Privacy policy

For the purposes of applicable data protection and privacy laws, Work Work LTD trading as No Agent (‘NoAgent, ‘us’, ‘we’), registered in the UK with its registered offices at Work Work LTD, Comer Business & Innovations Centres North London Business Park Oakleigh Road South London N11 1GN. We are registered in England and Wales No 06360359. , is considered the ‘controller’ in respect of the Personal Data that it collects, uses and manages in accordance with this privacy policy (‘Policy’).

A ‘controller’ is a party that determines the purposes and means of data processing. ‘Processing’ essentially means doing anything with Personal Data. This includes collecting it, storing it, accessing it, combining it with other data, sharing it with a third party, or even deleting it.

References in this Policy to ‘the Website’ shall mean, collectively, our website and portal available via the domain https://noagent.properties/ and all sub- domains to that domain (for example https://ads.noagent.properties).

Protecting your privacy is important to No Agent. We are committed to protecting all Personal Data provided to us, whether by individuals with whom we do business, visitors to and users of the Website, or otherwise. Personal Data is information which relates to an identified or identifiable living individual.

This Policy explains what Personal Data we collect, how we may use and manage it and the rights you have in relation to your Personal Data. Before you provide us with any Personal Data, including browsing and using the Website, you should read through this Policy in full and make sure that you are comfortable with our privacy practices.

Please note that the Website may contain links to other websites. These third party sites are not subject to this Policy and we recommend that you check the privacy and security policies of each Website that you visit. We are only responsible for the privacy and security of the data that we collect and have no control over the actions of any third parties (including agents, our third party partners and our business users) in relation to your data.

If you have any questions or comments about this Policy or No Agent’s use of your Personal Data, please contact us by email at support@noagent.properties

Whose Personal Data do we collect?

No Agent collects Personal Data from a range of individuals in the context of its business activities, including:

• users of the Website;
• representatives of agents, our partners, suppliers and other business contacts;
• contractors;
• individuals who contact us by any means; and
• job applicants.

How we collect your Personal Data

We obtain Personal Data which you knowingly and voluntarily disclose to us, both in an online and offline context. We collect Personal Data when you:

• Register with the Website;
• Visit and use the Website and / or complete one of our web forms;
• Contact our customer service centre or request information from us in any other way; and
• Communicate with us via telephone, email, social networking websites, third party apps and other technologies.

We may also collect information received by us from third party sources. For example, if you register through an agent rather than registering directly with No Agent through the Website, we will receive confirmation from the agent that you have registered with them locally. We will then contact you by email to validate your registration with No Agent.

If you are registered with an agent at the time that an agent on-boards its property and customer databases to the Website, we will receive your Personal Data including your name, contact details, details of the property you are selling and the history of that property through the agent, e.g. how long your property has been on the market, how many viewings you have had etc. We will only process this data on behalf of the agent and will not use this data for our own purposes unless you register with us. If you do subsequently choose to register with us, this data will move into your No Agent central profile and No Agent will become a controller of that data for the purposes of applicable data protection and privacy laws.

If you purchase products or services from our business users or partners, having accessed their website through the Website, we may collect information from these third parties as to the value of any purchases you have made, for our commission purposes.

What Personal Data we collect

No Agent may collect and process a range of Personal Data from users of the Website, including:

General User Data

• Registration information including your name, login credentials, address, phone number and email address.
• Your property search criteria, including property type, cost and location, and any changes you may make to these from time to time.
• Your search history on the Website.
• Photos, images, videos, likes, comments, ‘pins’ and other interactions and content that you post within Property Playground.
• Information provided by you filling in our surveys, entering our competitions, posting on our discussion boards or using social media functions available on the Website.
• Recordings of calls with us.
• Property alerts that you set up on the Website.
• Your communications with us.

When you click through to a third party site through the Website, for example in order to purchase an item featured on Property Playground, or to enquire about a service provided by one of our third party partners, we may collect Personal Data, including the third party site you access, the value of any purchases you make and, at your option, a purchase history of the products or services that you purchase.

Seller / Landlord Data

When you are selling or letting a property through the Website, we will collect and process additional information from you and / or from any third parties you have instructed in connection with your sale, including:

• The agent you have instructed to sell / let your property.
• Your property’s status, for example, on the market / sold subject to contract / not on market / currently rented etc.
• Your price / rent expectations.
• Your availability for viewings at your property.
• Feedback provided by others on your property.
• Offers received on your property.
• On acceptance of an offer on your property, details of any related chain, the lawyers you have instructed etc.
• Expressions of interest regarding your property.
• Your / your current tenant’s proposed move-out date.
• The status of your sale / let following acceptance of an offer, for example ‘contracts signed’, ‘exchange completed’, in the case of a sale, or ‘deposit paid’ in the case of a let.

Purchaser / Tenant Data

When you are purchasing or looking to rent a property on the Website, we will collect and process additional information from you and / or from any third parties you have instructed in connection with your sale, including:

• Any agents you have registered with.
• Your property buying / renting status, for example, cash or mortgage, investment or live in, first time buyer, existing house to sell etc.
• Feedback you provide on properties you have viewed.
• Offers you have made on properties.
• On acceptance of your offer on a property, details of any related chain, your mortgage provider, the lawyers you have instructed etc.
• Your expressions of interest regarding properties in certain areas or properties that are sold subject to contract.
• Your availability to view properties and your preferred move-in date.
• Whether you will be moving in alone or with others, the names of any other purchasers or tenants and their relationship to you.
• The status of your purchase / rental following acceptance of your offer, for example ‘mortgage agreed’, ‘survey completed’, ‘contracts signed’, ‘exchange completed’, in the case of a purchase, or ‘deposit paid’ in the case of a rental.

Property Data

When we list a property on the Website, we will collect and process certain information relating to that property. We do not generally consider this to be Personal Data but there may be circumstances where some of this information is considered to be Personal Data. This information may include:

• Images of the property and floor plan.
• Asking price / rent.
• Sales history / sold price.
• Property address / location.
• Property description.
• Property type, e.g. detached, terraced etc.
• Property tenure, i.e. freehold / leasehold.
• Local area information, including nearby schools and amenities.
• Digital valuation.
• Agent valuation.

We may also process historical property data relating to properties which have previously been marketed on the Website, including data collected from third parties, for example sold prices collected from HM Land Registry.

Business Contact Data

If you represent an agent or one of our partners, suppliers or other business contacts, including business users registered on Property Playground, we may collect and process your Personal Data in a business context, including your name, gender, job title and employer, photographic ID, email address, phone number and other business contact details, details of your business and other interests and communications with you (including notes from meetings).

Technical Data

When you use the Website, we collect certain technical information that is sent by your browser to the Website. This includes your IP address, browser type, operating system and platform, language, time zone setting and device information. We will also collect certain information about your visits to the Website including login information, access times, URL clickstream to, through and from the Website (including dates and times), properties or other products / services viewed or searched for, page response times, download errors, length of visits to pages; page interaction information (scrolling, clicks) and methods used to browse away from the page.

The purposes for which we process your Personal Data

We process your Personal Data for the following purposes:

General

• To provide the Website and our services.
• To register you as a user and create your central profile, to maintain your account and save your preferences.
• To distinguish you from other users.
• To link your central profile with any local profiles held with agents.
• To process and respond to any enquiries, complaints or other communications received from you.
• To communicate with you, including in connection with your property transactions and potential property transactions on the Website.
• To enable you to update the Personal Data we hold relating to you when necessary.
• To enable you to search the Website for properties that may interest you and update your search criteria when required.
• To update your search criteria within your local profiles when you change these within your central profile.
• To provide you with service updates relating to the Website and notify you of changes to the Website and our services.
• To provide you with information relating to products and services that may be of interest to you.
• To allow us to identify and enable our users to view property trends, including historical market trends and property valuations.
• To allow you to access information about previous house sale prices in your area.
• For our commercial purposes, including to build a property database.
• To enhance the services you select, improve the relevance of your property search results and customise your experience of the Website.
• To contact you for your views on our services and notify you about changes to our privacy policy/terms of use etc.
• To provide a faster and more useful service from agents and facilitate direct communications between users and agents.
• To enable you to access products and services offered by our third party partners and business users.
• To allow participation in competitions/promotions via the Website.
• To improve and optimise the Website, including maintaining appropriate security measures.
• For internal operation of the Website including troubleshooting, testing, data analysis, statistical and survey purposes etc.
• To provide services to the agents that register with us.
• To communicate with third party contacts, including facilitating and managing our relationships with agents and third party partners.
• To calculate and recover commission due to us from our third party partners and business users.
• To carry out analytics in relation to the use of the Website.
• To comply with applicable laws and regulations.
• Other business-related purposes, including negotiating, concluding and performing contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration.

Sellers / Landlords

• To notify you that we have received your details from an on-boarded agent and activate your central profile at your request.
• To notify you that there are buyers / tenants interested in properties in your area.
• To provide you with agent recommendations and put you in touch with agents that are of interest to you.
• To allow you to book property valuations.
• To ‘advertise’ your interest in selling / letting your property to scope out potential purchasers / tenants.
• To create a high level ‘ad’ for your property before it goes live on the market.
• To advertise your property on the Website.
• To introduce you to prospective purchasers / tenants.
• To notify purchasers / tenants of your availability so that they may book viewings.
• To notify you of viewings booked at your property.
• To provide you with feedback given by individuals who have viewed your property.
• To inform you of offers made on your property.
• To enable you to negotiate with purchasers / tenants through the platform.

Purchasers / Tenants

• To enable you to register ‘expressions of interest’ or ‘buyer ads’ regarding properties or areas that are of interest to you.
• To notify you of properties that may be of interest to you, including properties that meet your search criteria or any ‘expressions of interest’ or ‘buyer ads’ that you have registered, and invite you to view them (‘property alerts’).
• To notify agents / sellers / landlords that you may be interested in viewing a property.
• To ensure any property enquiries or requests to book a property viewing are transferred to the relevant agent and enable you to book property viewings.
• To collect your feedback on properties you have viewed and to share it with the relevant agents and sellers / landlords.
• To invite you to a second viewing or to make an offer.
• To pass any offers you make to agents and sellers / landlords.
• To update you on properties you have viewed and offers you have made.
• To enable you to negotiate with sellers / landlords through the platform.

Aggregate Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data under applicable law as this data will not directly or indirectly reveal your identity.

Marketing Communications

We may use your Personal Data to provide you with marketing communications, including sending you:

• direct marketing communications about products and services (both our own and those of our partners and other trusted businesses) which we think will interest you; and
• communications on third party social media platforms.

We may also carry out lead profiling based of your use of the Website, for example, any indications of intention to book a valuation appointment or viewing.

We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences at any time, you can: (i) log into your central profile to adjust your settings; (ii) follow the opt-out links on any marketing messages sent to you; or (iii) contact us at support@noagent.properties and request that we no longer send you marketing communications. Use of the Website is never contingent on your consent to marketing.

We also use your Personal Data to monitor the effectiveness of our marketing communications.

Recruitment

When you apply for a job via the Website or otherwise, we will collect additional more specific Personal Data about you, such as your qualifications, career history, third party references and interview notes. We may also ask you for other information, for example your interests and the types of jobs you are interested in. Any Personal Data you provide to No Agent in relation to a job vacancy will be processed in accordance with our Employment Candidate Privacy Notice.

The legal basis for No Agent processing your Personal Data

In order to comply with applicable data privacy laws, No Agent is required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for No Agent processing your Personal Data will typically be one of the following:

• your consent;
• the performance of our contract with you to provide certain services;
• our legitimate business interests (as set out below); or
• compliance with our legal obligations.

Legitimate Interests

We process your Personal Data where it is necessary for one or more of the following legitimate interests:

• running our business;
• providing services to our business and consumer users;
• maintaining relationships with our users and partners;
• analysing how our users purchase and use our products and services;
• ensuring we provide a competitive and cost-effective service;
• analysing property data to develop and improve market insights for our users;
• developing, enhancing and improving our products and services;
• building relationships with our partners so that we may offer users a wider range of services;
• informing our marketing strategy;
• keeping the Website up to date and relevant;
• provision of administration and IT services;
• keeping our records up to date;
• recovering debts due to us and preventing fraud;
• securing our network and systems; and
• growing our business.

Who we share your Personal Data with

Agents and other parties instructed on a transaction

No Agent will share your Personal Data with specified agents as necessary in connection with your use of the Website, including when you book a property valuation or viewing with an agent, when you make or accept an offer on a property and to facilitate all necessary communications between purchasers / tenants, agents and sellers / landlords.

When you register an interest in properties via MatchMaker, Secret Property, Sneak Peek, ChainMaker or any enquiry that relates to a property on our site, your contact information will be shared with the relevant agent to enable them to contact you to discuss your interest. This includes making use of SmartVal to obtain a valuation on your property.

Once we have shared that information the agent’s privacy policy will apply as to how they then use your information. We recommend that you check their policy before sharing any additional personal information. We are not responsible for the use of the information we share with agents in these circumstances.

When you make a booking with a particular agent, your No Agent central profile data will be shared with that agent in order that the agent may create their own ‘local profile’ for you, whether within the No Agent platform or on the agent’s own system. Your central profile and any local profiles you hold with agents will be linked.

When you update your property search criteria in your central profile this Personal Data will be shared with all agents with whom you hold a local profile, in order that such local profiles may be updated on the same basis.

At your option, we may provide updates to parties instructed on your property transaction, such as solicitors, mortgage brokers etc., for example, ‘mortgage agreed’, ‘contracts signed’ etc.

When you make use of our mortgage affordability calculator and select “How much can I borrow?” the information you have provided to obtain an estimate will be shared with a third-party financial broker in partnership with No Agent or with Estate Agents that work with No Agent so that they can contact you to discuss your requirements. Their privacy policy will then apply as to how they make use of the shared data.

No Agent may also use such reviews in other promotional material and media for our advertising and promotional purposes.

Website Authentication

We use third party sign-in / authentication tools provided by Google for the purposes of you signing into the Website. Your login credentials (e.g. username and password) will be shared with Google for the purposes of verifying your sign-in only. We do not store your password.

Third Party Links Products and Services

Where you wish to enquire about or purchase third party products and services offered via the Website (including via Property Playground), we will share your Personal Data with the relevant third party provider, as necessary in connection with your enquiry or purchase. If you are a business user of Property Playground or you represent one of our third party partners offering services on the Website, we will share your business contact details with users who are potential customers for the products or services that you offer.

Other Sharing

No Agent may share your Personal Data with people within our company who have a ‘need to know’ that data for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within No Agent.

We may disclose your Personal Data to third parties including the authorities, No Agent’s advisors, suppliers of IT services and third parties engaged by No Agent for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from No Agent’s Website; for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation; and to enforce No Agent’s Website Terms and Conditions of Use.

We may disclose your Personal Data to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets.

Finally, we may share non-Personal Data with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-Personal Data of numerous people together so that the data does not relate to any one person. De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.

Transfers of Personal Data

Please note that any person to whom No Agent may disclose your Personal Data under this Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country.

Whenever we transfer Personal Data across borders, we take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated in accordance with this Policy. You can request a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances, by emailing us at support@noagent.properties

Security

No Agent takes all reasonable technical and organisational security measures to protect Personal Data from accidental or unlawful destruction, accidental loss and unauthorised access, destruction, misuse, modification or disclosure.

Records retention

Your Personal Data is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records (including Personal Data) are destroyed or erased from our systems, or fully anonymised, when no longer required. The amount of time that records are kept for varies depending upon the type of Personal Data they contain, in accordance with our data retention policy. In particular:

• Once a property is sold, the data about that property becomes historical property data. It remains on the Website as part of our property database. To the extent that property data is also Personal Data, this will generally cease to be the case over time.
• User enquiry and correspondence data is deleted after 2 years and telephone call recordings are deleted after 3 months.
• Registration information is kept for as long as you have a central profile set up (this data is deleted when you close your No Agent account).
• General Website use data, e.g. your participation in competitions, promotions and surveys, data relating to third party sites you have accessed via the Website etc. will be retained for 2 years. Information provided via interactions through social media platforms will be retained as long as it is kept on your social media account (we will not copy or store it separately).

Your rights

Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.

• Right to access and rectification: You can request details of the Personal Data we hold, along with a copy of your Personal Data, and the correction of any errors in your Personal Data. You should review the Personal Data held in your No Agent central profile from time to time to ensure that it is up to date.
• Right to erasure (“right to be forgotten”): You have the right, in certain circumstances, to ask for your Personal Data to be deleted. In specific cases, we may not be able to delete some types of Personal Data, in particular, where we have a legal obligation to keep that Personal Data (e.g. for tax or accounting purposes) or, for example, where you want us to continue to provide you with our services and the processing of the Personal Data is necessary for the provision of those services.
• Right to portability: You have the right in some cases to receive your Personal Data in a digital format or to have it transmitted directly to another controller where technically feasible.
• Right to object: You have the right to object (on grounds relating to your particular situation) to the processing of your Personal Data on the basis of our legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: You can withdraw your consent at any time in respect of any processing of Personal Data which is based upon a consent.

We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Personal Data even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, email us at support@noagent.properties

Concerns and complaints

If you have a concern or complaint about how No Agent has used your Personal Data, as a first step, you should raise this in writing with No Agent, by contacting our Data Protection Officer at support@noagent.properties

If you are not satisfied with the handling of your concern or complaint by No Agent, you can escalate this to your national Data Protection Authority.

Changes to this Policy

We reserve the right to modify or amend this Policy at any time by posting the revised Policy on the Website. It is your responsibility to review the Policy every time you submit Personal Data to us.

Cookies

We use cookies when you visit the Website. You can read more about how we use cookies and how to set your cookie preferences in our Cookie Policy.

Social media features

noagent.properties includes social media features, such as sharing or following buttons. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly.

Social media features are either hosted by a third party or hosted directly on our websites. This Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

Your feedback

We think it is very important to hear what you have to say about our policies. If you have any feedback about this Policy, please e-mail us at support@noagent.properties