Expose is an innovative tech-enabled estate agency business built upon the principles of integrity, convenience and immediacy.
We combine exceptional marketing with intelligent strategies and pioneering technology to get the best result for our clients and aim to offer the best user experience in our industry.
We also aim to offer information parity for both our sellers and buyers and we believe that transparency between both parties is key to achieving the best result and a more enjoyable experience for everyone.
We offer a multiple property services including residential sales and lettings, property management, referring mortgage advice and conveyancing services, and in order to enable us to provide these and future services we will need to collect and process personal information about you, making us a “data controller” for any personal information you provide to us, we are therefore responsible for complying with data protection laws, this document helps you better understand how we will do this and outlines our responsibilities to you and your data, your rights, how we hold and process that data and how you can complain.
As we understand it, we are the only pay on performance estate agency to actively encourage open communication between our sellers and buyers, we believe in utter transparency and the only way to achieve this is to allow open and free communication between us all.
We also support modern methods of communication, such as whatsapp, which is baked into our website, so we will need your consent to communicate with you using these platforms, we wholeheartedly believe this will enrich your experience, information on this is found below.
Processing of your personal information
Naturally our relationship with you and the type of services we provide you will determine the nature of personal information that we collect and use about you. It will also determine the uses of your personal information, for example we will collect different personal information depending on the type of service we are offering, i.e. sales or lettings, and whether you are a seller or buyer.
This section details personal information collected about you and how it is used if you are either a buyer, seller, landlord or tenant of residential property.
We will collect…
Your title, name, and address, phone number(s), address(es) and email address(es).
Financial information, which may include your bank details, payment details and information obtained from credit checks if you are a landlord or tenant.
Documents provided to evidence your name and/or identity (such as your passport, driving licence etc) and proof of address (such as utility bills, bank statements, etc), a full list of acceptable identity documents can be found on the buyer/seller/landlord/tenant pages.
If you are a prospective tenant and have been introduced to a referencing company, any information collected as part of a referencing request.
If you are a prospective tenant, information about your employment, such as your job title, employment history and records (including information on your salary, benefits and earnings, past, present and future).
Additional information which is relevant to the property you are buying, selling, letting or renting, i.e…
your current home status and living circumstances
your family circumstances.
Information which we have gathered from public sources such as HM Land Registry.
Information which we have gathered from third party suppliers to confirm your identity and / or ownership of, or interest in, the property for sale or let.
How is your personal information collected?
We will collect information from you when:
You visit us or we visit you at your property;
You complete documentation including our terms of business, landlord management information, application for tenancy and reference requests;
You use our website;
You contact us by email, telephone, WhatsApp, Facebook (and other social media channels) and through any other written and verbal communications
You request information about our services or subscribe to a newsletter, marketing campaign or property alerts.
In addition to obtaining information directly from you, other sources of information can be…
third parties assisting with the sales or lettings process including solicitors, estate agents, third party referencing companies if you are a tenant and other property management companies
publicly available sources, for example Companies House or the HM Land Registry
credit reference agencies where you are a tenant.
third party suppliers used to confirm your identity and / or ownership of, or interest in, the property for sale or to let.
What will we use your personal information for?
We will use your personal information for a variety of different legitimate purposes, we of course must have “legal grounds” to do so, the following are examples of such…
We need to use your personal information to populate our terms of business and for you to engage us to carry out our services. For example, we need to use your personal information to arrange the letting or sale of your property and to administer all aspects of this service.
We have a legal and / or regulatory obligation to use your personal information. For example, our regulators and governing bodies obligate us to hold records of our dealings with you and the HMRC require us to keep certain records.
We need to use your personal information for a legitimate business purpose, for example to keep a record of all the properties that we have been involved with, to assist with the buying or letting process, to keep all involved parties up to date, to keep business and accounting records accurate, to manage and maintain our business operations and also to develop and improve our products and services. When we use your personal information for any of these purposes, we will always assess the need to use your personal information against your rights to privacy and will ensure we are protecting your rights at all times.
We have a legal obligation to comply with anti-money laundering regulations and as such we will use your data to satisfy our obligations, we may also need to process data of individuals who jointly own your property or that may be involved, or benefitting from, the transaction(s) we assist you with. We will use third party providers to confirm identities and property ownership, a current list of whom will be made available upon request (as they may from time-to-time change).
Marketing / social media campaigns, we will protect your privacy but may ask to use your transaction and / or our services and / or relationship in a marketing or social media campaign, you can of course object to this, for details on how to do so please see section 9.
Who do we share personal information with?
We always keep your personal information confidential; we will never share it or sell it for commercial purposes, and will only share it when necessary to conduct legitimate business activities or to satisfy legal or regulatory requirements, some examples of parties that your information could be shared with are:
Third parties involved in the sale or letting process…
Solicitors, involved in the property transaction and associated transactions (chains)
Other estate agents (in dealing with chains, although we would likely limit the information shared to your name and address or associated transaction address if different to your home address, your solicitors details and name of mortgage broker / lender
Property developers (if for example you were purchasing through them).
Mortgage and financial advisers
Property management companies.
Contractors (if you were a tenant and a repair or maintenance was necessary)
A third party assisting with proving your identity for regulatory requirements.
A referencing company and landlords where you are a tenant and we have introduced you to a particular referencing company.
Insurers who provide our insurance and companies who arrange such insurance.
Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
Third party Stitch Ai, who enable us to communicate with you by WhatsApp.
Debt collection agencies.
Credit reference agencies.
Our third party service providers such as IT suppliers, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
Third parties such as Trustpilot who we use to gather feedback about our services and client testimonials.
Third parties who undertake analysis for the purposes of product improvement.
Selected third parties in connection with any sale, transfer or disposal of our business.
Sharing of personal information with associated parties in a transaction…
Your personal information may be shared with your vendor or buyer, landlord or tenant, we shall assume that you consent to this as it is needed for legitimate business purposes, unless you communicate to us that you do not wish for this information to be shared, however, please note that it is highly likely that decisions made about agreeing a sale or let cannot be made without the consideration of this information.
The information shared in this instance is limited to…
Partial or full address
Lender/finance broker details
Your associated buying or selling status(es)
Communication between associated parties in a transaction…
We pride ourselves on allowing open, clear and candid communication between buyer and seller and tenant and landlord, so unless we are instructed by you otherwise we will exchange your contact information at an appropriate point in the transaction, this will consist of an exchange of email addresses and phone numbers.
We will consult with you during your transaction on this matter, and to be clear this is purely optional. The information shared will consist of…
Communication via associated parties may be via email, whatsapp or phone. If you do not wish for this to happen please alert us, we will ask for this via email at email@example.com
Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include: Transparency: You have the right to be informed about how we use your data. If you think we are doing something with your information that is not covered in this Privacy Notice, you can raise an objection (see below). Access: You have the right to ask us what personal information we hold about you, and to request a copy, free of charge. Please note if we consider that the request is speculative, excessive, or repetitive, we are able to charge a reasonable fee. This fee will be based on the administrative cost to us of providing the information. Objection: You can object to us processing your personal data in certain situations. Please note that this right will not apply in all circumstances. For example, where we are processing information because it is necessary for the provision of our services or to satisfy our regulatory requirements and (therefore is required to adhere to the terms of our contract with our clients) we will be required to continue processing this information. Withdraw consent: In circumstances where we are processing your data based on your consent, you can withdraw this consent at any time. Where our processing is based on your consent and such consent is then withdrawn, we may no longer be able to provide our services to you. Rectification: If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that such inaccuracy or incomplete information is rectified. Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it. Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it. Data portability: You can ask us to provide you, or a third party (if possible), with some of the personal data we hold about you in a commonly used electronic form so that it can be easily transferred. Appeal: If you are not satisfied with the way that we have dealt with your personal data, please let us know and we will try and resolve your concerns. If you are not satisfied with the outcome, you can make a formal complaint (see ‘How to Complain’ below).
If you would like to exercise any of those rights, please: • email us at firstname.lastname@example.org • let us have enough information to identify you
. You may need to prove your identity • let us know the information to which your request relates, including any account or reference numbers, if you have them.
For further information on your rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
How to complain
We hope that initially we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or by telephone on 0303 123 1113.
You will be deemed to accept such changes from your continued use of the Site and/or our services, except where an update to consent is required, in which case we will request such consent accordingly.
DPO / How to contact us
Our Data Protection officer is Graham Colliss, who can be contacted on the below email.
Please contact him if you have any questions about this privacy notice or the information we hold about you, we can be contacted by email at email@example.com and although we welcome queries by phone, for the interests of both parties we would prefer to receive enquiries via email.