Controller
The Data Controller is Foremost Property Group Limited, Registered office address Sutton Court, Church Yard, Tring, Herts, HP23 5BB, United Kingdom Company number 6271862.
Contacting us with questions or requests
Complaints to the Data Protection Officer
If you believe that we have breached a privacy law with which we should comply, please send an email to firstname.lastname@example.org. We aim to respond in a reasonable time, normally within 30 days.
Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.
Complaints to the UK Information Commissioner
You have the right to complain to the UK Information Commissioner’s Office if you believe we have not handled your request in an appropriate manner. For information on contacting the ICO please see their website.