Privacy & Cookie Policy

Paul Fosh Group Privacy Policy

 

1. Introduction
The Paul Fosh Group of companies (referred to in this policy collectively as the Group, we, our or us) is committed to protecting your privacy. This privacy policy (Privacy Policy) explains how we collect and process personal data when you interact with us.

We may update this Privacy Policy from time to time, so please check this regularly.

2. Who is the Paul Fosh Group?
For this Privacy Policy, Group consists of the following companies:

• Paul Fosh Group Limited
• Paul Fosh Auctions Limited
• Paul Fosh Lettings Ltd
• YourBid Limited

This list will be updated to include any companies which become a part of the Group.

3. Personal Data
Personal data means any information about an individual from which that person can be identified. It does not include data where an individual cannot be identified (anonymous data).

We have grouped together the personal data we use as follows:

• Identity Data includes first name, maiden name, last name, date of birth, job title and organisation name.
• Contact Data includes billing address, personal email address, business email address and telephone numbers.
• Financial Data includes bank account and payment card details held at third party processors, optional and when provided.
• Marketing and Communications Data includes your marketing and communication preferences in receiving marketing from us.
• Technical Data includes internet protocol (IP) address, your login data, and other technology information on the devices you use to access our services or websites.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Usage Data includes information about how you use our website and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data can be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal an identity. However, if we combine or connect Aggregated Data with personal data so that it can directly or indirectly identify a person, we treat the combined data as personal data. This would be used in accordance with this Privacy Policy.

We may collect, use, store and transfer different kinds of personal data. If you would like to see how your personal information is used, including for one of our specific services, please refer to the Using your personal data section at the bottom of this Privacy Policy.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party 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. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of, and the purpose of, receiving our services.

If you fail to provide personal data
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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

4. How is Personal Data collected?

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

Direct interactions. You may give us your personal data when you:

• Correspond with us by post, phone, email or otherwise.
• Become a client for our services.
• Request that we contact you via the contact button on our websites.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the relevant Group website cookie policy for further details.

Third parties. We may receive personal data about you from various third parties as set out below:

• • Identity, Contact, Financial and Transaction Data from providers of payment and delivery the Services that you use to pay us.
  • Technical Data from analytics providers such as Google Analytics.
  • Identity and Contact Data from third party agents, and online property portals such as Rightmove and Zoopla.

5. Disclosures of your Personal Data
We may share your personal data with the following third-parties:

• Service providers who help us run our organisations, such as service providers who provide IT and system administration systems.
• Professional advisers including lawyers, bankers, auditors and insurers based in the provide consultancy, banking, legal, insurance and accounting services.
• Reference and credit-check providers.
• Tax authorities 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 your personal data in the same way as set out in this privacy policy.

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

Service-specific third-party disclosures are further set out in the Using your personal data section of this Privacy Policy.

6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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.

7. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal data: please see your legal rights below for further information.

8. Data controller
The Paul Fosh Group company you interact with will be the data controller of your personal data. Where your personal data is shared across the Group, the other group companies will become a data controller of your personal data. This mostly applies to our own marketing efforts and other ways of collecting personal data as per this Privacy Policy.

9. Legal bases of processing
We will only use your personal data when data protection law allows us to. Most commonly, we process your personal data for the purposes described in this Privacy Policy, based on the following legal grounds:

• Where we need to perform the contract we are about to enter into or have entered into with you (such as providing services to you).
• Where it is necessary for our (or a third-party’s) legitimate interests, and they do not override your interests and fundamental rights. For example, improving our services to meet the needs of our clients.
• Where we need to comply with a legal obligation. For example, legal obligations sometimes require us to retain or share certain information about you.

10. Your Legal Rights
Under certain circumstances, you have the right to:

• Request access to your personal data (commonly known as a 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.
• 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.
• 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 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.

No fee usually required
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 could 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 could 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.

Complaints
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.

11. How to Contact us

We hope this Privacy Policy has been helpful in terms of how we use personal data and your rights in relation to such personal data. If you have any questions, please contact us:

• Email us at marketing@paulfoshauctions.com.
• Write to us at Paul Fosh Auctions, 108 Lower Dock Street, Newport, NP20 2AG.

Using your personal data

Purposes for which we will use your personal data – all services

We have set out below a description of all the ways we may share and use your personal data across the Group.

 

Paul Fosh Lettings
When you enter into a relationship with Paul Fosh Lettings, your personal data will further be processed in accordance with the information below. In many cases, this engagement begins at the point of first contact and may occur prior to entering into a contract.

Disclosures of your personal data

In addition to the disclosure of personal data in accordance with this Privacy Policy, when using the services provided by Paul Fosh Lettings we may have to share your personal data with third parties. This will be required to perform our contract with you, or to comply with our regulatory obligations.

Please see below the relevant third parties:

• The local authority & utilities in relation to an occupied property and any necessary updates on its occupation.
• Contractors in relation to any property repairs.
• Deposit scheme providers as required by law, currently (TDS) Tenancy Deposit Scheme and (DPS) Deposit Protection Service.

Appointed Subprocessors

 

Paul Fosh Auctions
When you enter into a relationship with Paul Fosh Auctions, your personal data will further be processed in accordance with the information below. In many cases, this engagement begins at the point of first contact and may occur prior to entering into a contract.

Disclosures of your personal data

In addition to the disclosure of personal data in accordance with this Privacy Policy, when using the services provided by Paul Fosh Auctions we may have to share your personal data with third parties. This will be required to perform our contract with you, or to comply with our regulatory obligations.

Appointed Subprocessors

 

YourBid
When you enter into a relationship with YourBid, your personal data will further be processed in accordance with the information below. In many cases, this engagement begins at the point of first contact and may occur prior to entering into a contract.

Disclosures of your personal data

In addition to the disclosure of personal data in accordance with this Privacy Policy, when using the services provided by YourBid we may have to share your personal data with third parties. This will be required to perform our contract with you, or to comply with our regulatory obligations.

Appointed Subprocessors

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