RIGHTMOVE GROUP LIMITED

MOBILE APP PRIVACY POLICY 2019

WHO WE ARE

We are Rightmove Group Limited (company number 03997679) and our address is Building 2, Caldecotte Lake Business Park, Milton Keynes, MK7 8LE (referred to as "we" or "us" or "our"). We are the providers of the Rightmove mobile application software (referred to as the "App") and the website www.rightmove.co.uk (referred to as the "Site"). Our VAT number is 918501823.

We provide this App so that our members can upload property details for you to view. "Our members" include: estate agents, commercial agents, letting agents, landlords, new homes developers and overseas property owners. We are not an estate agency.

A reference to "you" or "your" is a reference to a user of the App or any of our services.

INTRODUCTION

We are committed to protecting your privacy. This privacy policy (referred to as the "Policy") explains how and for what purposes we use the information collected about you when you download and use our App on your mobile device ("Device"). Please read this Policy carefully.

If you have a query about information relating to your property on the App, please contact your estate agent or lettings agent directly or alternatively contact us on talk-to-us@rightmove.co.uk.

CONTACTING US

If you would like to stop receiving marketing and communications from us please contact us via email at talk-to-us@rightmove.co.uk or please write to the Customer Services Team, Building 2, Caldecotte Lake Business Park, Milton Keynes, MK7 8LE.

If you have any questions about this Policy or our use of your personal information or would like to submit a subject access request or exercise your other data subject rights, please contact our Data Protection Officer via email at dpo@rightmove.co.uk or please write to The Data Protection Officer, Building 2, Caldecotte Lake Business Park, Milton Keynes, MK7 8LE.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

PROPERTIES ADVERTISED ON THE SITE
What we collect and where it comes from
  • In the course of providing our services, we collect property data such as images of properties, property asking prices, sales history and sold prices, property addresses, property locations and property descriptions.
  • The property data is provided to us by our members or other third parties on behalf of those members.
Why we collect it
  • We will use this information for a number of reasons including:
    • to provide the Rightmove App;
    • to enable our members to advertise their properties to the largest online audience available;
    • to enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in;
    • to allow users to see current property trends such as the prices of houses for sale in their local area; and
    • for our own commercial purposes such as to identify trends in the property market, automated survey and valuation tools, and to build property databases.
Our lawful basis for processing this personal data
  • We have a legitimate interest to process this information. These legitimate interests are:
    • providing a service to our members by helping them to market properties;
    • providing a service to our members by advertising properties to potential purchasers or tenants;
    • providing a service to potential purchasers and tenants so that they know what properties are currently on the market and the price of those properties; and
    • to provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.
How long we will keep it for
  • We will stop advertising a property when we are instructed to do so by our members.
  • However, the property information will remain available on the App as historical property information to allow users to benefit from services such as identifying previous for sale or sold prices (please see the historical property data section below for further information).
HISTORICAL PROPERTY DATA
What we collect and where it comes from
  • If a property has previously been actively marketed on the App, we will continue to display it on the App as historical property information. If you have any concerns about any historical property information available on the App, please see the section of this Policy entitled "Removing Property Data from the App" (below).
  • We also have data that relates to historical property listings on the App which we collect from other third parties. For example, we obtain the sold prices of the properties from the Land Registry (or the Land Register of Scotland) and display those sold prices on the App.
Why we collect it
  • We will use this information:
    • to assist potential purchasers and tenants when forming a view about historical market trends and potential property values;
    • to assist vendors when researching the approximate value of their property;
    • to enable users to see detailed property descriptions and images of properties in areas that they may be interested in;
    • to allow users to see property trends that they may be interested in, such as the previous sale and sold prices of houses in their local area; and
    • for our other commercial purposes, such as to identify trends in the property market and automated survey and valuation tools, and to build property databases.
Our lawful basis for processing this personal data
  • We have a legitimate interest to process this information. These legitimate interests are:
    • to enhance the service that we provide on the App and providing a service that benefits our members, App users, vendors, landlords, potential purchasers and tenants;
    • to provide a service to our members by assisting them to more accurately value other properties;
    • to provide a service to vendors and landlords to form a view about the value of their properties;
    • providing a service to potential purchasers and tenants in understanding what properties have been on the market and the prices of those properties; and
    • to provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this historic property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.
How long we will keep it for
  • To the extent that property data is also personal data, it is generally the case that it ceases to be personal data over time. The historic property data is retained by us in accordance with our property database and remains necessary in order for us to provide the services summarised in the "why we collect it" box. If you have concerns about historical property information featured on our App and you can prove to us that you have a valid association to the property you are concerned about, please contact us at sold.prices@rightmove.co.uk
INFORMATION YOU GIVE TO US
What we collect and where it comes from
  • We will collect the information that you give to us when using our App or services:
      • Enquiries to our members:
    • if you choose to access a particular search feature or to fill in a form on the App you may be asked to provide information about yourself, such as:
      • your name and contact details
      • details of the sort of property you are interested in
      • the cost and location of the property, and
      • your current residential address
    • If you choose to book an appointment to view a property on the App, you may be asked to provide more details, including:
      • your availability to view the property
      • your preferred moving date
      • details of your household income as a proxy for calculating affordability in relation to the advertised monthly rental value of a property
      • an indication of whether you are moving alone or with others, and
      • your feedback on a property that you have viewed,
    • if you choose to contact us or a member using the member telephone number on the App, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.
      • Registered Users and Property Alerts:
    • information that you provide to us when you register as a Rightmove user and/or request property email updates such as Property Alerts about when a property is placed on the market in your chosen postcode and meeting your search parameters;
      • General App Use:
    • information that you provide when downloading the App or registering to use the App;
    • information that you provide when participating in discussion boards or other social media functions on our App and enter into competitions, promotions or surveys available on the App; and
      • Communications:
    • information that you provide to us by corresponding with us by phone, e-mail or otherwise
Why we collect it
  • We will use this information:
      • Enquiries to our members:
    • to make sure that you receive the benefit of the Rightmove service. This may include:
      • transferring your property enquiry to our member advertising that property so that they can respond to your enquiry. Some of our members may use lead handling agencies who handle and process your enquiry on their behalf; or
      • sending your request to book a property viewing to our member advertising that property and for us to confirm your booking by email or text on our member's behalf;
      • transferring other relevant information to our member so that they can assess whether the property is suitable for you; and
      • allowing you to provide our member with feedback on the property once you have viewed it;
    • for training and monitoring purposes where calls are recorded;
    • to profile your lead activity on our App or telephone calls to our Members to enhance the service you receive from our Members. If you want to know more about this, see "Lead Profiling" below
      • Registered Users and Property Alerts:
    • to provide you with the benefit of services for registered users only;
    • to provide Property Alerts to you of new and reduced properties, or properties you may have missed that are marketed on our App that meet your search criteria;
      • General App Use:
    • to provide the App to you and to enable you to download the App;
    • to enhance the services that you select on our App;
    • to process any queries that you have about Rightmove or its members;
    • to customise and enrich your experience on our App;
    • to contact you for your views on our services and to notify you occasionally about important changes to our Terms of Use or this Policy or developments to this App or our services;
    • to deliver relevant advertising to you whilst you are on the App; and
      • Communications:
    • to process and resolve any queries that you may have.
Our lawful basis for processing this personal data
  • We have a legitimate interest to process this information. These legitimate interests are:
      • Enquiries to our members:
    • to provide a service to our members and/ or to provide a service to you;
      • Registered User and Property Alerts:
    • to provide you with our services;
      • General App Use:
    • to gain information about the use of our App and any improvements that can be made as well as providing advertising space to our members and third parties;
    • and to enable you to download and use the App; and
      • Communications:
    • to ensure that your queries are addressed.
How long we will keep it for
  • We will store the information summarised above for the following periods:
      • Enquiries to our members:
    • all enquiry data will be kept for two years from the date on which you last used our App or our services. After that it will be erased or anonymised so that the data no longer identifies you.
    • Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted.
    • profiling data will be kept for a shorter time period, as described in "Lead Profiling" below.
      • Registered Users and Property Alerts:
    • information that you provide to us when you register as a Rightmove user will be kept for as long as you have an account setup on Rightmove. The personal data relating to your account will be deleted when you delete your account.
      • General App Use:
    • information that you provide when downloading the App, registering to use the App or for accessing in-App services will be retained for as long as you have the App installed on your device.
    • information that you provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years.
    • information that is provided when you interact with us through social media functions will only be retained on the social media platforms which you use to contact us. We will not copy or store it separately. This data will be retained for as long as you keep it on your social media accounts.
      • Communications:
    • information that you provide to us by corresponding with us by phone, e-mail or otherwise will be retained for the later of 18 months from the date of communication or until your query is resolved.
INFORMATION WE RECEIVE FROM THIRD PARTIES (OTHER THAN OUR MEMBERS)
What we collect and where it comes from
  • We may receive information about you if you use any of the other websites we operate or the other services we provide via the App. In this case we will have informed you, when we collected the data, that it may be shared internally and combined with data collected on this App.
Why we collect it
  • We will use your information:
    • to allow you to participate in the interactive services available on our App or to participate in competitions or promotions via our App;
    • to pass your searches and messages on to our members to help them communicate with you directly and to provide a more personalised service to you. This may include contacting you about other relevant properties, adding you to their enquiry database for future contact and offering you their additional services;
    • to provide services and information to our members, which they can use to benchmark their performance;
    • to customise and enrich your experience on our App; and
    • to contact you for your views on our services and to notify you occasionally about important changes to our Terms of Use or this Policy or developments to this App or our services.
Our lawful basis for processing this personal data
  • We have a legitimate business interest to process this information. These legitimate interests are:
    • enhancing the service that you receive on the App;
    • to provide a service to our members so they can respond to enquiries; and
    • providing information necessary to enable us to provide a competitive, cost effective services.
How long we will keep it for
  • We will store this personal data for two years from the date on which you last used our App or services at which point it will be erased or anonymised so that the data no longer identifies you.
INFORMATION WE COLLECT ABOUT YOU
What we collect and where it comes from
  • This is different to "information you give us" because it relates to technical data that we collect. We may:
    • Collect technical information, including the type of Device you use, a unique identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting;
    • details of your use of our App or your visits to our Site via the App, the resources that you access and the advertisers and partners that you contact;
    • use GPS technology on your Device to determine your current location. Some of our location-enabled services require your personal data for the feature to work; and
    • set a unique application number which is contained within the App. When you install or uninstall the App or when the App searches for automatic updates, that number and information about your installation, for example, and the type of operating system, may be sent to us.
    • we may combine technical information with other information that we have about you to help us with our processing of your information as set out in this Policy.
Why we collect it
  • We will use the information summarised above:
    • to provide the App to you;
    • to conduct reviews that assist us in the improvement and optimisation of our App;
    • to ensure that content from our App is presented in the most effective manner for you and for your device;
    • to administer our App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • as part of our efforts to keep our App safe and secure;
    • to customise and enrich your experience on our App;
    • to provide you with GPS enabled functionality; and
    • to identify what versions of the App are being used or when the App is uninstalled from a device
Our lawful basis for processing this personal data
  • We have a legitimate interest to process this information. These legitimate interests are:
    • to help ensure the on-going security of the App;
    • enhancing the service that you receive on the App; and
    • providing information necessary to enable us to provide a competitive, cost effective services.
  • If you wish to use a location data service which engages your Device's GPS tracker, you will be asked to consent to your data being used for this purpose upon registering to use the App. You can withdraw your consent at any time by turning off the location services settings for the App on your Device.
How long we will keep it for
  • We will store this personal data for two years in order to allow us to review and monitor normal traffic patterns and trends on App.
  • We will store the unique application number for as long as the App is installed.

LEAD PROFILING

We may from time to time profile your activity when using our services or our App. This profiling is limited in its scope to telephone and email enquiries you send to our members. It only takes place to help us and our members understand what sort of properties you may be interested in and to categorise your activity to help us and our members determine how likely you are to require services from our members. Members may then contact you to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing your personal data). You can always object to our profiling by emailing us here dpo@rightmove.co.uk Any profiling data that we hold about you will only be kept for a period of 12 months from the date of the last telephone or email you have sent to a Rightmove member.

USE OF YOUR DATA FOR MARKETING AND COMMUNICATIONS

Sometimes we may use your personal information to provide marketing messages to you. You can opt out of marketing and other communications at any time by contacting talk-to-us@rightmove.co.uk. You can always make use of the App without having to agree to marketing. The types of things that we may do include:

REMOVING PROPERTY DATA FROM THE SITE

If you have any concerns about the property data on the App, please contact us at dataquality@rightmove.co.uk and we will endeavour to resolve the issue promptly.

If you are a vendor or landlord of a property that is being actively marketed on the App, please contact your estate agent or lettings agent directly.

If you have concerns about historical property information about a property featured on our App and you can prove to us that you have a valid association to that property, please contact us at sold.prices@rightmove.co.uk.

WHO HAS ACCESS TO YOUR PERSONAL DATA?

We retain access to all personal information that we have collected from you or about you. Once your information has been passed to one of our members in the course of providing our services (most typically when you communicate with an estate agent through our App) then that Rightmove member will have a copy of the information that you have provided within your enquiry and your contact details which they will use to get in touch with you. In relation to property data, it is provided to us by our members (or third parties that act on their behalf). Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of your information by any of our members.

When our service is available via the websites of our partners, those partners may have access to your information. We may also have links to other websites from our App. We are not responsible for the content, security, privacy policies and practices of any other websites, even if you access them using links from this App or if you can access this App or use our services from them. We recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.

If our business is sold or merged, or if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your information to them in order to deliver the service. The categories of third parties (who are acting as a data processors) include: telephone call recording and our support ticketing systems. We may also use third parties to provide services on our behalf which may include processing (but not using themselves) your information e.g. to complete partial addresses or to augment the information we hold about you. In either case, we will not pass your information to anyone who is not also subject to adequate privacy commitments in our contract with them.

We will not otherwise disclose, sell or distribute your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.

WHERE DO WE STORE YOUR PERSONAL DATA?

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data at any time.

You have the right to use our App without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We always use the most recently submitted form to be your current consent status. If you are a registered user, but not signed in when you submit a form, we will not be able to use your saved settings so will deem your consent choice to be as per the form you submit at the time. You can exercise your right to prevent such processing by selecting the specific options in the fields or forms when you become a registered user.

You have a right to request access to or rectification of your personal data which we hold about you. You also have a right to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us, the right to object to our processing of your personal data and a right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this policy.

You have the right to complain to the Information Commissioner's Office if you feel unhappy with the way we process your data. Please visit www.ico.org.uk for more information.

COOKIES AND TRACKING

Like many app providers, we use "cookies" to enable us to personalise your visits to our App, simplify the signing-in procedure, keep track of your preferences and to track the usage of our App. For full details about what cookies we set and why we use them, please see our Cookie Policy available here.

CHANGES TO THIS POLICY

We may change the terms of this Policy at any time. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App; please check back frequently to take notice of any changes that we have made, as you will be deemed to accept such changes from your continued use of the App.