Click on any of the following sections to jump directly to that heading:
- Who We Are. 1
- The Personal Data We Collect. 1
- Cookies. 2
- How We Use Your Personal Data.. 3
- Keeping your Personal Data Safe. 4
- Storage and Retention.. 5
- Disclosing Your Personal data.. 5
- Disclosures Required by Law… 6
- Your rights. 6
- Updating this Policy. 7
We are JPS (Surveyors) Limited, a company registered in England and Wales with company no. 5017249 and registered office at Worth House Unit 32 Stanley Road, Whitefield, Manchester, M45 8QX. You may also know us by our trading name “ASSETtrail”. For the purposes of data protection law, we will be a controller of the personal data we hold about you. This means we make decisions about how and why your information is used, and have a legal duty to make sure that your rights are protected. Our data protection officer is Mark Isaacs who can be contacted by e-mailing [email protected], calling on 0161 767 8001 or in writing using the details given below.
We collect the following types of personal data:
Data you give us
You can find us at either www.JPSsurveyors.co.uk (our “Website”) or submit your details through one of our links such as notifyme.auction. You may also be able to access our Sales Platform through one of our other domains e.g. JPS.auction or www.bidspotter.co.uk (our “Sales Platform”). It doesn’t matter which web address you use, as they all point to the same Sales Platforms.
When you fill out forms on our Website or our Sales Platform, we will receive the personal data they contain. This information may be provided at the time of registering to use our Sales Platform, filling out a survey for us, concluding a transaction, subscribing to our services or requesting information about what we do. If you contact us, we may keep a record of that correspondence. We will also receive personal information about you if you make a purchase via our webshop, Amazon or eBay accounts
Details of transactions you carry out through our Sales Platform, the fulfilment of your orders, and any communications by telephone, in person or by any other means relating to those transactions will also be stored.
When you have agreed to set up a direct debit arrangement, the information you have given to us is passed to our own bank for processing according to our instructions. We do keep a copy of this. However, we will never store your card details – these are held by a third-party provider.
If you send us personal data in connection with a job application, we may keep it for up to three years in case
we decide to contact you at a later date. Finally, if you have interacted with us via social media e.g. by liking our Facebook page, or connecting with us on LinkedIn, we may notify you of forthcoming sales, events, service developments or offers.
Data we obtain about you through our work
We act as professional valuers and surveyors, typically for insolvency practitioners. As part of our work, we may obtain personal data about you from an insolvent company, if you were a customer or supplier of that insolvent company. We may use the information we obtain to contact you regarding the company e.g. if there are debts outstanding or assets in your possession.
When you visit our Website or our Sales Platform, we may collect technical data about the device you are using, including where available your IP address, operating system and browser type. This is used for system administration and to improve the look and feel of our web presence. We may also send data to our partners, sponsors or advertisers. This is statistical data in aggregated form about our users’ browsing actions and patterns, and will not allow our partners or clients to identify you from such data.
Special Category Data (also known as sensitive personal data)
We do not actively collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If we do obtain any such sensitive personal data by chance when collecting the assets of an insolvent company, we will not actively process this in any way, unless explicitly instructed to do so by an insolvency practitioner.
A cookie is a small file of letters and numbers that we store on your browser or device if you agree.
We use the following types of cookies:
- Strictly necessary cookies.
These are cookies that are required for the operation of our Website and Sales Platform. They include, for example, cookies that enable you to log into secure areas of our Website or bid on auctions.
- Analytical/performance cookies
These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website or Sales Platform. This helps us to improve the way both sites work, for example, by ensuring that users are finding what they are looking for easily.
- Social Media Sharing Buttons
We do use sharing buttons in order to make it easier for you to follow our content via your social media pages. These buttons are third-party cookies which are placed onto your device when you visit our Website. The social networks which place such cookies are Twitter and LinkedIn. Even without you clicking on the relevant sharing button, these sites are aware that you have visited our Website, and may use this information when building their profile of you, and deciding what advertisements you might like to see. You should check the respective policies of each of these social networks to see how exactly they use your personal data. This process does not involve us collecting or storing any of your personal data ourselves.
You can refuse to accept all or some cookies by modifying settings within your browser (for guidance on how to do this visit http://www.aboutcookies.org/). However, if you block strictly necessary cookies, you may be unable to access certain parts of our Website.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform a contract with you e.g. to fulfil your order when you purchase something from our Sales Platform or one of our webshops;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (see the “Legitimate Interests” section below); and
- where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in order to inform you of upcoming sales or events by e-mail where you are an individual, sole trader or unincorporated partnership. In those circumstances, you have the right to withdraw consent to marketing at any time by contacting us using the details set out in section 1 of this policy.
We may use personal data held about you in the following ways:
- Providing you with information, products or services that you request from us or which we believe would interest you in a way that is targeted and relevant. This could include but is not limited to auctions, private sales, storage services, transportation and valuations or to improve how we serve you,
- Advising you of forthcoming sales, events and services;
- Ensuring that content from our Website is presented in the most effective manner for you and for your device;
- Responding to queries you send us;
- Carrying out our obligations arising from any contracts entered into between you and us, or between us and our clients; or
- Selling or purchasing property, assets or services.
When contacting you for the above purposes we may do so by phone, post, email or other electronic means, unless you tell us otherwise.
Your data will be treated in accordance with applicable data protection law. It will not be disclosed to anyone outside of JPS, its affiliated or associated companies, and any other parties named or described in section 7 below.
We may rely on legitimate interests to process your personal data, provided that your interests do not override our own. This is particularly true where we obtain your personal data from an insolvent company as part of the insolvency process.
Where we rely on legitimate interests, these interests are:
- to keep our records updated and to study how our Website, Sales Platform and other services are used;
- to assist insolvency practitioners to carry out their legal duties;
- to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting); and
- to inform our marketing strategies around future auctions.
We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, use or disclosure of it. Electronic data and databases are stored on secure servers in the United Kingdom and we control who has access to them (using both physical and electronic means). These means include an electronic firewall and other protection measures that involve virus scanning, installation of security patches, vulnerability testing, backup and recovery planning, security audits and other steps designed to improve data protection. The server software (SSL) encrypts all the data you supply us. Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or Sales Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We cannot absolutely guarantee the security of the internet, external networks, or your own device, accordingly any online communications (e.g. information provided by email or through our Website) are at your own risk.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that any personal data transferred outside the UK or the EEA is treated securely and in accordance with applicable data protection laws.
How long we keep it
We collect and store personal data for purposes connected with our business. As such, we will only retain your personal data for as long as necessary for those purposes. We verify our records periodically and if we learn that you are no longer involved with a business that is in our database, we will erase your personal data.
We keep information which forms part of our business record for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it. We may retain certain records for longer than 6 years in a few specific cases, as set out below:
- we retain personal data about buyers of specialist items for 10 years in case we wish to enquire about the value of a similar asset in the future; and
- we retain buyer’s details for certain specialised industries in order to inform them about similar sales as they arise.
We may need to disclose your personal data to third parties. Where we do so, any such disclosure will be on the basis that these third parties are required to keep the data we give them confidential and secure, and will not use it for any other purpose than to carry out the services they are performing for us. This section sets out the circumstances in which we may disclose your personal data, and what categories of third party may receive it to process transactions, administer events or communicate with you.
We may disclose your personal information to:
- marketplaces we use to sell assets e.g. Amazon and eBay;
- Marketing fulfilment companies
- order fulfilment companies we use to send out goods when they are purchased e.g. Royal Mail; and
- website administration companies necessary to keep our IT infrastructure secure and up to date e.g. WordPress and Microsoft.
We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
We also may need to retain and disclose certain personal data about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud prevention. We will disclose this information as is required by law.
We want you to remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- where your personal data is processed on the basis of consent, the right to withdraw that consent;
- the right to confirmation as to whether or not we are holding any of your personal data and, if we are, to obtain a copy of it;
- from 25 May 2018, the right to have certain data provided to you in a portable electronic format (where technically feasible);
- the right to have inaccurate personal data rectified;
- the right to object to your personal data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
- the right to restrict how your personal data is used; and
- the right to be forgotten, which allows you to have your personal data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).
If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in section 1.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.
We may update this Policy at any time. When we do, we will post a notification on the main page of our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we hold.
This policy was last updated on 14 May 2018