This website is the property of Castlereach Estate Agents Limited of Top Floor, 1 Olympic Way Wembley London HA9 0NP registered in England and Wales (registered number 07166682). Castlereach Estate Agents Ltd and its subsidiaries (“Ezytrac”, “we,” or “us”), our web site at https://www.castlereach.com (the “Site”), and all related web sites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this document is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the Site, our “Service”). If you disagree with any part of these terms and conditions, please do not use our website.
“Personal Data” means any information relating to an identified or identifiable natural person.“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.“User” means an employee, agent, or member of the public, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
- The content of the pages of this website is for your general information and use only. It is subject to change without notice.
- The information provided and the opinions expressed in this website represent the views of the authors and contributors. They do not constitute legal advice and cannot be construed as offering comprehensive guidance to the Data Protection Act 1998 or other statutory measures.
- Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. We are not liable for any inaccuracies or errors.
- Your use of any information or materials on this website is entirely at your own risk, it is your responsibility to check that the information available meets your requirements. Nothing on this website shall be regarded or taken as financial advice.
- This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics.
- Information on this site may be contributed by our members or other contributors (including in blogs). We do not control the information they provide and are not responsible for the views expressed.
- If you believe that your intellectual property rights have been infringed on this site please notify us. We accept no liability for infringements as a result of user-generated content but we will take reasonable action to remove such content where possible.
- Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
- The services provided by us are not available to those under 18 years of age.
- Every effort is made to keep the website up and running smoothly. However, we take no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.
- We reserve the right to refuse, suspend or cancel your access to the site at any time and without notice.
- Purchases of third-party education and training products or delegate places at events advertised on this site are subject to the terms and conditions of the providers.
- Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales and that any and all disputes arising therefrom shall be subject to the exclusive jurisdiction of the English courts.
- Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
This website and its content are copyright of Brett Alegre-Wood and our contributors. All rights reserved.
Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
- You may print extracts for your personal and non-commercial use only
- You may refer to and quote from the content for review or reference purposes within the limits of “fair dealing”, but only if you acknowledge the website as the source of the material
- You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
2.0 Anti-Money Laundering
We are committed to operating its business in a transparent and open manner consistent with our legal and regulatory obligations. We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity. We always seek to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to National Crime Agency.
As part of this commitment, we adopt a strict compliance of all applicable Anti Money Laundering rules, with specific emphasis on the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Bribery Act 2010 and the Terrorism Act 2000.
Our policy commitment is applicable to all our customers, including vendors, buyers, landlords and tenants. As a result we obtain and hold for a period of at least five years evidence pertaining to our customers’ identity and, where appropriate, we obtain proof of ownership of property and source/ destination of funds. We will be unable to proceed with any work on behalf of our customers if we are unable to obtain this information. Customers’ identity will be subject to an electronic identity check, which may also include a credit check.
We are registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017.
3.1 The Information We Collect on the Service:
Ezytrac processes your information under the following Lawful basis’s.
- Performance of a contract: where you enter into a contract with Castlereach and we need to process your information as part of this contract
- Legitimate interests: some information is processed by Castlereach as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications , profiling , direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller
- Public interest: some information is processed in accordance with public interest such as relocations
- Consent: where we process information under consent we will seek your clear and unambiguous consent prior to processing your data
3.1.1 User-provided Information. When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, and mobile phone number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.
3.1.2 “Automatically Collected” Information. When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs” or “web beacons.” This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
3.1.4 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
3.1.5 Types of Information Collected.
Castlereach collects the following basic initial information, usually through web-based sign up forms on our websites.
|First Name||Last Name||Phone|
3.2 How We Use the Information We Collect
We use the information we gather to contact you via Phone, Email, messaging platforms (such as Whatsapp, Messenger, WeChat), social media platforms (such as Facebook, Instagram, Linkedin, Twitter) This information allows you to login our site, communication with us, download educational material, register for events, and/or receive our property launches.
Generally, we will collect, use and hold your information for the purposes of:
- Assessing applications for and providing Castlereach products / services
- Conducting business, developing relationships with Castlereach and affiliates
- Process payments / transactions including: accounting, authorisation, clearing, chargebacks, auditing, billing, reconciliation, collection, complaints, enquiries, credit checks and related dispute resolution activities
- Protect against and prevent fraud, unauthorised transactions, money laundering (please see above), tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes
- Create and manage any accounts, associated authentication criteria (ID’s and passwords) you may have with Ezytrac
- Provide, administer and communicate with you about Ezytrac products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.
- Compile business directories, including business contact information
- Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
- Developing new products and services
- Managing communications, assess effectiveness and optimisation of advertising
- Functionality of our websites, mobile applications other digital assets
- Evaluate your interest in employment and contact you regarding possible employment opportunities
- Comply with industry standards and Ezytrac policies
You may opt-out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential unauthorised activities, Ezytrac engages profiling activities via direct use or anonymisation of sensitive personal information.
18.104.22.168 Direct Profiling
- Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.
- Background checks for existing and new employees, clients, business partners, affiliates
- Financial Viability analysis / reports
- Business partner / client portfolio position, performance, risk positions
- Anti-money laundering
- Tax reporting
- Credit defaulting / exposure
22.214.171.124 Indirect Profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:
- Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.
- Compiling and communicating promotional and marketing information about products and services that Ezytrac Group, affiliates and other organisations that we have affiliations with have and that may be of interest to you.
- Conducting market research
- Facilitating our internal business operations, including the fulfilment of any legal requirements.
3.3 Information We Share
- Local Letting Agencies for the purpose of securing a tenant.
- Our panel affiliates and partners / Financial Institutions / Insurance Companies / Surveyors for business facilitation to provide required services, such as mortgages, conveyance, insurance cover etc.
- Companies within the Group structure
- Formally contracted service providers to perform services on our behalf. For example for the maintenance of your property, Gas and Energy Certificates, Property Inspections.
- Hosting Data centres and software providers, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
- Councils, health and care providers
- Utility companies
- Law firms
- Referencing and Credit agencies
- Government Agencies such as HMRC in the case of Non-Resident Landlords.
- Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
- Prospective employers requesting references via your written consent.
On websites, features can be accessed where we partner with other entities that are not affiliated with Castlereach. These include messaging, social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features.
3.3.2 Service Providers
We work with third-party service providers who provide website, software, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
3.3.3 Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government summons or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
3.3.4 Change of Ownership
3.4 Your Choices
3.4.1 Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Castlereach’s Data Protection Officer at email@example.com. You also have a right to lodge a complaint with data protection authorities.
3.4.2 Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the “Subscription Preferences” tab on the Service, or through the bottom of each email received.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
3.4.3 Amending and Deleting of your Data
If the User requests Castlereach to remove the data, we will respond to their request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Personal Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for us to identify the User or third party and the information to delete or amend.
3.5 Third-Party Services
The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
3.6 Sharing your Data for Direct Marketing
We will not share any Personal Data with third-parties for their direct marketing purposes. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
3.7 Interest-Based Advertising
Interest-based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smartphone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the Castlereach products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviours of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest-based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.
3.8 Third Party Cookies & Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
3.8.1 The Following Types of Cookies Are Used in the Site:
- strictly necessary/essential cookies – These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services, you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
- performance cookies – These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- functionality cookies – These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- behaviourally targeted advertising cookies – These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
3.9 Minors and Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at Privacy@castlereach.com and request that we delete that child’s Personal Data from our systems.
If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
3.10 How We Protect Personal Information
The security of your personal information is very important and Castlereach is committed to protecting the information we collect. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymise Personal Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping the password confidential. Please notify us immediately if you suspect that your password is no longer secure.
3.11 Data Retention
We will keep information for a reasonable amount of time in order to perform the purposes listed above. We only keep your information for as long as necessary.
- Google Analytics data is retained for 26 months.
- Billing information is retained for a period of 6 years as of their provision to Castlereach in accordance with the United Kingdom accounting and taxation laws.
- Information on legal transactions between Clients and Castlereach is retained for a period of 6 years.
- Information on employees are retained for a period of 6 years.
Castlereach reserves the right to keep information for longer if we feel that this is in the legitimate interests of Castlereach.
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
3.13 Data Transfer
The Service is hosted in the United Kingdom. Users Data including Personal Data will be hosted in Castlereach’s EU datacenter located in London, United Kingdom. Regardless of the database being hosted in the EU, if you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from EU law. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services.
3.14 Data Controller and Data Processor
Castlereach does collect and determine the use of any Personal Data and because it does determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Castlereach is acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and does have the associated responsibilities under the GDPR.
3.15 How to Contact Us
If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices. If you have any concerns or complaints about this Policy or your Personal Data, you may contact Castlereach’s Data Protection Officer by email at firstname.lastname@example.org.
Or write to us at:
Brett Alegre-Wood, Group Data Protection Officer, Suite 8 The Regatta, Henley Way Lincoln United Kingdom LN6 3QR.
To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.
If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
Last update: May 1, 2018