Privacy Notice


Introduction 

Welcome to the poweredbypie privacy notice. For details of the companies that this includes please see below.

We respect your privacy and we are committed to protecting personal data. This privacy notice will inform you about your privacy rights, how the law protects you, what types of data we need to provide you with services and collect for other purposes and how we look after personal data.

 

1.     Important information and who we are

Purpose of this privacy notice 

This privacy notice aims to give you information on how we collect and process data you provide us in a variety of ways such as (without limitation) when you use any of our websites (see below for website details) generally and regardless of where you visit it from), use our ordering platforms which are accesses via our websites, when you order products or services from us by other agreed methods, when you have signed up to receive our newsletter or attend an event we have organised or where we communicate with you generally in a commercial manner (for example: to follow up on a meeting at a trade fair, or a request for information or because we have identified your business as a potential client) or because you supply products or services to us.

Our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

 

Controller Information

poweredbypie is a group of companies as set out below. As this privacy notice is issued on behalf of all of the poweredbypie group when we mention, "we", "us" or "our" in this privacy notice, we are referring to the relevant poweredbypie company as controller as is responsible for processing your data.

poweredbypie group

CRN

Controller of named website

R-SQUARED HOLDCO LIMITED

10708321

 

R-SQUARED BIDCO LIMITED

10708732

 

PROPERTY INFORMATION EXCHANGE LIMITED

06029390

www.poweredbypie.co.uk

www.brighterlaw.co.uk

www.spidercubed.co.uk

HOMEINFO UK LIMITED

05035207

 

PSG CONNECT LIMITED

03674092

www.psgconnect.co.uk

JCS SEARCHES LIMITED

10412876

 

HOMEINFO WALES LIMITED

05035207

 

HOMEINFO ENGLAND LIMITED

10037152

 

PSG FINANCIAL SERVICES LIMITED

05543910

 

PSG CLIENT SERVICES LIMITED

04762434

 

 

We have appointed a Group data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details 

Name or title of data privacy manager: Lee Paine

Postal Address: Citibase Business Park, Wyvols Court, Swallowfield, Reading RG7 1WY

Email address: Lee.Paine@poweredbypie.co.uk

Telephone number: 0208 334 1051

 

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

poweredbypie companies providing search products are are regulated by the Property Codes Compliance Board (PCCB) (www.pccb.org.uk) and we area  member of the Council of Property Search Organisations (CoPSO) (www.copso.org.uk).

PSG Financial Services Limited is authorised and regulated by the Financial Conduct Authority (FRN 583137).

 

Your duty to inform us of changes 

It is important that the personal data we hold is accurate and current. Please keep us informed if your details change during your relationship with us.

 

Third-party links 

This website may include links to third-party websites such as those relating to our suppliers or partners. 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 our 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 from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect and use data which relates to you as (i) a user of the website or other client of our business where we supply products and services in by other agreed methods (Client), (ii) a business person with whom we do, or would like to do business with (Client or Prospect) or (ii) a supplier to us (Supplier). The data we collect and use depends on the context of our dealings with you. We may also collect Own Client Data (see below).

In this notice where we refer to “you” we do not make a distinction between these routes of collect and uses and this distinction will be driven by the context. However, we have indicated the Data Types and data subjects in the table below.

Using our Ordering Platforms – Own Client Data

Where our websites have an ordering platform and you use this to order products and services or you provide us with client details by any other agreed method you agree that our Terms and Conditions apply. 

You are ordering products and services for your own clients in relation to their conveyancing transaction and accordingly, it is your responsibility to ensure that you have obtained appropriate consent or provided appropriate privacy notice information to your own client (Own Client) to enable you to share this data (Own Client Data) with us for this purpose. You would usually do this as part of your own client engagement process.

We do not use Own Client Data for any purpose other than to provide products and services to you and only ask you for Own Client Data that is relevant and which we need to provide the products and services to you.

In the limited instance of the use of our ordering platforms you agree that you are the data controller and we are the data processor. In using our ordering platforms, you agree to the data processing provisions set out in our Data Processing Notice.

In addition to the above, where a search product carries insurance cover for the benefit of your Own Client (a SRIP) in the event of a claim under the policy, we will share Own Client Data with the SRIP provider to process this claim.

 

Data Types and Data Subjects

We may collect, use, store and transfer different kinds of personal data which we have grouped together follows (this list is not intended to be exhaustive):

Data Type

Includes

Data Subjects

Identity Data

Name, email, telephone, business address, user name for the online platform

Client and Supplier or other persons granted view only access to the online platform which could include a Prospect

Contact Data

Billing address, email, telephone

Client or Supplier

Financial Information

Bank account and payment card details

Own Client, Client or Supplier

Own Client Data

including name, maiden name, address, purchase address, date of birth, gender, previous addresses, passport or driving licence details, national insurance number

Own Client provided by you under the data processing notice

Transaction Data

details about payments to and from you and other details of products and services you have purchased from us or we have purchased from you

Client and Supplier

Technical Data

internet protocol (IP) address, your login data, 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 our websites

Client, Supplier or Prospect using our websites

Profile Data

username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses

Client or Prospect

Usage Data

information about how you use our websites, and products and services you order

Client

Marketing and Communications Data

includes any preferences in receiving marketing from us, and our External Third Parties and your communication preferences, Identity Data

Client, Prospect or Supplier

 

We do not collect any Special Categories of Personal Data about data subjects (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3.    How we use personal data

We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

We do not rely on consent as a legal basis for processing personal data.  We are working with you in a business capacity and we consider that you are not providing data which relates to you as an individual and in respect of your personal life.

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

4. Purposes for which we will use personal data

We have set out below, in a table format, a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. This information is not intended to be exhaustive.

Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client including user of an online platform

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Own Client Data / Own Client Data

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy notices

Letting you know about any website service issues

Communicating with you to deliver services or report back on provision of those services

(d) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Marketing and Communications

 

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

 

 

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our websites and ordering platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our websites, ordering platforms, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have not opted out of receiving that marketing.

We will not use any Own Client Data for marketing purposes.

 

Third-party marketing  

We will get your express opt-in consent before we share personal data with any company outside the poweredbypie group for marketing purposes.

 

Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

 

Change of purpose  

We will only use personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5.    Disclosures of personal data

We may need to share personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties – these are businesses within the poweredbypie group as set out above.
  • External Third Parties – these are those third parties (also Suppliers) who provide us with products and services and which are ordered through the ordering platform.
    • This category also includes Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; and
    • HM Revenue & Customs, Financial Conduct Authority, PCCB, CoPSO and other regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • 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 personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of personal data and to treat it in accordance with the law and only for specified purposes. We do not allow our third-party service providers to use personal data we share for their own purposes.

 

6.    International transfers

Generally, for our internal functions we do not transfer your personal data outside the European Economic Area (EEA).

Whenever we transfer personal data out of the EEA, we ensure a similar degree of protection is afforded to it.

Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the EEA.

 

7.    Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place 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.

For more information as how your data is protected, please click here.

 

8.     Data retention

How long will you use my personal data for? 

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. 

By law we have to keep basic information about our clients (and Own Clients) (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9.     Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. 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. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond 

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 a number of requests. In this case, we will notify you and keep you updated.

 

10.      Cookies

 A Cookie is a small file placed on your computer or device by websites when you visit certain parts or features of websites.

Our websites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our websites and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

See our Cookie Policy for details of the first party Cookies and first party cookies for analytical purposes that may be used on our websites. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our websites, it does enable us to continually improve then and make each a better and more useful experience for you.

Most internet browsers also enable you to choose whether you wish to disable all Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

 

The links below provide instructions on how to control Cookies in all mainstream browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835

Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)

Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB

Safari (iOS): https://support.apple.com/en-gb/HT201265

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences

Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)

 

 

 


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