Privacy Policy

Nokkel Technologies Ltd

This Privacy Notice was last updated in December 2021.

OUR CONTACT DETAILS

Nokkel Technologies Ltd

Company Number: 13149003

Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ

Email Address: hello@nokkel.app

WHO WE ARE

In this privacy notice (“Privacy Notice”), whenever you see the words ‘We’, ‘Us’ or ‘Our’, it refers to Nokkel Technologies Ltd, a company registered in England, with company number 13149003 and registered offices at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ (“Nokkel”). For the purposes of the UK GDPR (as defined in the Data Protection, Privacy and Electronic Communications Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations SI 2019/419) and to the extent relevant, the General Data Protection Regulation (Regulation (EU) 2016/679), or 'EU GDPR', (and together, “Data Protection Laws”), we are a Controller in respect of the personal information that we collect and process about you as described in this Privacy Notice. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Laws to notify you of the information contained in this Privacy Notice. We are registered with the Information Commissioner’s Office as a Controller, with registration number: ZB273169.

In this Privacy Notice references to the “Nokkel App” include all Nokkel applications and websites.

WHAT IS THE PURPOSE OF THIS DOCUMENT?

Nokkel is committed to protecting and respecting your privacy, and we value any personal data we have in our organisation. This Privacy Notice, together with any other documents referred to in it, sets out the basis on how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and the care in which it will be handled.

This Privacy Notice applies to the personal data of: (a) prospective buyers; (b) home owners; and (c) financial advisors who register with the Nokkel App.

The Nokkel App is owned and operated by Nokkel. Please see the Nokkel Terms of Use which set out the terms that apply to all individuals that become registered users of the Nokkel App.

WHAT IS PERSONAL DATA?

Personal Data (or personal information) is defined in Data Protection Laws as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

DATA PROTECTION PRINCIPLES

In order for Us to comply with Data Protection Laws, the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

BUYERS - THE TYPE OF PERSONAL INFORMATION WE COLLECT

We will collect, store and use personal information about you that relates to your engagement with us. The personal information that we collect includes the following (some of which is sensitive data relating to your financial position):

• Identity data: this comprises details about you such as your name, address, email address, phone number;
• Property data: this includes details of properties you add to your wish list or are interested in purchasing;
• Financial data: this includes your bank details and details of your financial status;
• Usage data: this is data we collect from you in connection with your usage of the Nokkel App, including data collected about the browser you use and your user behaviour; and
• Location data: this includes your location to register your interest in properties.

HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A BUYER

• Entering your details on the Nokkel App when registering for our services;
• Using the Nokkel App and our services;
• Entering your details to submit an enquiry about a property (without formally registering as a registered user of the Nokkel App);
• Contacting us with enquiries or comments by telephone, email or hard copy correspondence; and
• Via social media channels.

PROPERTY OWNERS - THE TYPE OF PERSONAL INFORMATION WE COLLECT

• Identity data: this comprises details about you such as your name, address, email address, phone number;
• Details of your property: this may include details of your house name/number, description of property, postcode and photographs of your property;
• Financial data: we may collect data relating to your payment/billing information, where you purchase any of our paid-for services;
• Usage Data: this is data we collect from you in connection with your usage of the Nokkel App, including data collected about the browser you use and your user behaviour; and
• Location Data: this includes the location of your property.

HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A HOME OWNER

• Entering your details to register your property on the Nokkel App;
• Using the Nokkel App and our services;
• Contacting us with enquiries or comments by telephone, email or hard copy correspondence; and
• Via social media channels.

FINANCIAL ADVISORS - THE TYPE OF PERSONAL INFORMATION WE COLLECT

• Identity data: this comprises details about you such as your name, address, email address, phone number. It also includes official ID documentation such as passports and driving licences where we are required by law to verify your identity (such as to make payments to you); and
• Usage Data: this is data we collect from you in connection with your usage of the Nokkel App, including data collected about the browser you use and your user behaviour.

HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A FINANCIAL ADVISOR

• Entering your details to register as a financial advisor on the Nokkel App;
• Using the Nokkel App and our services;
• Contacting us with enquiries or comments by telephone, email or hard copy correspondence; and
• Via social media channels.

SPECIAL CATEGORY PERSONAL DATA

We will not ask you to share details of any information regarded to be special category personal data under Data Protection Laws (for example, details of your race or ethnicity). If we do ever require such details, we will let you know first and we will ask for your permission before processing data of this sensitive nature.

We will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to provide it. You should be aware that it is not a condition of your contract with us that you agree to any request for permission from us.

LOCATION DATA

In order to use the location functionality when using the Nokkel App, you will be asked to turn on your location in the settings on your phone.

HOW WE WILL USE THE INFORMATION ABOUT YOU – LEGAL BASES

We must have a legal basis to process your Personal Data. In most cases the legal basis will be one of the following:

• “Consent”: we may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law, for example, in relation to our direct marketing activities including email newsletters. If we ask for your consent to process your Personal Data, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Notice.
• “Contractual Obligations”: we may require certain information from you in order to fulfil our contractual obligations and provide you with our services.
• “Legal Compliance”: we are required by law to collect and process certain types of data, such as to detect, prevent and respond to fraudulent activity or other illegal actions, or to comply with our legal obligations such as respond to legally binding requests from regulators, law enforcement authorities or other government authorities.

“Legitimate Interest”: we might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. This could include understanding how you use our services to enable us to derive knowledge that enables us to develop the services. When we process Personal Data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

MARKETING

We aim to tailor our communications and ensure you are able to ‘opt-in’ to receive the information that you want. To achieve this, we will inform you, before collecting your data, if we intend to use your data for such purposes. You can exercise your right to prevent such processing and withdraw your consent by letting us know in writing. You will always have the right to ask us not to process your personal data for marketing purposes and you can exercise your right to erasure by contacting us at: hello@nokkel.app.

SHARING DATA WITH THIRD PARTIES

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. They must only process your personal data for specified purposes and in accordance with our instructions.

We may additionally disclose your personal information to third parties for reasons including the following:

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
• In order to enforce or apply any agreements; or
• To protect the rights, property, or safety of Nokkel or others.

This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we must comply with.

We may share your personal data in connection with any proposed or actual sale of our business or assets or an investment into our business. In such circumstances we will ensure the transfer of your personal data complies with Data Protection Laws.

No other third parties have access to your personal data unless it is specifically required to meet either contractual obligations or the legitimate interests of Nokkel as defined under Article 5 of the UK GDPR.

INTERNATIONAL DATA TRANSFERS

We may share your personal data overseas from time to time. Where we do, to ensure that your personal information receives an adequate level of protection we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may enter into data sharing agreements that contain up to date standard contractual clauses.

HOW DO WE STORE YOUR PERSONAL DATA AND FOR HOW LONG?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. Once our relationship with you has come to an end, we will retain your Personal Data for a period that enables us to:

• Maintain business records for analysis and/or audit purposes
• Deal with any complaints;
• Defend or bring existing or potential legal claims in respect of our relationship with you; and
• Comply with record retention requirements under the law.

If you are a Buyer, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.

If you are a Home Owner, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.

If you are a Financial Advisor, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.

In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.

HOW YOUR PERSONAL DATA IS KEPT SECURE

To help protect the privacy of your personal data, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

While we strive to protect your personal data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

AGE LIMIT FOR OUR USERS

The Nokkel App is not intended for children and we do not knowingly collect data relating to children. You must not use the Nokkel App unless you are aged 18 or older.

COOKIES

We collect your data automatically through cookies when you visit our website, in line with cookie settings in your browser. We may collect information about your computer, operating system and browser type for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual unless you choose to complete a form. We will only collect your data through the placing of non-essential cookies with your prior consent. More information on cookies and the data they capture is available in our Cookies Policy, accessible here.

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

YOUR DATA PROTECTION RIGHTS

Under certain circumstances, by law you have certain rights.

Your right of access: you may request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Your right of rectification: you may request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Your right to erasure: you may request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Your right to object to processing: you may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

Your right to restriction of processing: you may request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Your right to data portability: you may request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please let us know in writing.

CHANGES TO THE PRIVACY NOTICE

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us at hello@nokkel.app. You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 (local rate)

Website: https://ico.org.uk/concerns