https://we-complete.com (our website) and our online portal is provided by Techinc Holdings Limited, a company registered in England and Wales under company registration number 08010283, with registered office address at Friars Mill, Friars Terrace, Stafford, England, ST17 4AU, trading as WeCOMPLETE (‘we’, ‘our’ or ‘us’).

WeCOMPLETE offers a SaaS (Software-as-a-Service) portal designed to enable estate agents, legal teams, sellers and buyers to monitor the progress of property transactions (the Portal).

We are the controller of personal data obtained via our website and the Portal, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website and the Portal. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

What this policy applies to

This privacy policy relates to your use of our website and the Portal.

Throughout our website and/or the Portal, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website and the Portal. We will collect and use the following personal data about you:

• your name, address and contact information, including email address and telephone number and (if relevant) company details;
• your account details, such as username and login details;
• information to check and verify your identity, e.g. date of birth;
• your gender, if you choose to give this to us;
• location data, if you choose to give this to us;
• your billing information, transaction and payment card or other payment method information;
• bank account and payment details;
• details of any information, feedback or other matters you give us by phone, email, post or via social media;
• your activities on, and use of, our website/the Portal;
• your personal or professional interests;
• information about the services we provide to you; and
• information about how you use our website and the Portal.

If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it may prevent us from providing services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us for access to our Portal, contact us (including via email), send us feedback, use our services, visit our website, post material to our Portal, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services to you	To provide you with access to our Portal
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Customise our website and Portal and its content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent as gathered – see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Retaining and evaluating information on your recent visits to our website and Portal and how you move around different sections of our website/Portal for analytics purposes. This helps us to understand how people use our website/Portal so that we can make it more intuitive or to check our website/Portal is working as intended	Depending on the circumstances: —your consent as gathered – see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information
External audits and quality checks, e.g. for the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

 

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) in connection with our services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us at: info@we-complete.com

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

• third parties that have access to the Portal e.g. law firms/conveyancers, estate agents, mortgage brokers, and other parties normally involved in a standard conveyancing transaction (Conveyancing Third Parties).
• other third parties we use to help us run our business, e.g. website hosts and website analytics providers

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. The law firms/conveyancers shall provide their own privacy notice to you when you sign up with them regarding how they in turn handle your personal data.

The Conveyancing Third Parties will have access to the Portal for the conveyancing transaction. You can view these third parties’ details on the Portal, and only the firms/conveyancers shall be able to see certain documents e.g. confidential information relating to the transaction.

We or the third parties mentioned above may occasionally also need to share personal data with:

• external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data.

For the avoidance of doubt, we shall keep your data on the Portal in case you require the relevant documents (e.g. certificates) for a future sale of your property. If you request as to delete/anonymise your data on the Portal, we shall do so as soon as reasonably practicable.

Transferring your personal data out of the UK

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

For example, we may transfer your personal data to our service providers located outside the UK in the United States of America.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. In addition, EEA data protection laws provide that transfers of personal data to the UK are lawful under an interim arrangement (UK interim bridge) while the European Commission seeks to determine if the UK can be granted a longer-term adequacy decision;
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Where we transfer your personal data outside the EEA we do so on the basis of the UK interim bridge or an adequacy decision or (where such is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

For further information about such transfers and the safeguards we employ, please contact us (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

The table below provides more information about the cookies we use and why:

The cookies we use	Name	Purpose	Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie
Analytics cookies	Google Analytics	usage – we use cookies to help us to track what pages/sections you visit on our website and Portal	necessary cookies – we use these cookies to help make our website/Portal usable by enabling basic functions like page navigation and access to pages which require visitors to create an account and login. Our website/Portal cannot function properly without these cookies   For more information visit: https://support.google.com/analytics/answer/6004245
Analytics cookies	Hotjar	usage – we use cookies to help us to track what pages/sections you visit on our website and Portal	necessary cookies – we use these cookies to help make our website/Portal usable by enabling basic functions like page navigation and access to pages which require visitors to create an account and login. Our website/Portal cannot function properly without these cookies   For more information visit: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookie-Information

 

·       Consent to use cookies and changing settings

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

·       How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

For further information on cookies generally, including how to control, manage and/or disable them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website/Portal.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. [We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.]

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• the Information Commissioner in the UK, and
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.

The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details	Our Data Protection Manager’s contact details
WeCOMPLETE info@we-complete.com Friars Mill, Friars Terrace, Stafford, England, ST17 4AU	Amy Simmons ceo@we-complete.com Friars Mill, Friars Terrace, Stafford, England, ST17 4AU

 

Changes to this privacy policy

We may update this policy from time to time by publishing a new version on our website, so you should check this page occasionally to ensure you are happy with any changes we have made to this policy. We may also notify you of changes to this policy by email.

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