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Privacy Policy

  • Updated

About this policy

This Privacy Policy explains how Allbricks ("Global Brick Exchange Ltd”, a private limited company registered in England & Wales with company number 13320618, “we”, “our”, “us”) processes the personal data of visitors to and users of our website hosted at allbricks.co (the "Site"), individuals who become Home Buyers and Investors, and Estate Agents (together referred to as "Users", "you", "your").

As explained elsewhere on the Site, a Home Buyer is someone who applies to purchase a property through Allbricks. The Home Buyer buys a minimum of 1% of the property purchase price or £10,000 (whichever is higher) and Investors purchase the remainder of the property. Home Buyers will live in the property they are purchasing and own a share of it; they pay rent on the portion they do not own to the Investors. Home Buyers can increase the proportion of their ownership over time by purchasing more units of property value (we call them ‘Bricks’).

An Investor is someone who does not occupy the property but will help to fund the purchase of it by purchasing Bricks; in this way, the Investors provide the capital for the Home Buyer to purchase the property from its previous owner; and the value of the Investors’ Bricks can grow over time. Global Brick Exchange Ltd (“Allbricks”) is the 'data controller' of your personal data and is subject to the General Data Protection Regulation (the "GDPR"). We are the data controller of this personal data under the GDPR because in the context of our business relationship with you, we decide why and how your information is processed in the ways explained in this Privacy Policy.

This Privacy Policy forms part of and is incorporated into the Terms of Use applicable to the use of the Site.

We may amend this page from time to time. You should check this page periodically for any changes. This page was last updated on 3 November 2022.

How we collect Users' information

When you use the Site, we collect your personal data in the following ways:

  • When you access and navigate around the Site (please see our Cookie Policy);
  • When you apply to become a Home Buyer or an Investor;
  • When you communicate with us by email, phone, or via the Site; and
  • When you sign up to receive our newsletters and other updates.

Where you provide us with personal data relating to others (for example, your cohabitees, family members or guarantors), we understand that you are authorised to provide that information to us, and that you have provided this Privacy Policy to them, as appropriate.

The types of information we collect

Where you are a visitor to the Site, we may collect the following types of personal data about you:

  • Name and contact details, including email addresses, postal addresses, and telephone numbers;
  • Other information that Users provide through the Site, for example in messages to our support team;
  • Information about Users' devices and Site browsing activity collected through the use of cookies, including details of your domain name, location and internet protocol (IP) address, operating system, browser version, the content viewed during a particular browsing session, and how long a User stayed on a particular page. Please see our Cookie Policy.

We may also collect 'sensitive personal data', for example information concerning health and medical conditions, but only where Users volunteer this information in a message, form or email to us.

Where you are a Home Buyer, we may collect the following types of personal data about you:

  • Biographical and contact information, including your name, date of birth, residency and tax status, and contact information including email addresses, postal addresses, and telephone numbers;
  • Identification and due diligence information, including your passport or driver's licence or National ID information, proof of address, national insurance number (or other tax identification number), income, employer details and due diligence information such as the results of anti-money laundering checks (Political Exposed Person (PEP) status, sanctions and adverse media results),‘know your client’ and tenancy checks (credit check including credit score, number and status of credit accounts, CCJ data, bankruptcy data, insolvency data, previous names, electoral roll registration data, employment type, occupation, confirmed income, employer name and address, length of employment);
  • Financial and wealth-related information, including bank account details and information relating to your financial situation such as your income, source of income, source of wealth; and proof of source of income and wealth;
  • Property-related information concerning the property which you are using our help to purchase, including its location and value (insofar as this may become data relating to you, as its owner).

Where relevant, we may also obtain these and similar details about your cohabitees and guarantors.

Where you are an Investor, we may collect the following types of personal data about you:

  • Biographical and contact information, including your name, date of birth, residency and tax status, and contact information including email addresses, postal addresses, and telephone numbers;
  • Identification and due diligence information, including your passport or driver's licence or National ID information, proof of address, national insurance number (or other tax identification number) and due diligence information such as the results of anti-money laundering and ‘know your client’ background checks (which may reveal that you are a politically exposed person (PEP) or details of any sanctions you are subject to);
  • Financial and wealth related information, including bank account details and information relating to your financial situation such as your assets, net worth, income, source of wealth and your investment objectives in purchasing Bricks in one or more properties through Allbricks.

Where you are an Estate Agent, we may collect your name and business contact details (including email addresses, postal addresses, and telephone numbers) and other information relevant to your professional involvement in the Allbricks community, including where we may provide you with training and educational material in relation to our business and where we work together to promote Allbricks as an alternative way to fund the purchase of a home.

Where you are a prospective Home Buyer, we may obtain, from third party sources and based on your online browsing activities, certain information about your income, your professional and personal interests, investment interests, details of property you own, etc. in order to assess whether you might be interested in purchasing a property using Allbricks, and to reach out to you to gauge your interest in this.

Where you are a prospective Investor, we may obtain, from third party sources and based on your online browsing activities, certain information about your income, your professional and personal interests, investment interests, details of property you own, etc. in order to assess whether you might be interested in becoming an Investor in one or more properties purchased using Allbricks, and to reach out to you to gauge your interest in this.

The legal grounds and purposes for processing Users’ information and how we use it

(i) We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract, in particular:

  • our Terms and Conditions, which govern our relationship with Home Buyers and Investors generally;
  • the Platform Agreement, which governs your use of the Allbricks platform (which is used to communicate the availability of Bricks for particular properties which Home Buyers wish to purchase through Allbricks, to report on all purchases of Bricks, and to track ownership and sales);
  • an Assured Shorthold Tenancy agreement, which is signed by Home Buyers in respect of the property they are purchasing through Allbricks; and
  • the Participation Agreement, which governs the relationship between Allbricks, the Home Buyers (in respect of the property they are purchasing) and the Investors (in respect of all properties they are  co-funding the purchase of by purchasing Bricks as made available via the Allbricks platform).

In this respect, we may use your personal data for the following:

  • processing your application to be a Home Buyer, including:
    • carrying out initial assessments of the property value you can purchase and the associated rent amount, affordability checks regarding the rental component of the purchase, and appropriateness tests to ensure that you meet our criteria to become a Home Buyer;
    • carrying out the Home Buyer on-boarding process, involving identity verification checks, anti-money laundering and ‘know your client’ background checks, credit checks and tenancy checks (including county court judgment (CCJ) checks and references from previous landlords) to assess your creditworthiness and suitability in respect of the property you wish to purchase through Allbricks;
    • carrying out the property on-boarding process, including a homebuyer survey, searches and other due diligence in relation to the property;
  • raising the purchase funds via crowdfunding from Investors who purchase Bricks;
  • on-boarding and liaising with you as an Investor, including:
    • carrying out the Investor on-boarding process, involving identity verification checks, anti-money laundering and ‘know your client’ background checks, and appropriateness tests (to ensure that you meet our criteria to become an Investor);
    • contacting you as part of the Bricks purchasing process to gauge your interest in purchasing Bricks for particular properties via the Allbricks platform;
    • helping you ensuring you have sufficient funds in your wallet to purchase Bricks and completing the transfer of those funds where you wish to purchase Bricks; and
  • otherwise for the performance of the Allbricks agreements mentioned above, including:
    • to manage the additional purchase, and the sale, of Bricks in properties, whether by Home Buyers or Investors;
    • liaising with Champions in connection with the sale and purchase of Bricks, the management of properties, or other matters under the Allbricks agreements (as applicable); and
    • collecting rental payments, coordinating property maintenance work, and carrying out our duties as landlord under Assured Shorthold Tenancy agreements (as applicable).

(ii) We may process your personal data because it is necessary for our or a third party's legitimate interests. Our "legitimate interests" include our interests in operating our business and the Site in a commercial and User-friendly way.

In this respect, we may use your personal data for the following:

  • to interact with you via the Site(for example, to send you promotional material or answer enquiries about our products);
  • for record keeping purposes, so that we have a record of the enquiries we receive through the Site;
  • outsourcing selected website / services administration functions to third parties for the purposes of the efficient management of the Site and/or those services;
  • to monitor, evaluate and improve the performance and effectiveness of the Site, the Allbricks platform and our services, including by training our staff and/or monitoring their performance.

(iii) We may also process your personal data for additional reasons where:

  • it is necessary for compliance with our legal and regulatory obligations. In this respect, we may use your personal data for:
    • anti-money laundering and ‘know your client’ purposes;
    • regulatory recordkeeping purposes;
    • compliance with our obligations under all laws applicable to our business, including tax laws and directions from HM Revenue and Customs; 
    • compliance with applicable regulatory rules including HMRC rules; and
    • carrying out our statutory obligations as a landlord under Assured Shorthold Tenancy agreements.
  • it is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights or property including intellectual property rights in and to our brand, the Site and any of its content, and/or when enforcing contractual rights or bringing claims under any of the Allbricks agreements referred to above); and
  • we have your specific or, where necessary, explicit consent to do so (for example, where we need your consent to send you our newsletter or other marketing communications by email).

Sharing Users’ information with others

For the purposes referred to in this Privacy Policy and relying on the bases for processing as set out above, we may share your personal data with certain third parties, including:

  • our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
    • our Champions and other staff and contractors who may provide or offer to provide services to you in response to a request for support or an enquiry you make about Allbricks;
    • providers of outsourced services to us (for example, any third party we engage to administer the Site on our behalf, the providers of ‘back office’ functions and tools, and those we use for the verification and on-boarding of Home Buyers and Investors, including credit reference agencies, Smartcredit Limited (trading as SmartSearch, used for address checks), IDnow UK Limited (used for KYC checks), ComplyAdvantage for PEP, Sanctions, Adverse Media Checks as well as Transaction Monitoring, Modulr (trading as Modulr Finance Limited, providing the wallets) and Canopy plus others who may be named in their Privacy Policy, which is found here: https://www.canopy.rent/legal/privacy-policy);
  • internal and external auditors, our professional advisers, and potentially regulators including HMRC (where required);

Transferring Users’ information outside of Europe (including the UK)

In the course of interacting with you via the Site and/or as a Home Buyer, Investor or Estate Agent, we may transfer your personal data outside of the European Economic Area ("EEA") or the UK (as applicable), including to third party service providers and data processors which may be based in the United States or elsewhere; this means that your personal data may not have the automatic protection of European / UK data protection laws (including the GDPR) which apply in the EEA / UK. In these circumstances, in order to ensure that your personal data continues to have adequate protection when it is transferred out of the EEA / UK, your personal data will only be transferred on one of the following bases: 

  • a European Commission / UK decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
  • where the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by applicable law (for example, standard data protection clauses adopted by the European Commission or the UK Secretary of State, as applicable);
  • there exists another situation where the transfer is permitted under applicable law (for example, where the transfer of your personal data is necessary for the performance of a contract with you).

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA / UK by contacting us using the details set out below.

How long Users’ information is kept

We will retain your personal data for as long as we are interacting with you via the Site and/or under applicable Allbricks agreements, including our Terms and Conditions, Platform Agreement, Participation Agreement and any Assured Shorthold Tenancy agreements (as applicable), for as long as necessary to keep in touch with you where you have previously asked for this (e.g. where you are part of our network of Estate Agents and/or where you have signed up for our mailing list), and for as long as permitted or required for legal and regulatory purposes after the last such interaction we have with you or following the expiry or termination of your contract(s) with us.

Subject to any other notices that we may provide to you, we will typically retain your personal data for at least seven years after our last interaction with you, or the end of the applicable Allbricks agreements between you and us. 

Information security

Allbricks takes information security seriously. We have implemented all appropriate technical and organisational measures to ensure that the personal data (and other information) we collect is kept secure at all times. Those measures include robust network security, using resilient systems and services, regular testing for security threats, policies and training for staff, and ensuring the ability to restore access to data quickly in the event of an information security incident.

If you want to know more about the information security measures we have in place, please get in touch using the contact details below.

Users’ rights in relation to personal data

Under the GDPR, you have the following rights in relation to our processing of your personal data. Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

  • to obtain access to, and copies of, the personal data that we hold about you;
  • to require us to correct the personal data we hold about you if it is incorrect;
  • to require us to erase your personal data in certain circumstances;
  • to require us to restrict our data processing activities in certain circumstances;
  • to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
  • to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

Note: If you have given your consent (e.g. to receive our newsletters) and you wish to withdraw it, please contact homebuying@allbricks.co or investing@allbricks.co.

Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

If you are not satisfied with how we are processing your personal data, you can raise a concern with the UK Information Commissioner. You can also find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk.

Contact us

If you have any queries about this Privacy Policy or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you may contact us by email at dataprotection@allbricks.co.

Cookies

The Site uses cookies. A "cookie" is a small text file which is sent by our Site’s server and stored on your computer or other device when you access the Site. These cookies are used for the purpose of improving your experience of the Site by remembering your preferences, the places you have visited, and other information that you have provided to us. When you use the Site, you will be asked to confirm whether you agree to the Site using cookies and, if you accept, we will store cookies on your device. You can if you wish change the cookies settings on your device to refuse cookies. However, if you do this, or if you reject our request to use cookies when you visit our Site, you may be unable to access certain parts of the Site and/or you may not be able to benefit from the full functionality of the Site.

As a very simple summary, we use the following cookies for the following purposes:

  • Essential Cookies: these are essential in order to enable you to move around the Site and use its features, for example to remember which page of the Site you have previously visited during the same session, so that you can quickly move backwards and forwards between those pages.
  • Performance and Analytics Cookies, including Google Analytics: these keep track of the pages of the Site that you visit and the content you access, so that we can determine which content is most popular and improve the performance of the Site. These cookies record only anonymous statistical data and do not collect any personal data that could identify an individual User.
  • Functionality Cookies: these remember the choices you make, such as language options or the region you are in. These cookies help to make your visit to the Site more personal and are deleted automatically when you close your browser or when your browsing session expires.

To find out more general information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org.

To find out more detailed information about the cookies used on the Site, please see our full Cookie Policy.

 

 

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