ZUMP LIMITED PRIVACY NOTICE
This privacy notice explains what personal information we collect when you sign up to the Zump Platform. It also explains how we will store and use that personal information, how we keep it safe and what rights you have over it.
SUMMARY OF HOW WE USE YOUR PERSONAL INFORMATION:
1. Introduction
This Privacy Policy has been prepared in accordance with the Data Protection Act 2018 which implements the General Data Protection Regulation (or such UK legislation intended to replace or supersede it) (“Data Privacy Laws”). Defined terms used in the Privacy Policy have the meanings set out in the Data Privacy Laws.
This summarises how we use your personal information when you sign up to become a user of our app (the “Platform”) in connection with the purchase or sale (as applicable) of a property featured on the Platform.
2. Who Are We?
We are Zump Limited, a company incorporated in England and Wales with company number 12036039 and registered offices at 1 & 2 The Barn, Oldwick West Stoke Road, Lavant, Chichester, West Sussex PO18 9AA. We are the controller in relation to your personal information. If you would like any information about how we handle your personal information or have any questions or concerns about the information in this notice you should contact daniel.gray@zump.me.
3. What information do we collect, store and use and how do we use it?
Depending on whether you are buying or selling a property, when you register to become a user of the Platform, we ask you to provide some or all of the following details:
- Full name
- Full property address (this will only be displayed in full if you wish it to – see below for further information)
- Telephone number
- Email address - A copy of your driving licence (only if you wish to set up a profile)
- A profile photo (only if you wish to set up a profile)
4. Legal Grounds for collecting, storing and using your information
Under Data Privacy Laws we need to have a legal basis for collecting, storing and using your personal information. Please see the detailed summary below for an explanation of this.
5. Automated Decision Making
We may use automated decision making to send your details to our exclusive agency partner, Nexa Properties. Please see the detailed summary below for more information.
6. Who do we share information with?
We may share your information internally and also from time to time, externally. Please see the detailed section below for more information on who we share your personal data with.
7. International Transfers
We will not transfer your personal data outside of the EEA at any time.
8. How long do we keep personal information?
We keep information relating to you for the period in which you remain a user of the Platform and for 2 years following the date on which you cease to be a Platform user.
9. Withdrawing consent and rights over personal information
You have rights over your personal information such as the ability to ask for access to it, to have it corrected or to have it deleted. Please see the detailed section below for a full explanation of your rights.
10. Who can you contact if you have a question or complaint?
You have the right to make a complaint at any time to the UK regulator for data protection issues, the ICO (see www.ico.org.uk). We would like to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact our daniel.gray@zump.me.
DETAILED PRIVACY NOTICE
WHO ARE WE?
"We", "our" or "us" means Zump Limited. Our company number is 12036039. Our registered office is at 1 & 2 The Barn, Oldwick West Stoke Road, Lavant, Chichester, West Sussex PO18 9AA.
We are the controller of your personal information. This privacy notice provides information about what personal information we collect, store and use when you sign up to become a user of the Zump app (the “Platform”) in connection with the purchase or sale (as applicable) of a property featured on the Platform (the “Services”). This privacy notice also tells you what your rights are over your personal information and how to exercise those rights.
If you have any questions or concerns about the information in this notice, or about our handling of personal information more generally, or if you would like more detailed information on a particular point, you should contact daniel.gray@zump.me.
SELLERS ONLY - HOW WE USE YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR THAT
1. What personal information do we collect and how do we use it?
Information you give us: If you choose to become a user of the Platform, we will collect information from you, such as your name, email address, telephone number and the residential property address of the property you are selling. We will use this information to:
• Notify you (by way of sending you “Zumps”) when we match your search criteria with a prospective buyer; and
• Provide the Services to you via the Platform.
2. What is our legal basis for using your personal information?
Our legal basis for using the personal information above is that it is in our legitimate interests. Under Data Privacy Laws we must have a legal basis to use your personal information. We have set these out below.
Type of personal data
Legal basis relied on to process personal data
Name, email address, telephone number
The legitimate interest of Zump providing services to users via the Platform.
Full residential property address
The legitimate interest of Zump featuring properties on the Platform advertised to its customers.
We believe that use of your personal information for the purpose outlined above is a proportionate use of your personal information as we require your details in order to advertise properties on the Platform and in turn provide the Services and to be able to contact you with details of prospective buyers for your property. We consider that this is a proportionate use of your personal information because it is something we think you would expect us to do.
BUYERS ONLY - HOW WE USE YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR THAT
1. What personal information do we collect and how do we use it?
Information you give us: If you chose to become a user of the Platform, we will collect information from you, such as your name, email address, telephone number and the residential property address of the property you are selling. We will use this information to:
• Notify you (by way of sending, “Zumps”) when we match your search criteria with a property; and
• Provide the Services to you.
As a property purchaser, you will also be given the opportunity to create a user profile. In order to create a profile, you will be asked to upload a photo of yourself. If you chose, your profile picture may be publicly displayed on the Platform, viewable by other Platform users.
We may also ask you to provide a copy of your personal ID, such as a driving licence. This is a security measure to enable us to seek redress should you breach any of the terms set out in our Platform Terms and Conditions.
2. What is our legal basis for using your personal information?
Under Data Privacy Laws we must have a legal basis to use your personal information. We have set these out below.
Type of personal data
Legal basis relied on to process personal data
Name, email address, telephone number
The legitimate interests of Zump providing the Services to users via the Platform.
Profile photo
The legitimate interests of Zump offering the profile feature functionality to users to display further details about themselves as part of the wider Services.
Copy of personal ID
The legitimate interests of Zump protecting its business and implementing security measures to prevent breach of the Platform terms of use.
Our legal basis for using the personal information above is that it is in our legitimate interests. We believe that this is a proportionate use of your personal information as we require your details in order to match your search criteria with properties on the Platform and in turn provide the Services and to be able to contact you from time to time. We consider that this is a proportionate use of your personal information because it is something we think you would expect us to do.
INFORMATION THAT APPLIES TO BOTH SELLERS AND BUYERS
CAN WE CHANGE THE PURPOSE FOR WHICH WE USE YOUR PERSONAL INFORMATION?
We will only use your personal information for the purpose we have set out above unless another purpose we want to use it for is compatible. If we change the purpose for which we are using your personal information and you would like an explanation as to how the new purpose is compatible with the original purpose please contact. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to do so in a similar way to how we have done it in this notice.
WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?
If you don’t provide the personal information where we need it in relation to a contract with you then, we may not be able to contact you in relation to a contract we have entered into with you. Where we process your personal information on consent you have the right to withdraw your consent at any time. If you have any concerns about whether you need to provide the personal information please contact daniel.gray@zump.me.
DO WE USE YOUR PERSONAL INFORMATION TO MAKE AUTOMATED DECISIONS?
We will not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention). However, we may use automated decisions to notify our exclusive third party agency partner, Nexa Properties, of a property match. This happens automatically when a match occurs without our involvement. However, this only happens once you have accepted a “Zump”.
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice and, in any event, we will securely delete information you give us after 2 years. To determine the appropriate retention period for your personal data, we will consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If a dispute arises between us, we will keep your personal information for the purposes of responding Type of personal data Legal basis relied on to process personal data Name, email address, telephone number The legitimate interests of Zump providing the Services to users via the Platform. Profile photo The legitimate interests of Zump offering the profile feature functionality to users to display further details about themselves as part of the wider Services. Copy of personal ID The legitimate interests of Zump protecting its business and implementing security measures to prevent breach of the Platform terms of use. 4 to and dealing with this dispute and this may mean that we keep your personal information for longer to enable us to deal with the dispute.
WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?
We will only share the personal information that you give us with the following third parties and for the following reasons: We only share your data where we have sufficient safeguards in place and where we, and the organisations we transfer data to, are acting in accordance with Data Privacy Laws.
Unless stated otherwise, we may share the personal information that we collect from you with the following:
• Nexa Properties, our exclusive agency partner; and
• Our Technical Development Team in connection with the development of the Platform and any subsequent technical updates that may be required from time to time to the Platform.
WILL YOU TRANSFER MY PERSONAL INFORMATION OUTSIDE THE EEA?
We will not transfer your personal data outside the EEA at any time.
HOW DO WE ENSURE THAT YOUR PERSONAL INFORMATION IS SECURE?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
WHAT RIGHTS DO I HAVE OVER MY PERSONAL INFORMATION?
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), (the UK regulator for data protection issues. See www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact daniel.gray@zump.me in the first instance. In order to protect you and others, we may require you to prove your identity before you exercise these rights.
You also have a number of additional rights over your personal information, which are:
• the right to ask us what personal information we have about you and to have a copy of your personal information from us;
• the right to ask us to correct any errors in your personal information;
• the right to object to our legitimate interests, profiling activities and marketing communications;
• the right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information is carried out by automated means;
• the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;
• the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
• where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting our daniel.gray@zump.me.
If you are unhappy with how we have handled your personal data, you have the right to complain to your local data protection authority, which in the UK is the Information Commissioner’s Office. You can reach them through their website at http://ico.org.uk or you can contact them on 0303 123 1113.
HOW WILL YOU TELL ME ABOUT CHANGES TO THIS PRIVACY NOTICE?
We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email where appropriate (e.g. if we have your email address as a contact at one of our customers).
HOW YOU CAN CONTACT US
If you have any questions about this privacy notice or about the ways we use your personal information, please contact daniel.gray@zump.me.
ZUMP LIMITED PRIVACY NOTICE
This privacy notice explains what personal information we collect when you sign up to the Zump Platform. It also explains how we will store and use that personal information, how we keep it safe and what rights you have over it.
SUMMARY OF HOW WE USE YOUR PERSONAL INFORMATION:
1. Introduction
This Privacy Policy has been prepared in accordance with the Data Protection Act 2018 which implements the General Data Protection Regulation (or such UK legislation intended to replace or supersede it) (“Data Privacy Laws”). Defined terms used in the Privacy Policy have the meanings set out in the Data Privacy Laws.
This summarises how we use your personal information when you sign up to become a user of our app (the “Platform”) in connection with the purchase or sale (as applicable) of a property featured on the Platform.
2. Who Are We?
We are Zump Limited, a company incorporated in England and Wales with company number 12036039 and registered offices at 1 & 2 The Barn, Oldwick West Stoke Road, Lavant, Chichester, West Sussex PO18 9AA. We are the controller in relation to your personal information. If you would like any information about how we handle your personal information or have any questions or concerns about the information in this notice you should contact daniel.gray@zump.me.
3. What information do we collect, store and use and how do we use it?
Depending on whether you are buying or selling a property, when you register to become a user of the Platform, we ask you to provide some or all of the following details:
- Full name
- Full property address (this will only be displayed in full if you wish it to – see below for further information)
- Telephone number
- Email address - A copy of your driving licence (only if you wish to set up a profile)
- A profile photo (only if you wish to set up a profile)
4. Legal Grounds for collecting, storing and using your information
Under Data Privacy Laws we need to have a legal basis for collecting, storing and using your personal information. Please see the detailed summary below for an explanation of this.
5. Automated Decision Making
We may use automated decision making to send your details to our exclusive agency partner, Nexa Properties. Please see the detailed summary below for more information.
6. Who do we share information with?
We may share your information internally and also from time to time, externally. Please see the detailed section below for more information on who we share your personal data with.
7. International Transfers We will not transfer your personal data outside of the EEA at any time.
8. How long do we keep personal information? We keep information relating to you for the period in which you remain a user of the Platform and for 2 years following the date on which you cease to be a Platform user.
9. Withdrawing consent and rights over personal information You have rights over your personal information such as the ability to ask for access to it, to have it corrected or to have it deleted. Please see the detailed section below for a full explanation of your rights.
10. Who can you contact if you have a question or complaint? You have the right to make a complaint at any time to the UK regulator for data protection issues, the ICO (see www.ico.org.uk). We would like to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact our daniel.gray@zump.me.
DETAILED PRIVACY NOTICE
WHO ARE WE?
"We", "our" or "us" means Zump Limited. Our company number is 12036039. Our registered office is at 1 & 2 The Barn, Oldwick West Stoke Road, Lavant, Chichester, West Sussex PO18 9AA.
We are the controller of your personal information. This privacy notice provides information about what personal information we collect, store and use when you sign up to become a user of the Zump app (the “Platform”) in connection with the purchase or sale (as applicable) of a property featured on the Platform (the “Services”). This privacy notice also tells you what your rights are over your personal information and how to exercise those rights.
If you have any questions or concerns about the information in this notice, or about our handling of personal information more generally, or if you would like more detailed information on a particular point, you should contact daniel.gray@zump.me.
SELLERS ONLY - HOW WE USE YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR THAT
1. What personal information do we collect and how do we use it?
Information you give us: If you choose to become a user of the Platform, we will collect information from you, such as your name, email address, telephone number and the residential property address of the property you are selling. We will use this information to:
• Notify you (by way of sending you “Zumps”) when we match your search criteria with a prospective buyer; and
• Provide the Services to you via the Platform.
2. What is our legal basis for using your personal information?
Our legal basis for using the personal information above is that it is in our legitimate interests. Under Data Privacy Laws we must have a legal basis to use your personal information. We have set these out below.
Type of personal data
Legal basis relied on to process personal data
Name, email address, telephone number
The legitimate interest of Zump providing services to users via the Platform.
Full residential property address
The legitimate interest of Zump featuring properties on the Platform advertised to its customers.
We believe that use of your personal information for the purpose outlined above is a proportionate use of your personal information as we require your details in order to advertise properties on the Platform and in turn provide the Services and to be able to contact you with details of prospective buyers for your property. We consider that this is a proportionate use of your personal information because it is something we think you would expect us to do.
BUYERS ONLY - HOW WE USE YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR THAT
1. What personal information do we collect and how do we use it?
Information you give us: If you chose to become a user of the Platform, we will collect information from you, such as your name, email address, telephone number and the residential property address of the property you are selling. We will use this information to:
• Notify you (by way of sending, “Zumps”) when we match your search criteria with a property; and
• Provide the Services to you.
As a property purchaser, you will also be given the opportunity to create a user profile. In order to create a profile, you will be asked to upload a photo of yourself. If you chose, your profile picture may be publicly displayed on the Platform, viewable by other Platform users.
We may also ask you to provide a copy of your personal ID, such as a driving licence. This is a security measure to enable us to seek redress should you breach any of the terms set out in our Platform Terms and Conditions.
2. What is our legal basis for using your personal information?
Under Data Privacy Laws we must have a legal basis to use your personal information. We have set these out below.
Type of personal data
Legal basis relied on to process personal data
Name, email address, telephone number
The legitimate interests of Zump providing the Services to users via the Platform.
Profile photo
The legitimate interests of Zump offering the profile feature functionality to users to display further details about themselves as part of the wider Services.
Copy of personal ID
The legitimate interests of Zump protecting its business and implementing security measures to prevent breach of the Platform terms of use.
Our legal basis for using the personal information above is that it is in our legitimate interests. We believe that this is a proportionate use of your personal information as we require your details in order to match your search criteria with properties on the Platform and in turn provide the Services and to be able to contact you from time to time. We consider that this is a proportionate use of your personal information because it is something we think you would expect us to do.
INFORMATION THAT APPLIES TO BOTH SELLERS AND BUYERS
CAN WE CHANGE THE PURPOSE FOR WHICH WE USE YOUR PERSONAL INFORMATION?
We will only use your personal information for the purpose we have set out above unless another purpose we want to use it for is compatible. If we change the purpose for which we are using your personal information and you would like an explanation as to how the new purpose is compatible with the original purpose please contact. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to do so in a similar way to how we have done it in this notice.
WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?
If you don’t provide the personal information where we need it in relation to a contract with you then, we may not be able to contact you in relation to a contract we have entered into with you. Where we process your personal information on consent you have the right to withdraw your consent at any time. If you have any concerns about whether you need to provide the personal information please contact daniel.gray@zump.me.
DO WE USE YOUR PERSONAL INFORMATION TO MAKE AUTOMATED DECISIONS?
We will not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention). However, we may use automated decisions to notify our exclusive third party agency partner, Nexa Properties, of a property match. This happens automatically when a match occurs without our involvement. However, this only happens once you have accepted a “Zump”.
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice and, in any event, we will securely delete information you give us after 2 years. To determine the appropriate retention period for your personal data, we will consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If a dispute arises between us, we will keep your personal information for the purposes of responding Type of personal data Legal basis relied on to process personal data Name, email address, telephone number The legitimate interests of Zump providing the Services to users via the Platform. Profile photo The legitimate interests of Zump offering the profile feature functionality to users to display further details about themselves as part of the wider Services. Copy of personal ID The legitimate interests of Zump protecting its business and implementing security measures to prevent breach of the Platform terms of use. 4 to and dealing with this dispute and this may mean that we keep your personal information for longer to enable us to deal with the dispute.
WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?
We will only share the personal information that you give us with the following third parties and for the following reasons: We only share your data where we have sufficient safeguards in place and where we, and the organisations we transfer data to, are acting in accordance with Data Privacy Laws.
Unless stated otherwise, we may share the personal information that we collect from you with the following:
• Nexa Properties, our exclusive agency partner; and
• Our Technical Development Team in connection with the development of the Platform and any subsequent technical updates that may be required from time to time to the Platform.
WILL YOU TRANSFER MY PERSONAL INFORMATION OUTSIDE THE EEA?
We will not transfer your personal data outside the EEA at any time.
HOW DO WE ENSURE THAT YOUR PERSONAL INFORMATION IS SECURE?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
WHAT RIGHTS DO I HAVE OVER MY PERSONAL INFORMATION?
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), (the UK regulator for data protection issues. See www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact daniel.gray@zump.me in the first instance. In order to protect you and others, we may require you to prove your identity before you exercise these rights.
You also have a number of additional rights over your personal information, which are:
• the right to ask us what personal information we have about you and to have a copy of your personal information from us;
• the right to ask us to correct any errors in your personal information;
• the right to object to our legitimate interests, profiling activities and marketing communications;
• the right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information is carried out by automated means;
• the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;
• the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
• where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting our daniel.gray@zump.me.
If you are unhappy with how we have handled your personal data, you have the right to complain to your local data protection authority, which in the UK is the Information Commissioner’s Office. You can reach them through their website at http://ico.org.uk or you can contact them on 0303 123 1113.
HOW WILL YOU TELL ME ABOUT CHANGES TO THIS PRIVACY NOTICE?
We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email where appropriate (e.g. if we have your email address as a contact at one of our customers).
HOW YOU CAN CONTACT US
If you have any questions about this privacy notice or about the ways we use your personal information, please contact daniel.gray@zump.me.