Privacy Policy

Introduction

We take the protection of your personal information and privacy very seriously.  When you use our website or our app, you trust us with your information.  This policy explains what information we collect about you and why we collect it, how we use that information, and your choices and rights. Please read this policy carefully and ensure you understand it.

Who we are

This privacy policy covers Trovier Limited (“Trovier/we/us/our”), a limited company registered in England under company number 14701640.  Our registered address is Astra House, The Common, Cranleigh, Surrey, United Kingdom, GU6 8RZ and our main trading address is 13 Hanover Square, Mayfair, London W1S 1HN.

We are the providers of the Trovier mobile application software (“our app”) and the website https://trovier.com (“our website”) (which together are referred to as “our platforms”) and any other services we may operate in the future.

When you are using our platforms, Trovier Ltd is the data controller. We have appointed a Data Protection Officer who can be contacted by email at dpo@trovier.com.

What does this policy cover?

This privacy policy applies only to your use of our platforms. Our platforms may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Your rights

As a data subject, you have the following rights under the GDPR, which this policy and our use of personal data have been designed to uphold:

• the right to be informed about our collection and use of personal data;
• the right of access to the personal data we hold about you;
• the right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in this policy);
• the right to be forgotten – i.e. the right to ask us to delete any personal data We hold about you (we only hold your personal data for a limited time, as explained in in this policy, but if you would like us to delete it sooner, please contact us);
• the right to restrict (i.e. prevent) the processing of your personal data;
• the right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• the right to object to us using your personal data for particular purposes; and
• rights with respect to automated decision making and profiling.

If you have any cause for complaint about our use of your personal data, please contact us and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

What data do we collect?

Depending upon your use of our platforms, we may collect some or all of the following personal and non-personal data (please also see the section on our use of cookies):

• name;
• date of birth;
• gender;
• business/company name
• job title;
• profession;
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences, and asset interests;
• financial information such as credit / debit card numbers;
• asset information such as images of the assets, including videos and floorplans, prices, features, and locations;
• IP address;
• web browser type and version;
• operating system and type of device you use;
• a list of URLs starting with a referring website, your activity on our platforms including interactions and partners that you contact, and the website you exit to;

How do we use your data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times.

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

General

• registering you as a user and saving your preferences;
• distinguishing you from other users;
• providing and managing your account;
• providing and managing your access to our platforms;
• personalising and tailoring your experience on our platforms;
• supplying our products or services to you (please note that we require your personal data in order to enter into a contract with you);
• personalising and tailoring our products or services for you;
• responding to your enquiries, complaints or other communications received from you;
• communicating with you, including in connection with your asset transactions and potential asset transactions on the platforms;
• supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by using the unsubscribe link in the emails or contacting us);
• processing your payment information;
• calculating commission due to us from our third-party partners and business users;
• analysing your use of our platforms and gathering feedback to enable us to continually improve our website and your user experience.

Members

• enabling you to search our platforms for assets that may interest you and update your search criteria when required;
• linking your profile with any profiles/assets added by agents;
• enabling you to ‘favourite’ assets that are of interest to you;
• notifying you of assets that may be of interest to you, including assets that meet your search criteria or any ‘favourites’ that you have registered, and invite you to view them;
• notifying agents that you may be interested in an asset;
• ensuring any asset enquiries are transferred to the relevant agent;
• passing any offers you make to agents;
• updating you on assets you have enquired about and offers you have made;
• enabling you to communicate with agents through the platform.

Agents

• enabling you to add and manage your assets to advertise them to our members;
• enabling members to see details of assets that they may be interested in;
• enabling you to add and manage branches and agents on our platforms;
• notifying you when members express their interest in your assets.

With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message or in-app notifications with information, news and offers on our products or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Third parties whose content appears on our platforms may use third-party cookies. Please refer to the section in this policy on our use of cookies for details and more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

We keep web server logs that record information about a visitor to our website, such as IP address, browser type and operating system for approximately 30 days.  We retain the logs for this period to analyse traffic and investigate issues if something goes wrong with the website.

We may retain your personal data where it is necessary for compliance with a legal obligation, or to protect your vital interests or the vital interests of another natural person.

Where we process personal data in connection with performing a contract, we keep the data for 7 years from your last interaction with us.

Where we process registration data, we do this for as long as you are an active user of our platforms and for 7 years after this.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

How and where do we store your data?

We only keep your personal data for as long as We need to in order to use it as described in the above section, and/or for as long as we have your permission to keep it.

Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our website and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our website.

Do we share your data?

We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of our platforms including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

We may sometimes use third-party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR.

In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

What happens if our business changes hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

How can you control your data?

In addition to your rights under the GDPR, set out in this policy, when you submit personal data via our platforms, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your account).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Your right to withhold information

You may access certain areas of our platforms (such as areas of our website) without providing any data at all. However, to use all features and functions available, you may be required to submit or allow for the collection of certain data.

You may restrict our use of cookies. For more information, see the section on our use of cookies in this policy.

How can you access your data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Please contact us for more details.

Our use of cookies

Our website may place and access certain first-party cookies on your computer or device. First-party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our website and to provide and improve our products and services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our platforms, you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than us.

All cookies used by and on our website are used in accordance with current Cookie Law.

Before cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our platforms may not function fully or as intended.

Certain features of our platforms depend on cookies to function. Cookie Law deems these cookies to be “strictly necessary”. These cookies are shown in the table below. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings, but please be aware that certain features of our platforms may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party cookies may be placed on your computer or device:

and the following third-party cookies may be placed on your computer or device:

Our platforms use analytics services provided by Google and Mixpanel. Analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our platforms are used. This, in turn, enables us to improve our platforms. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our platforms, it does enable us to continually improve our platforms, making better and more useful experiences for you.

The analytics services used by our platforms use cookies to gather the required information.

The analytics services used by our platforms use the following cookies:

In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our platforms more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up to date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Contacting us

If you have any questions about our platforms or this privacy policy, please contact us by email at privacy@trovier.com.

Changes to our privacy policy

We may change this privacy policy from time to time (for example, if the law changes). Any changes will be posted on our website and you will be deemed to have accepted the terms of the privacy policy on your first use of our platforms following the alterations. We recommend that you check this page regularly to keep up to date.