Privacy Policy

Introduction

This Privacy Policy relates to the business operated in the United Kingdom by Perfect Portal Limited (“Perfect Portal” or “we”, “our” or “us” or “Data Processor”), a company registered in England with company number 09287455 and whose registered office is at 10 John Street, London, United Kingdom, WC1N 2EB. Perfect Portal understands that your privacy is of paramount importance to you and that you care about how your Personal Data is collected and used. Perfect Portal are committed to the protection of privacy in accordance with all applicable laws (including (without limitation) the UK General Data Protection Regulation). We will only collect and process Personal Data in ways that are described within this Privacy Policy and in a way which is consistent with our obligations and your rights in law.

This policy (together with our terms and conditions as set out at https://www.perfectportal.co.uk/terms-conditions (“Terms of Use”) applies to your use of our Services. This policy sets out how we treat personal data that we collect from you (the “Data Controller”) or that you provide to us (including our procedures regarding the handling of personal data, including collection, use, disclosure and storage of information, as well as your rights to access and correct that information).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

The Client is the Data Controller of the personal data on Our Site and we are the data processor. Our third-party providers (as outlined below) processing such data will adopt the role of sub-processor. In our capacity as a Data Processor, we may collect personal information and data from you in order to provide our services and to meet our legal obligations. By using our website (www.perfectportal.co.uk) (“Our Website”) or ordering our Services (e.g. via Our Website, our Ordering and Delivery System, by telephone or by email) (“Ordering Methods”), or by providing any personal information to us, you are accepting and consenting to the collection, use and disclosure of your personal information as set out in this Privacy Policy. We are committed to protecting your personal data and respecting your privacy.

Definitions and Interpretation

In this privacy policy, the following words shall have the following meanings:

App” means the Application developed by Perfect Portal for our Clients who shall own the App.

Consumer” means any person acting for purposes other than their trade, business or profession.

“Data Controller”, “Data Processor”, “processing”, and “data subject” shall have the meanings given to the terms “controller” “processor”, “processing” and“ data subject” respectively in Article 4 of the GDPR. “Personal Data” means all such “personal data”, as defined in Article 4 of the GDPR, as is, or is to be, processed by the Data Processor on behalf of the Data Controller.

“Integration Partner” means the provider of your Case Management Systems which You use to access and order our Services through.

Service(s)” means the supply of services by Perfect Portal to you including but not limited to mobile applications, quoting, property searches, reports and photographs, company searches, trademarks and domain names searches and other searches from time to time and includes our instructions to a Supplier, on your behalf and the dissemination of the information subsequently provided by the Suppliers.

Sub-Processor” means any organisation, or third party appointed by the Data Processor to process the Personal Data on your behalf for the purposes of providing the Services.

Supplier” means any organisation or third party who provides data or information of any form to Perfect Portal for the purposes of providing the Services.

Information About Us

Our Website is owned and operated by Perfect Portal (UK) Limited, a limited company registered in England and Wales under company number 09287455.

Registered Address:    
10 John Street, London, WC1N 2EB
Data Protection Officer:
Daniel Ralphs
Email address:
DPO@perfectportal.co.uk
Telephone number:
01704 827 447
Postal address:
137 Fylde Road, Southport, PR9 9XP

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

What does this Policy cover?

This Privacy Policy gives you information on how Perfect Portal collects and processes your Personal Data through your use of Our Website, including any data you provide to us when purchasing a product or service from Perfect Portal Limited. Please note that Perfect Portal does not have control over how your Personal Data is collected, stored, or used by other websites and we advise you to check the privacy policies of each individual website before providing data to them.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 12 June 2023. It may change and if it does, these changes will be posted on this page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

What is Personal Data and how does Perfect Portal collect it?

Personal Data is defined by the UK GDPR as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.’

Depending on your use of Our Site, we may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: including first name, middle name, last name, username (or similar identifier), company name and job title
  • Contact Data: including email address, postal address and telephone numbers.
  • Financial Data: bank account statements and payment card details.
  • Profile Data: includes your username and password, notification settings and preferences.
  • Usage Data: includes URL information about how you access and use Our Site, products and services.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Biometric Data: includes facial images.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Perfect Portal collects the personal data you provide when you:

  • Apply to become a Client or user of our products and services
  • Use our services by logging into our system or ordering products or services from us via Our Site, by telephone, email or in other ways.
  • Enter personal data into our system about you or other third parties in connection with your use of our products and services
  • Contact us as a prospective employee or contractor of Perfect Portal.

How does Perfect Portal protect Personal Data?

Perfect Portal employ a variety of physical and technical measures to keep personal data safe to prevent unauthorised access to, use or disclosure of it. Electronic data and databases are stored on secure computer systems and we control who has access to them (using both physical and electronic means). Our staff receive data protection training, and we have a set of detailed data protection policies and procedures which personnel are required to follow when handling personal data.

We store personal data in computer storage facilities, paper-based files and other records. We take steps to protect the personal data against loss, unauthorised access, use modification or disclosure, and against other misuse. These steps include password protection and access privileges for accessing our IT system, encryption of data stored and physical access restrictions to paper files. Some of these services, such as hosting our computer file servers, are provided by third parties in the UK and we endeavour to ensure that they also have adequate privacy safeguards in place through the use of contractual measures to protect personal data.

Because transmission of information over the internet is often insecure, we do not accept responsibility for the security of information you send to or receive from us over the internet, or for any unauthorised access or use of that information by others over the internet.

Perfect Portal shall ensure that all personnel who access and/or process any of the personal data are contractually obliged to keep Personal Data confidential.

How is Personal Data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial and Marketing and Communications Data) you consent to giving us about you by filling in information on Our Site or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site.
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

Third party links

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

How to contact us or make a complaint

If you have any questions about this Privacy Policy or if you wish to make a complaint about the way we have collected, disclosed or used your personal data, please contact:

Daniel Ralphs - Perfect Portal Data Privacy Officer

We will acknowledge and investigate any complaint about the way we manage personal data as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations. We are not responsible for the privacy policies or privacy practices of the organisations we provide links to from Our Site. We suggest that you check the privacy policies and practices of those organisations.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Site or the distribution platform or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the Site also allows us to improve the Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

 

Lawful basis

We rely on the following types of lawful basis to process your personal data:

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at anytime by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity
Type of data
Lawful basis for processing
To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Third party: Xero and Stripe for payment processing
Identity
Contact
Financial Transaction
Device
Marketing and Communications
‍Location
Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to any Services

Third party: AWS, Google, Apple, Mailchimp, Zoho Corporation
Identity
Contact Financial
Profile
Marketing and Communications
Your consent

Performance of a contract with you Necessary for our legitimate interests (to keep records  updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey Third party: Mailchimp
Identity
Contact
Device
Profile
Marketing and Communications
Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our  business)
To administer and protect our business including troubleshooting, data analysis and system testing
Identity
Contact
Device
Your consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Your consent

Performance of a contract with you  
To enable us to collate reviews about your services

Third party: Review Solicitors
Identity
Contact
Device
Profile
Your consent

Performance of a contract with you

Necessary to comply with legal obligations (to meet  anti-money laundering requirements)
To enable verification of identity to meet AML/KYC legal obligations and as part of the conveyancing process.

Third party: GB Group Plc (“GBG”)
Identity
Contact
Device
Profile
Content
Biometric
Your consent

Performance of a contract with you

Necessary to comply with legal obligations (to meet anti-money laundering requirements)
To enable integration with case management systems used by you
Identity
Contact
Device
Your consent

Performance of a contract with you

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties setout below for the purposes set out in the table:

  • Internal Third Parties. Other companies in the ATI Group who are based in United Kingdom and Australia and provide IT and system administration services and undertake leadership reporting.
  • External Third Parties. Specific third parties listed in the table below.

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the following sub-processors for the purpose of providing the Services:

Third  Party
Third  Party Service and Certification
Location
GB Group Plc

The Foundation, Herons Way, Chester  Business Park, Chester, UK, CH4 9GB
Digital identity verification checks (inc. biometric data)
UK and EEA
Amazon Web Services, Inc

410 Terry Avenue North Seattle, WA  98109, United States
Cloud infrastructure (hosts our platform)

(ISO/IEC 27001:2013, 27017:2015,  27018:2019, 27701:2019, 9001:2015, and CSA STAR CCM v3.0.1)
EEA
InfoTrack Limited

10 John Street, London, United Kingdom, WC1N 2EB
Facilitation of digital verification and onboarding
UK
Reapit Ltd

3rd Floor, 67 – 74 Saffron Hill, London, EC1N 8QX
 
 
Property software system that allows agents to forward leads directly from their CRM system to Client’s portal
Global data centres are used by Reapit, there is no specific location specified on their GDPR/Privacy Policy.
Stripe, Inc

7th Floor, The Bower Warehouse, 211  Old Street, London EC1V 9NR, United Kingdom
Allows Clients to receive in-app payments from Client End Users using Apple and Google Pay

(PCI Service Provider Level 1)
Global data centres are used by Stripe, there is no specific location specified on their GDPR/Privacy Policy.
Xero

5th  Floor
‍100 Avebury Boulevard
Milton Keynes, MK9 1FH 
Cloud based accounting software used to send and process invoices

(ISO/IEC 27001:2013)
United States and New Zealand
Zoho Corporation

5 Fleet Place,  London, England, EC4M 7RD
Sales and marketing CRM software

(ISO/IEC 27001:2013, ISO27017:2015  & ISO27018)
Netherlands and Ireland
Google LLC

Belgrave House, 76  Buckingham Palace Road, London, SW1W 9TQ
Management of Client advertising campaigns

(SOC 2 Type 2, SOC 3 audited, ISO  27001, 27017, 27018 Certified)
Global data centres are used by Google, there is no specific location specified on  their GDPR/Privacy Policy.
Professional Reviews Ltd trading as Review Solicitors

167-169 Great  Portland Street, London, England, W1W 5PF
Generate additional leads and share  reviews on Client’s profile, collates Client End User feedback and ratings
Global data centres are used by Review Solicitors, there is no specific location specified on their GDPR/Privacy Policy.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Service providers: AWS, MailChimp, Xero and Zoho acting as processors based in the UK, India, New Zealand and the USA who provide IT and system administration services.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.

Marketing

Where you are a Supplier, or an existing customer, we may wish to send you details regarding:

  • new services and products offered by us;
  • details of meetings, events and seminars that may be of interest to Perfect Portal customers and clients;
  • our newsletters and other marketing

We may contact you inviting you to opt-in to receive this information. This means that you will be given the choice as to whether you want to receive these messages and will be able to select how you want to receive them (email, telephone, or post). You may opt-out of receiving direct marketing or the disclosure of your personal information for the purpose of direct marketing by:

  • contacting our Data Privacy Officer at DPO@perfectportal.co.uk;
  • by using any unsubscribe facility contained in email communications that you receive from us;
  • writing to us at Perfect Portal, 137 Fylde Road, Southport PR9 9XP.

The information we hold is never used for marketing purposes and is never marketed, rented or sold to any third parties.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, the Controller can ask us to delete data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a)       if you want us to establish the data's accuracy;

(b)       where our use of the data is unlawful but you do not want us to erase it;

(c)       where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)       you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by writing to us at Perfect Portal Ltd, 137 Fylde Road, Southport, PR9 9XP or emailing us at DPO@perfectportal.co.uk.