Privacy & Cookies Policy

This Privacy and Cookies Policy applies to the website moveready.app, moveready.app and the MoveReady mobile applications available on iOS and Android devices (“the Platform”) which is run by MoveTopia Ltd (“the Company”) whose registered office address is 39 Parmiter Way, Ampthill, Bedford.

The Company recognises the importance of honest and responsible use of your personal information. This Privacy and Cookies Policy (“Policy”) explains how the Company collects, uses and discloses personal information about you when you visit this Site and when you contact the Company, whether by e-mail, post or telephone using the contact options on this Site. The information you provide to us through the Platform will initially be collected by MoveTopia Ltd, but may then be shared with other companies.

Our collection of website use information may involve the use of cookies and Web beacons. Please see the “Cookies” section below for more information.

DATA PROTECTION

For the purposes of the Data Protection Act 1998 (the Act) and the General Data Protection Regulation, the data controller is the Company.

LEGAL BASIS FOR THE USE OF PERSONAL DATA

The legal basis on which we rely to process your personal information includes:

- On some occasions, we process your data with your consent (for example, when you agree that we may place cookies or process information that you input into our website).

- On other occasions, we process your data when we need to do this to fulfil a contract with you (for example, if you sign up to our move tracker service or where we are required to do this by law (for example, to comply with record keeping obligations).

- We also process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights (including for example, when we share data with our affiliates).

In most cases, the information the Company processes about you is required to deal with your request or registration, or required by law, or is necessary for the exercise of the Company’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.

The Company may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Company performance.

PERSONAL INFORMATION WE COLLECT FROM YOU

If you want to use the services and facilities we provide on the Platform, you will need to provide us with some personal information. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.

We have established a number of measures to keep your data secure on our platform, including encrypting data both at rest and in transit.

Where you choose to provide personal details to us, we may collect, store and process the following personal information from you:

- your full name;

- your contact details e.g. address, telephone numbers and e-mail address;

- Information about your move, including for example details about your conveyancer, mortgage broker and any information that you complete within your profile and move budget;

- account details – your password, e-mail address and your full name, address and postcode;

- identification information – the details you enter when you confirm your ID, including for example your passport photo from the passport scan, note that we do not store your passport number, expiry date, date of birth;

- affordability details – the information you enter that we use to calculate what property you can afford, including for example deposit and mortgage amount;

- property purchase details – the information you enter about the property you want to buy (if applicable), including for example the property price and lease type;

- property sale details – the information you enter about the property you want to sell (if applicable), including for example the property sale price, lease type and details about the property;

- your contact and marketing preferences;

- if you contact us, the reason for your contact, which may be an enquiry, a request or enquiry on behalf of someone else, providing a comment, or details in relation to a possible or existing service;

- if you take a survey or interact with us in various other ways – demographics information and information about subjects that may interest you;

- standard internet and website log information and details of patterns about how website visitors behave on our Site. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests.

- where you “like” us or make posts on our pages on social networking websites.

This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of other company services.

USES MADE OF YOUR PERSONAL INFORMATION

The Company may use information about you for purposes described in this Policy or disclosed to you on our Site or with our services. For example, we may use information about you for the following purposes, all of which we believe to be in our legitimate business interests:

• to operate services promoted on the Platform;

• to establish identity and carry out the anti-money Laundering checks as required under The Money Laundering and Terrorist Financing (Amendment) Regulations 2019. For this purpose, the Company will share client’s personal information with our referencing provider, and/or conveyancers, solicitors, financial providers and estate agents that are linked to you. This is required to ensure the Company, and our clients are not the victim of fraud and to protect our legal rights;

• to enable us to complete a transaction with you;

• to share relevant information about your move with third parties such as solicitors, surveyors, prospective buyers, vendors and financial advisors, this means you don’t have to provide the same information multiple times to other parties you are collaborating with;

• for the purpose of keeping you fully informed in relation to the property prior to bidding;

• To ensure that content from our platform is presented in the most effective manner for you and your device and show personalised content based upon your preferences and/or previous interactions with the Platform;

• to send promotional emails, post and/or SMS messages about new products, special offers or other information which the Company think you may find interesting using the email address and mobile phone number which you have provided;

• to notify you about changes to our service that the Company think may be of interest to you via email, post and/or SMS messages;

• to contact you for market research purposes either by email, phone, or mail;

• to respond and/or deal with any request or enquiry you may raise;

• to improve our products and services and to ensure that content from the Platform is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);

• to administer the Platform;

• for internal record keeping;

• to contact you (directly, either by the Company or through a relevant partner or agent) by e-mail or phone for the above reasons;

• subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;

• to perform any contract the Company has with you; and

• for compliance with legal, regulatory and other good governance obligations.

In all instances, the Company will only process personal information in this way if it is necessary for the performance of a contract, you have requested us to do so or if it is required for us to comply with any legal obligations.

The Company will never process your data for anything other than legitimate interest in ensuring that the Company can provide the best service possible or providing you with information that may be of interest to you.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other Company staff who properly need to know these details for their functions within the Company and our parent and subsidiary companies (“Group”). Please note that certain individuals who will see your personal information may not be based at the Company or in your country (please see below).

We may share personal information within the Company as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by the Company for the other purposes described in this Policy.

Your personal information may also be made available to third parties (within or outside the Company) providing relevant services under contract to the Company, (see below for further details), such as credit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.

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 providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Company, our employees, agents, customers, and others, as well as to parties to whom you authorise the Company to release your personal information.

We will not sell your personal information to any third party other than as part of any restructuring of the Company or sale of the business.

WHAT CHOICES DOES THE COMPANY OFFER YOU WITH REGARD TO DIRECT MARKETING?

The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post, social media or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.

WHAT SAFEGUARDS ARE IN PLACE TO PROTECT YOUR PERSONAL INFORMATION?

The Company takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of the Company, or their agents.

WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND PERSONAL INFORMATION?

You have the right to review and access your personal information held by the Company. You also have the right to ask us to rectify, block, complete and delete your personal information, to restrict its use, and to ‘port’ your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).

In addition, you have the right to request further information about the handling of your personal information.

If you wish to do so, or to notify the Company of a change in your details, please contact hello@moveready.co.uk.

There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.

If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us using the contact details set out above.

Finally, if you have unresolved concerns, you also have the right to complain to data protection authorities

KEEPING YOU INFORMED

When we store your information, we do so for as long as necessary to (i) fulfil the specific purposes for which your personal information was collected to perform the services set out in this notice and (ii) to comply with our legal obligations or enforce our legal rights.

INFORMATION ABOUT OUR USE OF COOKIES

We use cookies for certain areas of our Site. Cookies are small data files stored on your hard drive by a website. Cookies help us improve our Site and your experience. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Platform according to your preferences.

Overall, cookies help us provide you with a better experience of our website, by enabling us to monitor which pages you find useful and which you do not. We may also use cookies for targeting or advertising purposes. We may use Web beacons on our Site or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. To delete or block cookies by browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

We also use Google Analytics on our Site to collect information about your online activity on the Platform, such as the Web pages you visit and the links you click on the Platform. We use the information to compile reports and to help us improve the Platform. The cookies collect information in an anonymous form, including the number of visitors to the Platform, where visitors have come to the Platform from and the pages they visited.

For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this Site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.

The cookies used on our Site are categorised in accordance with the International Chamber of Commerce United Kingdom Cookie Guide as follows:

- Cookies which are “strictly necessary” for functionality of the Platform’s platforms. These cookies are essential in order to enable users to move around the Platform and use its features.

- "Performance" cookies which collect information about how users navigate the Platform, for example, which pages users access most frequently. They identify how users interact with our Site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Site works and understand what interests our Site’s users.

- "Functionality" cookies which allow the Platform to remember choices you make and your preferences as a logged in user (based on e.g. your user name).

- "Targeting or advertising" cookies used to deliver adverts relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Platform to ensure advertisements about similar products displayed on the Platform are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the Platform has been visited from a device and share that information with marketing organisations. The marketing cookies on our Site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards our Site so that we know whether it is worth us investing in that particular advertising source.

Cookie name Expiration Period Purpose Category

VSI Cookie Status 12 months from set/update Enables us to remember if you have seen the cookie information panel and accept cookies from this website. A. Strictly necessaryC. Functionality

Google Analyticsutma 2 years from set/update Provides a unique ID for each Web browser that visits this site. D. Targeting / advertising

Google Analyticsutmb Session30 minutes from set/update Used to establish and continue a user session with this website. D. Targeting / advertising

Google Analyticsutmc Session(these cookies typically expire at the end of Used to establish and continue a user session with this website. D. Targeting / advertising

COOKIE SETTINGS

We will ask for your consent to the use of cookies set out in this Privacy and Cookies Policy when you first access the Platform and if we introduce any new cookies to the Platform. When you first visit the Platform, a box/banner will appear asking you to agree to the cookies that we set on the Platform.

You can usually choose to set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on our Site.

If you agree to cookies from our Site by clicking on the “I agree” button, we will set cookies from categories A, B, C and D on your device. If you wish to delete the cookies we have set on your device, please refer to your browser Help menu.

If you do nothing to indicate your cookie preference for our Site (i.e. if you do not click on “I agree”), we will treat this as acceptance and set category A, B and C cookies (which are, in our reasonable view, not ‘intrusive’ of your privacy) on your device. By default, category D cookies will not be set on your device. To modify your cookie settings, please refer to the Help menu of your browser.

If you say no to cookies on our Site we will not set category A, B C, or D cookies on your device. Please note that if you do this you may not be able to use the full functionality of our Site.

CHANGES TO THIS PRIVACY AND COOKIES POLICY

We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.

We encourage you to check the date of this Policy when you visit this Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.

Contact/address details

If you have any questions about this Privacy Policy, contact us at hello@moveready.co.uk.

MoveReady Privacy & Cookies Policy