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 your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities 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).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Philip D Avery & Co. Limited (CRN: 05193308) trading as Avery & Co.
23 Goodlass Road, Liverpool L24 9HJ |
| Our data protection officer | Kate Avery
E – kathryn.avery@averysurveys.co.uk T – 0151 321 2000 |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
We may collect and use the following personal data about you:
- your name and contact information, including email address, postal address and telephone number and company details
- information to check and verify your identity,
- your gender, if you choose to give this to us
- location data, if you choose to give this to us
- information to enable us to undertake credit or other financial checks on you
- information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and via our website. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g.:
- sanctions screening providers (in the case of employees only);
- credit reference agencies;
- customer due diligence providers;
- from a third party with your consent, e.g. your bank or building society
- from cookies on our website—for more information on our use of cookies, please see our cookie policy which is available on our website
- via our IT systems, eg:
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
- through Quest, Gmail and Livedrive
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, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you and/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.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us |
| Conducting checks to identify our customers and verify their identity
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations |
| Updating & enhancing customer records | 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 For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to:
—existing and former customers;
|
For our legitimate interests e.g. to promote our business to existing and former customers |
| External audits and quality checks, eg for RICS or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations |
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or the processing is necessary to establish, exercise or defend legal claims.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’) and we have asked you for your consent in our terms of engagement. Where further 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 23 Goodlass Road, Liverpool L24 9HJ
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
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 or share it with other organisations for marketing purposes (except for any our successors in title).
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, e.g. payment service providers;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share personal data with external auditors, e.g. in relation to RICS accreditation and the audit of our accounts;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
- share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible or required (particularly in the case of a successor in title), 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).
We will not share your personal data with any other third party.
Where your personal data is held
Personal data may be held at our offices and those of our cloud service providers, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.
How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not keep your personal data for longer than necessary, however, you should be aware that for legal purposes, some of the information we hold must be retained for a period of up to 15 years from the date of instruction to comply with other regulations including section 14B of the Limitation Act 1980.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Further information
If you would like further information about data transferred outside the UK, please contact us or our Data Protection Officer (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| 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 (see below) |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg 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 (see below) |
| To object | The right to object:
—at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision making | 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 |
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights or the Information Commissioner’s office website https://ico.org.uk/
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right 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. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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 query or concern 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. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on [insert date] and last updated on [insert date].
We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email (admin@averysurveys.co.uk).
How to contact us
Individuals in the UK:
You can contact us and/or our Data Protection Officer 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 Officer’s contact details |
| 23 Goodlass Road, Liverpool L24 9HJ
admin@averysurveys.co.uk Liverpool: 0151 321 2000
|
Kate Avery
E: Kathryn.avery@averysurveys.co.uk T: 0151 321 3000
|
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
