Privacy Policy

Introduction

This Privacy Notice describes the ways in which we collect, manage, store and dispose of data relating to individuals. We may amend or update it from time to time.  We encourage you to read this Privacy Notice.

Information you provide

You may provide us with personal contact information in several ways including sending a property enquiry, corresponding with us via email, completing a survey, entering a competition, completing a review, provide feedback or reporting an issue. We only store your personal data after you have consented by agreeing to our terms and conditions on the form. 

What Personal Information We Collect

For purposes of this Privacy Notice, “Personal Information” means any information that, by itself or in combination with other information, identifies, relates to, describes, references, is capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual, a device, or a household.  Personal Information does not include information that is anonymized, publicly available information from government records, deidentified or aggregated data subject information, information excluded from relevant data protection law by preemption by sector-specific privacy laws.  The Personal Information XSELL collects may include, but is not limited to: Contact Information, Applicant Information, Employment Information, Compliance Data, Client Service Data, Marketing Information, Technological Information, Special Categories of Personal Information, and Other Data. 

How and Why We Collect Personal Information

We collect Personal Information from many sources.  It may come directly from individuals (data subjects), indirectly from individuals (i.e. interactions with the website), or from clients, colleagues and publicly available sources. We automatically collect Meta data from your web browser limited to the type and version, the device make and model, your IP address, the referral domain, and the browser language setting. 

As a real estate company we regularly receive Personal Information in connection with the provision of our services and as part of our professional activities. For example, we may collect Personal Information:

• As part of our business intake procedures;

• When clients and prospective clients seek advice;

• When providing services to our clients 

• That is publicly available (e.g. social media);

• When it is required for the provision of services from our vendors;

• When individuals browse or interact with our website or use any of our online services, including registration details when you use, or register to use, any of our Sites, Apps, or services;

• From third parties who provide it to us;

• In carrying out our business, including records of interactions or correspondence with the Firm, including your attendance and participation at events or meetings we hold (including when we record such events or meetings, of which you will be provided notification, where applicable);

• In connection with any application for employment or interviews if you apply for a role with us and take part in an interview or selection process; and

• When individuals email us or provide Personal Information to us in other circumstances, such as requesting details about or attending and participating in a firm sponsored event or engaging with the alumni or careers portal.

We collect Personal Information, among other reasons, for:

1. Providing services and responding to requests for services;

2. Managing our business relationships, including billing, accounting, collection and support services;

3. Providing information relating to our services either in response to specific requests or generally to develop our business;

4. Processing employment applications;

5. Invoicing for our services and obtaining payment;

6. Responding to complaints;

7. Meeting our legal and regulatory obligations;

8. Making appropriate business development plans to better support our clients’ needs for  services;

9. Preventing, detecting and responding to fraud or potential fraud or other illegal activities;

10. Improving the functionality of our website and other IT services;

11. Leveraging communications data from our Exchange server, including Outlook, to maintain a repository of business contacts and run analytics on metadata which advance our business development initiatives; and

12. Processing employee data.

Ways in which we may share your personal information

We provide your given name, email and phone number to agents whenever you send a property enquiry. Once we have sent this data, the agents own privacy policy will apply to how they use it. We send information about your visit to analytics and search engine providers for the purposes of improving our services. This data includes IP the address, pages visited and browser type, but does not contain any direct personal identifiers such as name or email address. We may send your Meta Data to advertising networks for the purpose of serving relevant ads to you. If XSELL or its assets is acquired, the user data that we hold will be part of the transfer. If we obtain professional advice (e.g. from lawyers or financial advisors) we may disclose your personal information. We may disclose your personal information if we are required to do so by a government or regulatory authority. 

Ways in which we use your personal information

Fulfilling your requests such as forwarding property enquiries to agents or developers. Providing you with information on XSELL services that may interest you. Any marketing emails that we send you will have the option to unsubscribe. Enhancing your experience of our services e.g. ensuring content is presented in the most effective manner for your device. Delivering relevant advertising to you on our site or other sites operated by XSELL. Internal business administration e.g. data analysis, troubleshooting, testing and research. 

Whom We Disclose Personal Information To

We may retain other companies and individuals to perform functions on our behalf. Such third parties may be provided with access to Personal Information to perform the functions for which they have been retained. Our agreements with these third parties will describe the purpose of the processing, will not permit them to use Personal Information for any purposes other than as is required to perform the function for which they have been retained and will commit them to comply with applicable data privacy standards.  We also enter into data processing agreements and model clauses with our vendors and clients whenever required and appropriate. 

Third parties may include, but are not limited to: 

• Providers of data services such as website hosting, data hosting, and SaaS tools;

• Outsourced IT and Data Quality service providers;

• Financial institutions;

• Benefits and Human Resources service providers;

• Professional services providers;

• Building and facilities services;

• Shipping or direct mail organization;

• Event partners and sponsors;

• Paper-based service providers (i.e., storage, shredding, courier, printer, etc.);

• Parties assisting us in recruitment and staffing, including contractors;

• Our auditors and professional advisers;

• Our professional indemnity insurers;

• Travel service providers;

• Our clients, as it relates to our professional services offering;

• Other people in your organization; and

• Regulators and public bodies, including in connection with tax and VAT payments, compliance with obligations relating to the prevention and reporting of financial crime and compliance with other applicable laws.

We may also disclose any information, including Personal Information, as we deem necessary, in our sole discretion, to comply with a subpoena, any applicable law, regulation, legal process or governmental request

Storing your personal information

We may store your information on secure servers anywhere in the world. By submitting your personal information, you agree to this transfer, storing or processing. Wherever our servers are, we rely on approved data transfer mechanisms to ensure that your personal information is adequately safeguarded. Once you have sent us your data we use strict procedures to ensure that your data is secure, however we cannot guarantee its security. Any data that you send to us is sent at your own risk. Where you have a password to enable you to access some parts of our websites, you are responsible for keeping that password confidential. You must not share your password with anyone. 

How We Protect Personal Information

XSELL has appropriate physical, technical, and administrative safeguards in place designed to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from our website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please also read our Disclaimer before sending any information to us. Moreover, where you use passwords, ID numbers, or other special access features to access our website, it is your responsibility to safeguard them.

How Long We Retain Personal Information

Personal Information will be retained by XSELL for as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law. If you would like to delete your information from our servers you may request us to do so by contacting us 

Cookies

A “cookie” is an element of data that a website can send to your browser, which may then be stored on your system. XSELL uses different kinds of cookies on the Site. 

Do-Not-Track Signals

Your browser may allow you to send “do-not-track” requests to websites you visit. If you enable this feature and your browser sends a “do-not-track” request, the Site will respond by deactivating all nonessential cookies set on the Site.

Google Services

On the Site, XSELL uses several services provided by Google:

GOOGLE ANALYTICS

This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).

Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Please note that, for the Site, we activated the IP anonymization, i.e., Google will truncate/anonymize the last octet of your IP address to ensure an anonymized collection of IP addresses (IP Anonymization). In exceptional cases only, the full IP address is sent to and shortened by Google servers.

On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the Site, compiling analytics, demographics and interest reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in. 

Third Party Sites

Our Site may contain links to other third-party sites. When you click on one of these links you are visiting a website operated by someone other than XSELL, and the operator of that website may have a different privacy notice. XSELL is not responsible for their individual privacy practices. We encourage you to investigate the privacy notices of these third-party operators.

Contacting us

Any changes we may make to this Policy in the future will be posted on this page. If there are any questions regarding this privacy policy, you may contact us.