This Privacy Notice is v3.0 and is valid from 00:01hrs on 1 January 2021. It replaces and supersedes all other Privacy Notices associated with SQ Property Trading Ltd.

We take your privacy very seriously. This Privacy Policy details what personal data we collect and how we shall use it.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Our Name & Contact Details.

The Data Controller of your personal data is SQ Property Trading Ltd. This means that SQ Property Trading Ltd decides how your personal data is processed and for what purposes. Our contact details are:

Email: Compliance@expressoffers.today

Web: https://www.expressoffers.today/

Telephone: 0808 196 4554

In writing: SQ Property Trading Ltd, St George's House, 56 Peter Street, Manchester M2 3NQ

Data Protection Officer Contact Details.

In observance of the UK /General Data Protection Regulation and the Data Protection Act 2018, SQ Property Trading Ltd have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing Compliance@expressoffers.today or writing to:

Data Protection Officer,

St George's House,

56 Peter Street,

Manchester,

M2 3NQ

For what purposes do we process personal data, and what are the lawful bases by which we process data?

SQ Property Trading Ltd processes your Personal Data for the following purposes:

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may use your personal data to:

• Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services, if your details were received during the course of a sale/contract and for which you have been offered a simple means to opt out of direct marketing;
• Maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
• Prevent, detect and investigate fraud;
• Prevent, detect and investigate crime;
• Fulfil our statutory or regulatory obligations;
• Reporting, analytics and product/service improvement, (including internal training);
• Resolve complaints and/or disputes;
• Improve data accuracy or completeness;
• Track your email engagement;
• Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
• Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes. Verify staff suitability and experience for employment.
• Verify eligibility to work in the UK.

What personal data do we collect?

We use various kinds of personal information, and group them together like this.

Sharing your personal data

SQ Property Trading Ltd may choose to share your personal data internally and/or externally to the business. Where we choose to share your personal data, we shall do so for the following reasons:

• Where we have your "Consent" to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to "Your Right to Withdraw Consent" section below;
• Where necessary to fulfil the services and/or products we are "Contracted" to provide to you;
• Where we have a "Legal Obligation" and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
• Where we have "Legitimate Interest" to do so, including:
  • For the purposes listed in the "What are our legitimate interests for processing your data?" section above.
  • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should SQ Property Trading Ltd establish or become part of a group.
  • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with SQ Property Trading Ltd's aim of helping their customers buy, sell and/or create the house of their dreams in a fair, lawful and transparent manner that we do not currently provide ourselves.
  • Where 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case we would contact you using Legitimate Interest to request specific Consent to share your personal.
  • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
  • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:

Selling your personal data

SQ Property Trading Ltd may choose to sell your personal data.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

Where we choose to sell your information, we shall do so in the following circumstances:

• Where we have your "Consent" to do so;
• Where we have a "Legitimate Interest" to do so, including;
• • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

International Personal Data Transfer

SQ Property Trading Ltd may transfer personal data to countries outside of the UK and/or EEA. Specifically, we use data processors based in Pakistan, Canada and the United States. If data is transferred outside of the EEA, SQ Property Trading Ltd will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the UK General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

SQ Property Trading Ltd has the following data retention policies:

• Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
• Where you have purchased, or enquired about purchasing, an SQ Property Trading Ltd product or services, we shall retain any personal details applicable to the contract delivery for a period of 15 years (name, email, telephone, postal address). During this time, we may contact you using legitimate interest to market additional products or services.
• Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number, company, job title) for a period of 7 years. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you
• Where you have signed up to receive information emails from SQ Property Trading Ltd, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 7 years, or until you withdraw your consent.

When we no longer need this information, we will erase or anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

• Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here. In most cases SQ Property Trading Ltd will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 30 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
• Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about your Right to Rectification here.
• Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. You can read more about your Right to Erasure here.
• Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about your Right to the Restriction of Processing here.
• Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. You can read more about your Right to Object to Processing here.
• Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your individual rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing Compliance@expressoffers.today or writing to:

Data Protection Officer, SQ Property Trading Ltd, St George's House, 56 Peter Street, Manchester, M2 3NQ

Automated decision-making, including profiling.

SQ Property Trading Ltd does not use currently use automated decision-making tools or profiling in the processing of your personal data.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK's Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, SQ Property Trading Ltd would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing Compliance@expressoffers.today, or writing to:

Data Protection Officer, SQ Property Trading Ltd, St George's House, 56 Peter Street, Manchester, M2 3NQ

If your complaint has not been resolved, you can lodge a complaint with the Information

Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire.
SK9 5AF.

Or by telephone on 0303 123 1113.