Retransform

Privacy Notice

Last updated: June 2024

1. Who we are

Annet Technologies Europe Limited (ATEL) and its subsidiary companies including Retransform and associated group entities including Annet Technologies (USA), Inc., Annet Technologies (Middle East) FZE, Annet Technologies (Australia) Pty. Ltd., Annet Technologies (Mumbai) LLP, Annet Retransform (Gujarat) LLP (together “Retransform” or “we”) are a global technology provider offering Proptech, Technology Solutions and Business Managed Services to the real estate industry. Retransform are committed to respecting and protecting our customers’ privacy and treats it with respect.

We incorporate marketing preferences in your online account, which affect how we will process your personal data. By using the marketing preferences functionality, you can specify whether you would like to receive direct marketing communications and limit the use of your information. You can change your marketing preferences at any time by calling your ATEL account manager or calling our switchboard and asking to speak to our GDPR team.

2. About this notice

This privacy notice applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of such personal data. It captures personal data entered across all channels: through our website, app, or via our Customer Account Management team.

Please read this notice carefully to understand our views and practices regarding your personal data and how we will treat it.

3. How we use your personal data

In this section we outline how we may process your personal data. All personal data we process falls into one or more of the following categories:

  •  Order data
  • Transaction data
  •  Financial data
  • Internal social data
  •  Usage data
  •  Communication data
  •  Enquiry data
  •  Digital marketing data
  •  CCTV where used

We may process your order data (“order data”). The order data may include your name, billing address, delivery address, phone number and email address. The order data will be processed for the purposes of delivering your order to you. The legal basis for this processing is the performance of a contract between you and us.

We may process your transaction data (“transaction data”). The transaction data may include information relating to your previous transactions, including purchases of goods and/or services. The transaction data may include your name, billing address, delivery address, telephone number, email address and purchase history. It may be processed for the purposes of supplying the purchased goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.

We may process financial information (“financial data”) you share with us. The financial data may include data about your company, name and billing address. The financial data may be processed for the purposes of processing your payments and to prevent fraud. The legal basis for this processing is the performance of a contract between you and us.

We may process information that you post for publication on our website or app, such as wall posts or product ratings and reviews (“internal social data”). This internal social data is public and may be processed for the purposes of enabling interaction on the website or app between customers and ATEL staff. In instances where internal social data is stored in an unstructured format (such as free text reviews and wall posts) it is exempt from our data retention rules, however may be deleted upon request. The legal basis for processing internal social data is consent.

We may process data about your use of our website or app, and reaction to our emails and services (“usage data”). The usage data may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data are our analytics packages (including, but not limited to Google Analytics) and email service providers. This usage data may be processed for the purposes of analysing the use of the website, emails and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

We may process information that you provide to us for the purpose of subscribing to our direct marketing communications (“communication data”). The communication data may include your name, email address, postal address, phone number or marketing preferences. This communication data may be processed for the purposes of contacting you with service notifications, such as that your order has been processed, or contacting you with relevant offers and messages. The legal basis for this processing is performance of a contract for service notifications and legitimate interests for direct marketing communications.

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). This enquiry data may be processed for the purposes of providing clarification, resolving issues or marketing relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and to ensure we are responding to your enquiry.

We may process information that you provide to us for the purpose of improving our digital marketing (“digital marketing data”). We may use digital marketing data in a number of different ways: either to advertise our products and services to you on third party websites such as Facebook, or to advertise our products and services to similar customers (lookalikes) on third party websites such as Facebook. We may also use digital marketing data to exclude you from seeing advertisements from third party websites such as Facebook. The digital marketing data may include your name, email address, billing address, phone number, date of birth, gender, and the user ID of any social platforms you have connected with us on. The legal basis for this processing is our legitimate interests, namely providing better services and enhancing our customer base.

Please be aware that CCTV is in operation in our head office.

We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Please do not supply any other person’s personal data to us.

4. Providing your personal data to others

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is essential in order do that.

However, we may disclose your personal data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this notice:

  • To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice
  • To our insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice
  •  To deliver news, provide updates and offers to you we will you via the post or email

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data with law enforcement, regulatory and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure.

5. Transfers outside of the European Economic Area (EEA)

Where there is a transfer within Retransform or to a third party in a different jurisdiction, including, but not limited to transfers outside of the European Economic Area, we will take appropriate steps to ensure there is an adequate level of protection for personal information (which includes a legal agreement and appropriate security measures) in place in accordance with applicable legal requirements. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

6. How long we retain your data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

If you have registered on our website, contacted us via telephone or email but have not purchased from us, the length of time we will retain your data is dependent upon whether you have opted into our marketing communications. If you have opted in, we will retain your data for 3 years since your last interaction; if you have not opted in, we will retain your data for 1 year but not use it, giving you the opportunity to re-establish a connection with us should you wish to take advantage or our threat warning, cyber advice or other valuable free services.

Whilst you are an active customer (which, for the avoidance of doubt, means you have purchased goods or services from us or used our paid advisory services) we will retain your data for as long as needed to give you the best possible customer service including the renewal of any subscription services you may have purchased. We will anonymise your personal data 7 years after your last transaction with any Retransform company.

For the purposes of this notice, an interaction is defined as an identifiable website or app session or contacting our Customer Account Management Team. We will inform you before we anonymise your data and give you the option for us to retain your details, so we can continue to serve you.

In all instances outlined above, the process of anonymising your data may take up to one calendar month.

In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.

7. Your rights

You have a number of legal rights in relation to the personal information that Retransform holds about you, and you can exercise your rights by contacting us using the details set out in section 10 below.

Depending on applicable law, these rights may include:

  1. Right to access. You have the right to request information regarding the processing of your personal information and access to the personal information we hold about you.
  2. Right to rectification. You have the right to request that Apex correct any information you believe is inaccurate. You also have the right to request Apex complete information you believe is incomplete.
  3. Right to erasure. You are able to request we erase your personal information in certain circumstances. There may be circumstances where you request us to erase your personal information but we are legally entitled to retain it.
  4. Right to restrict processing. You have the right to request that Apex restrict the processing of your personal data under certain conditions. There may be circumstances where you object to or ask us to restrict our processing of your personal information but we are legally entitled to refuse that request.
  5. Right to object to processing. You have the right to object to Apex’s processing of your personal data under certain conditions.
  6. Right to data portability. You have the right to request that we transfer the data we have collected to another organisation or directly to you under certain conditions.
  7. Make a complaint. You can lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by us.

8. Recruitment

For details of the way we process information relating to external candidates we are happy to provide when requested our recruitment data retention notice.

9. Marketing and unsubscription

At any time you can amend your marketing preferences to reduce, remove or increase the amount we contact you with direct marketing communications. You may exercise this right by either (a) emailing us at dpo@retransform.com or calling our main number +44-(0)20-3287-6426 and asking for our GDPR team or by contacting your Customer Account Manager.

10. How to contact us

If you have any concerns or questions about this privacy notice or would like to exercise your rights as a data controller, you can contact us at dpo@retransform.com.

11. Updates

We will update this privacy notice when necessary to reflect changes in the law, our practices and in our services, as well as to ensure it is accurate and up to date. When we make an update we will amend the date at the top of this notice, you are therefore advised to check this privacy notice periodically.  We may also notify you in other ways from time to time about the processing of your personal information.