Privacy Notice

This privacy notice provides information on how the Project 28 Working Group collects and processes your personal data when you visit our website.

This website is not intended for children, and we do not knowingly collect data relating to children.

1. About us

Project 28 is a cross industry working group with the goal of reducing y the time between sale agreed to exchange to  28 days for property transactions in England and Wales.  The project 28 Working Group has developed a Charter and wishes to engage the wider industry in achieving their goal.

The Project 28 Working Group is made up of different legal entities, details of which can be found here: https://propertytransactionscharter.co.uk/members/

This Privacy Notice is issued on behalf of the Project 28 Working Group by Landmark Information Group Limited who is the Controller.  When we mention Project 28, (“we”, “us” or “our”) in this privacy policy, we are referring to the Project 28 Working Group.

2. 2. What is Personal Data and how do we collect it?

Depending on your use of Our Website, we may collect some or all of the following categories of Personal Data:

• Identity Data: includes first name, last name, middle name, username (or similar identifier), company name and job title.
• Contact Data: includes email address, telephone number, and postal address.
• Technical Data: includes IP address, login data, web browser type and version, time zone, location and operating system.
• Usage Data: includes URL information about how you access and use Our Website and Our, Products and Services.
• Marketing Data: includes your preferences in receiving marketing communications from us.

You are not obliged to provide Personal Data to us, however, please be advised that in many cases, if the Personal Data we request is not provided, we may not be able to supply Our Services.

3. How we Collect Personal Data

We use different methods to collect Personal Data from and about you, including:

1. a) Collection directly from you

Most of the Personal Data we process about you comes directly from you. You may give us your name and contact details when filling in forms or corresponding with us by email, phone, mail, in person or otherwise including when you:

• subscribe to email alerts;
• buy or express an interest in Our Services (including attending an event) and;
• use our platform by visiting Our Website.

1. b) Automatic collection

We automatically collect Technical Data when you use Our Website, for example: IP address, log-in data, browser type, time zone setting, location and plug-in types when you interact with Our Website.

We also collect data through cookies. Please see our Cookie Policy for further information and details.

4. Legal Basis

The law requires us to have a legal basis for collecting and using your personal data.  We have set out below a description of all the ways we use your Personal Data and which legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

5. Marketing

We may send you marketing communications to keep you up to date about the Charter from time to time.

You may elect to opt out of receiving marketing communication by using any unsubscribe facility contained in email communications that you receive from us; or contacting us at: [email protected]

6. What about sensitive data?

We do not generally collect sensitive data (also known as Special Categories of personal data) and we request that you do not submit sensitive data to us. In the limited cases where we do collect such data, we will do this in accordance with Data Protection Laws and/or ask for your consent.

7. 7. Will we share your Personal Data with third parties?

We may share Personal Data with the following categories of recipients:

• Project 28 Working Group members

• Our third-party service providers, including our affiliated companies, IT service providers, marketing automation, solutions and analytics providers, marketing agents, Project 28 partners, professional advisors.

We may also share your Personal Data with public and governmental authorities if we are required to do so, or with third parties in connection with potential corporate or commercial transactions.

Before we share your Personal Data with any third parties, we take the necessary steps to ensure that your Personal Data will be given adequate protection in accordance with Data Protection Laws and our internal policies.

8. 8. How long will your Personal Data be retained by us?

We retain Personal Data for no longer than necessary for the purpose for which it was collected including for the purpose of satisfying any legal, regulatory or reporting requirements. We maintain specific records management and retention policies and procedures so in determining how long Personal Data information will be stored, we will consider:

• the quantity, nature and sensitivity of the Personal Data;
• the purpose(s) and use of your information both now and in the future;
• our legal, regulatory and contractual obligations; and
• what information we need to manage your relationship with us and to develop and deliver Our Services.

We continually review the Personal Data we hold and delete what is no longer required.

9. International Data Transfers

We do not process your personal data in any country outside the United Kingdom (UK).
However, certain third parties that we work with are based outside of 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 by the UK.
• 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 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.

10. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

11. Which rights do you have with respect to the processing of your Personal Data?

We want to ensure you remain in control of your Personal Data. Part of this is making sure you understand your legal rights which are as follows:

• Access: the right to make a subject access request (“SAR’’) to obtain information regarding our processing of your Personal Data and access to the Personal Data which we hold about you. *

• Correction: the right to inaccurate data rectified.
• Erasure: the right to request the deletion of your Personal Data in certain circumstances.
• Restriction: the right to object to, and request that we restrict, our processing of your Personal Data in certain circumstances.
• Transfer: the right to request transfer of your Personal Data directly to a third party where this is technically feasible.

• 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.

If you wish to exercise any of these rights, please contact us at [email protected]

12. What if you have questions or want to make a complaint?

If you have any questions regarding this Privacy Notice or any concerns or complaints regarding the way we process your personal data contact us directly so we can address your concerns promptly.

You can reach out to us via the following methods:

Email: [email protected]

We take all complaints seriously and will respond to your concerns as quickly as possible. If you are not satisfied with our response, you have the right to lodge a complaint with the ICO.  Their details can be found at http://www.ico.org.uk.

16. Updating our Privacy Policy

This Privacy Notice is updated from time to time, so we recommend you review the information on our website on a regular basis.