Privacy Policy

What is this policy?

This is our data protection and privacy policy. It explains who we are, and why and how we process personal data. If you are the subject of any of the personal data that we process, this policy explains what rights you have, and how to get in touch with us if you wish to.

Who are we?

We are ebrik Ltd (we, our, ebrik). Our contact and other details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy, except where this policy explains otherwise.

What do we do?

We provide an online platform and related services for use in relation to property developments so as to increase visibility between developers, building management teams, homebuyers and developers. The platform allows content relating to the development (including video, photos and other material) to be made available to those connected with the development to be kept up-to-date with the development and to see how it is progressing. The ebrik platform establishes new channels of communication and transparency along the construction, sales and home buying journey, and reduces complexity in communications between interested parties.

How do we process personal data?

How we process personal data depends on the purpose for which we obtain it and the individual to whom it relates. We will normally only process personal data relating to you if:

If personal data relating to you is contained in identification details, video, photo or other content uploaded to our platform by or on behalf of our clients, and which is processed by our clients on the platform in the course of using our platform to communicate with those involved in the relevant development.
If you are a client of ours (or you work for a client of ours)
If you provide goods or services (or if we are assessing your suitability to provide such goods or services) or you work for, or are agent for or otherwise represent, someone who supplies or is being considered as a supplier of goods or services to us or our clients. This includes if we have to provide or arrange any facilities, resources, travel, accommodation, insurance or anything else necessary to enable or assist you to provide goods or services to us or our clients.
If we wish to send you advertising, marketing or promotional material
If you browse any of our websites
If you apply for a position with us

We explain our personal data processing in more detail, below, in relation to each of these categories.

If personal data relating to you is contained in identification details, video, photos or other content processed by our clients using our platform

Purpose of processing
The primary purpose of our platform is to enable developers and others to use the platform to communicate with others involved with the development (for example, building management teams, homebuyers and other developers); as part of this, our clients are able to upload various types of content to the platform (for example, videos, photos and other material) which may contain personal data (for example, details of individuals with whom content is being shared, images of people included in the content, etc.).
In enabling our clients to do this, we will normally be acting as a processor on behalf of the relevant client, in which case any processing of your personal data by us will be solely in accordance with our client's instructions and under our client's control.

Information processed
The information relating to you that is processed will be determined by our relevant client, and will be under their control. By way of illustration, it may include your name, email address or other identifying details; your username and/or password; images of you.

Legal basis
As the controller of the relevant personal data, our client will be responsible for ensuring that there is an appropriate legal basis for the processing of your personal data.

How long we keep it
We will keep the personal data relating to you in accordance with our client's instructions and, once we are no longer providing relevant services to our client, will delete it.

If you are a client of ours, or you work for a client of ours

Purpose of processing
The purpose of the processing is to enable us to provide, and to manage and administrate the provision of, the relevant services by us to you or the person that you work for, and to communicate with you in relation to the provision of services concerned.
In the course of providing our services, we may share relevant information with third parties to the extent necessary to facilitate the provision of the relevant services to you or the person that you work for. For example, if we are engaging a third party to provide goods or services in relation to our provision of services to you, we may share your contact details with them if that is necessary to facilitate communications between you and them as part of service provision (see also other disclosures we may make, below).

Information processed

Your name.
Who you work for (if applicable).
Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
Bank account or other financial details (if you are an individual client)
Any other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the services.

Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR

How long we keep it
We keep the personal information that you give to us throughout the time during which we provide our services to you or the person that you work for, and for a reasonable period after the provision of services ends, after which we will delete it or archive it (if there is a appropriate reason to maintain an archive copy of it for future reference).

If you provide goods or services (or we are considering you as a provider of goods or service) to us or our clients

Purpose of processing
If:

You provide goods or services to us or our clients.
You work for, or are agent for or otherwise represent, someone who provides or is being considered as a provider of such goods or services.
We are assessing your suitability (or that of the person you work for) to provide such goods or services.
We may process information relating to you to enable us, our clients or other suppliers of ours or our clients to manage and administer the provision of goods or services by you or the person that you work for and to communicate with you and our client in relation to that provision. This may include (where relevant) processing any information necessary to enable us to provide or arrange any facilities, resources, travel, accommodation, insurance or anything else necessary to enable or assist you to provide goods or services to us or our clients.

Information processed

Name
Contact details (name, address, email address, phone number)
Communications sent or received
Goods or services purchased and/or delivered
Other personal details relevant to your involvement in the services being provided (for example, your CV if you are talent who is contracting to provide services)
Professional or other accreditation details.
Bank account or other financial details.

How long we keep it
We will keep the information for as long as necessary to facilitate the provision by you of the relevant goods or services and then for a period of up to 6 years afterwards, after which we will normally delete it. If we consider you, but decide not to select you, to provide such goods or services, then we will normally keep any relevant information provided by you for a period of 6 months, after which we will delete it (unless you have agreed to allow us to retain it in case, for example, we may wish to contact you in future regarding other opportunities to provide goods or services).

If we wish to send you advertising, marketing or promotional material to you

Purpose of processing
We may process your individual contact details in order to send you direct marketing material in order to advertise, market or promote our services (either to you or the person that you work for, as appropriate). We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.

Information processed

Name
Job function; department.
Work contact details (email address, phone number, address).
Personal contact details (email address, phone number, home address).
Events to which invited or which are attended.
Communications sent or received.
Use of our website (e.g. tracking data from use of our website)

Legal basis
You give consent to the processing – Article 6(1)(a) GDPR
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR

How long we keep it
We will keep the personal information for a reasonable period consistent with sending you marketing communications, after which we will either confirm that you are happy for us to continue to do so, or delete it (except to the extent we need to retain it for the so0le purpose of supressing further marketing communications to you).

If you browse any of our websites

Purpose of processing
We may collect information on your visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. We may keep a record of the content on our website that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests and which we have identified based on content you have looked at. This may involve the use of cookies, which is explained in our cookies policy.

Information processed

You name and/or other identifier
Who you work for
Your visits to our website
Content viewed by you
Links followed by you
Information downloaded by you

How long we keep it
We will kepe the information for a reasonable period and then delete it.

If you apply for a position with us

Purpose of processing
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information

Information processed

Information dependent on the position you are applying for– this will be communicated to you at the time

How long we keep it
If you are employed by us, for the duration of your employment and then for a further period of 6 years, after which the information will normally be deleted.
If you are an unsuccessful applicant, for up to 12 months after your application, after which we will delete it unless we have agreed otherwise with you.

Other disclosures of your information we may make

Where appropriate, we may disclose your personal data to third parties:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- the media, where you are participating in advertising or other marketing or promotion that is intended to be publicly disseminated;
- our auditors, legal advisors and other professional advisors or service providers;
- credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
In relation to information obtained via our website:
- our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or our safety or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where do we process personal data?

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff who are situated outside the EEA who work for us, for a company in the same group as us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of service delivery, the processing of payment details and the provision of support services.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) and that it is treated securely and in accordance with this privacy policy.
All personal data processed by us is stored securely. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

Under data protection law, you have certain rights. Your rights depend on our reason for processing your personal information.

You may request access to the personal data concerned (please see the section on obtaining access to your personal data, below).
You may request that incorrect personal data that we are processing be rectified.
In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned.
Where we are acting as a processor on behalf of a client, the client will control and be responsible for the relevant personal data and not us, so queries relating to the exercise of your rights should be directed to our client, and not to us.

If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.

How to withdraw your consent to processing

You can withdraw your consent to any relevant processing of personal data:

By emailing us at info@ebrik.co.uk.
By writing to us at the address below.

How to exercise your right of access to your personal data

You can exercise your right of access to your personal data:

By emailing us at info@ebrik.co.uk.
By writing to us at the address below.

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

Our details – contacting us

Our full details are:

ebrik Ltd
71-75 Shelton Street
London
WC2H 9JQ

A limited company registered in England with number 11398676.

Email: info@ebrik.co.uk

Updates to this policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy. This policy was last updated in June 2020.