Information covered by this statement
This Privacy Statement applies to the use and processing of personal information collected and used by the Complete Group.
Personal information is information, or any combination of separate pieces of information, that could be used to identify you.
Should you have any queries in respect of this statement or our use of personal data, please contact Complete Protection Officer – at email@example.com
If you are resident in the EU and require a EU based representative then please contact our office in Germany by contacting firstname.lastname@example.org
Information Complete collects
We may collect information about you from a variety of sources. This includes information we collect directly from you; information we collect when you visit our sites, view our online content or use our mobile applications or other services; and information we collect about you from other sources.
Information we collect directly from you
We collect information directly from you when you choose to participate in our offers and programs, create an account on our websites or in our mobile applications, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:
- Email address
- Postal address
- Username and password
- Telephone and/or fax number
- Date of birth
- Demographic information
- Payment information (such as a credit card) and bank account details
- Future communication preferences
- Telephone number and recordings when you call our customer service line
- Income level.
- Publicly observed activities or information made available by you to the public, such as blogs, videos, internet postings, and user generated content.
How Complete uses this information
We use the information we collect to provide you products, offers and services, to deliver to you advertisements, offers or other content tailored to your interests, and to conduct other Complete business operations. The following are examples of how we may use the information we collect:
- Answer your questions or respond to your requests.
- Develop new products and services.
- Enrol you in contests, programs, or offers that you request.
- Create and manage your account.
- Process payment for purchases or other services.
- Protect against or identify possible fraudulent transactions.
- Send you email and/or postal messages with information about Complete brands and other content we think may be of interest to you.
- Telephone you about Complete’s brands and other content we think may be of interest to you.
- Develop and provide Marketing tailored to your interests, including interest-based marketing.
- Personalise your experience on our websites by presenting products and information tailored to you.
- Allow you to participate in social sharing on our websites.
- Analyse the use of, and develop, our products, services and marketing. Enforce our Terms and Conditions and otherwise manage our business.
Complete will only process your information in pursuance of our legitimate interest if we receive any requests related to, for example, a product or service, a call-back, or specific marketing materials; we will use your personal information to fulfil your request. Where we need to manage your account and protect you against or identify possible fraudulent transactions, we will do so in accordance with our legal obligation placed on us under law. We will seek consent from you if we need to process your data solely identified purposes. To ensure meaningful consent is obtained from you, Complete will provide you with reasonable notice ensuring that your consent is provided on an informed basis.
The success of our business depends on your trust, and we do not sell your personal information to marketers outside of Complete. We share your personal information within Complete and as described in this statement. We do not share personal information with marketers outside of Complete unless you consent to such sharing, or as described within this statement.
Third-party service providers
We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your personal information with them. We provide our service providers with only the personal information they need in order to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.
For example, we may rely on a 3rd party service provider to:
- Fulfil your service requests and answer your questions such as maintenance and repairs requests.
- Host our sites and deliver our email or other communications.
- Contact contest winners, manage payments or take other actions on our behalf.
- Analyse our data, sometimes combined with data from other sources, to send you communications.
- Conduct research and analyse data to improve our products, services and sites.
- Perform other services that we request.
Where permitted by law, we combine personal information about you that Complete has collected with personal information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use Complete data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Statement as indicated above.
A list of third party suppliers is available on request.
Anti Money Laundering Checks for Buyers and Vendors
We use a third-party supplier, Thirdfort to carry out checks on the identity of buyers and vendors in order to satisfy anti-money laundering requirements. Thirdfort only temporarily stores your data while completing the AML checks. It’s all permanently deleted from their systems once the check has been completed. Most of your data gets stored locally on your phone, which only you can access. Thirdfort will keep your number for two years so you can access the app again if you need to, if you’d prefer Thirdfort didn’t do this, you can request a data deletion. A record of the search will be retained by Complete for 6 years to comply with our Anti- Money Laundering obligations. Complete are not permitted to market a property for sale or submit an offer to purchase a property until due diligence has been performed on vendors/ buyers.
Change of Occupier Notifications
Complete as The Agent has a data processing agreement in place with a Third-Party supplier to manage change of occupancy notifications on its behalf. This supplier is Ethical Introductions Limited (t/a Just Move In). All tenants will receive at no extra charge concierge services which comprise of change of occupation notifications for council tax and utilities, as well as setting up optional services such as broadband, TV, phone, insurance, and/or where requested other moving-related needs such as insurance, cleaning, storage and removals (“Concierge Services”).
Repairs and Maintenance Requests
Complete partners with a company called Fixflo which facilitates the simple reporting of repairs through to Complete to enable efficient diagnosis of repairs request and reporting through to our contractors to enable maintenance issues to be resolved as quickly as possible in line with our landlord’s repairing obligations. Fixflo is a third party provider and they will solely use Complete’s landlord and tenant data in line with our agreement with them to facilitate repairs.
The legal basis under which Complete as The Agent and the supplier process the Landlord’s data and provide it to the relevant parties for this purpose is that it is necessary for the legitimate interests of the Landlord and Tenant i.e. to maintain their property. Fixflo will receive and is also a controller of users’ Personal Data necessary for the provision of the repairs Services, and will retain the Personal Data for a period of 6 years from completion of the relevant transaction (being completion of a repair request).
Complete are able to take debit and credit card payments through a secure online transaction process via a third party, the online system ensures that the relevant card payment data is securely processed and stored via approved payment service providers. STRIPE is the approved provider and the system is PCI-DSS compliant and should be used for all such payments.
We may transfer or otherwise process your personal information:
- As part of the sale of a Complete brand to another company.
- When we have received your instruction to pass the sale of your property to another agent
- To protect, defend or exercise the rights and property of Complete (including enforcing our Terms and Conditions).
- When required by law and/or government authorities.
Personal Information Retention Period
We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.
Aggregated and non-personal information.
We share aggregated and/or anonymous information that does not identify you for Complete business purposes. For example, we may disclose the number of visitors to Complete sites or services. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.
Your communication options
We give you choices about how we communicate with you.
You can stop receiving promotional email messages from Complete by following the opt-out instructions provided in any such message you receive.
Mobile Text Messages
We only send you mobile text messages if you explicitly ask to receive these (you opt in). You can stop receiving promotional text messages by following the instructions to opt out provided within that text messaging program.
We will only call you regarding properties that might be of interest to you if you give us your permission.
You and your information
To the extent provided for by applicable law, you have certain rights in respect of the management of the personal data we hold about you.
We take steps to keep your personal information accurate. Many Complete programs provide access to view or update personal information you provided when you registered online. Check where you registered to learn if you can view or update your information there. Complete does not charge for this service and responds to reasonable requests in an appropriate timeframe.
If you wish us to delete your personal data from our software system then please let us know and we will arrange deletion within 1 month of the request.
To the extent provided by applicable law, you have the right to request rectification of your personal data; to obtain restriction of the processing of personal data; to object to the processing of personal data (including direct marketing) and to data portability. To exercise any of these rights, please contact us as described below.
Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by contacting us as described below. We will cease processing your personal data as soon as reasonably practicable following our receipt of your withdrawal.
If you consider that we have processed personal data in violation of applicable law, please contact us as described below. If you consider that we have processed personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a supervisory authority (e.g. the Information Commissioner in the UK).
We may use third-party web analytics services on our Sites, such as those of Google Analytics and Bing. These service providers help us analyse how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about Google Analytics, and how to opt out, please click here.
The providers of third-party plug-ins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plug-ins and widgets. We may also receive information you have made available to those third party services, including the geographic location of your mobile device and other information about you (such as name, email address, gender, locale, time zone, languages, social media profile URL, personal website URL, biographical information, birthday, photo, list of devices, education history, work history, hometown, interests, current city, political views, favourite athlete and teams, relationship status and information, religion, name of significant other, and certain security settings information) and your contacts on those services. This information is subject to the privacy policies or notices of the third party providers of the plug-ins and widgets.
Links to Third Party Sites and Social Media
Complete sites may include links to third-party sites. Complete does not control these third-party sites, and we encourage you to read the privacy statement of every site you visit.
Social Networks and Third-Party Plug-ins
Our websites may include plugins from social networks or other third parties. An example of a plugin is the Facebook “Like” button. Where legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plugin. This information may include your IP address, information about your browser and device, and the address of the web page you are visiting on our site. Loading, using or clicking the plugins may also place, read and transmit cookies. These cookies may contain a unique identifier the social network or third party assigns to you. The loading, functionality and your use of the plugins are governed by the privacy statement and terms of the party that provided the plugin.
Social Network and Third-Party Login
Our websites may allow you to log in using a social network or other third-party account. An example of a third-party login is “Log in with Facebook.” Logging into one of our sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party. The login feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. The social network or third party may also automatically collect information such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. The login feature may also place and read cookies from that third party that may contain a unique identifier the social network or other third party assigns to you. The functionality of and your use of the login is governed by the privacy statement and terms of the party that provided the login functionality.
User Generated Content
Please remember that any information you submit or post as user-generated content to Social Media sites become public information. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. Complete cannot prevent others from using such information in a manner that may violate this Privacy Statement, the law, or your personal privacy and safety. Complete is not responsible for the results of such postings.
Complete is committed to keeping personal information secure. We have implemented technical, administrative and physical procedures designed to protect personal information from loss, misuse or alteration.
All personal information are only accessible to restricted number to those who have a business need. We keep personal information only for so long as deemed reasonably necessary.
How long we’ll keep your information
We keep your information in line with our data retention policy. For example, we’ll normally keep your core data for a period of seven years from the end of our relationship with you if you have transacted for any Lettings and/or Management services. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes, such as managing your account and dealing with any disputes or concerns that may arise. We may need to retain your information for a longer period, where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate. If we don’t need to retain information for this period of time, we may destroy, delete it more promptly.
You have a number of rights in relation to the information that we hold about you. These rights include:
- the right to access information we hold about you and to obtain information about how we process it;
- in some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and / or request that we transmit it to a third party;
- the right to request that we rectify your information if it’s inaccurate or incomplete;
- in some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
- the right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information, but we’re entitled to continue processing your information and/or to refuse that request.
You can exercise your rights by contacting us using the email “email@example.com”. You also have a right to complain to the data protection regulator in the country where you live or work. For United Kingdom this is the information commissioner’s Office, which you can contact by visiting https://ico.org.uk
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Statement.
We have implemented a General Data Transfer Agreement, procedures and controls to help ensure that personal information is protected no matter what country it is stored in or transferred to.
Our Sites are not directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on our Sites.
Links to other websites and apps
Our Sites may provide links to other websites and apps for your convenience and information. These websites and apps may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
Updates to our Privacy Statement
We will post changes to this Privacy Statement and indicate the effective date when this Privacy Statement is updated. If we make any material changes to this Privacy Statement, we will notify you by sending an e-mail to the e-mail address you most recently provided us or by posting notice of the changes on this site.