Privacy Policy
Effective Date: 3rd June 2025
This Privacy Policy explains how Click A Brick (“we,” “us,” or “our”) collects, uses, stores, and protects your personal data when you use our website, engage with our services, or interact with us. Your privacy is very important to us, and we are committed to protecting the personal information you share with us.
1. Who We Are
Click A Brick operates an online property auction platform, facilitating the sale and purchase of properties. For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Click A Brick acts as the data controller in respect of your personal data collected via our website and services.
Our Contact Details:
INSERT ADDRESS, EMAILS, PHONE NUMBER
2. The Personal Data We Collect
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data: Includes first name, last name, title, date of birth, gender, marital status, and copies of identification documents (e.g., passport, driving license).
- Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
- Financial Data: Includes bank account details, payment card details (though actual card numbers are typically processed by third-party payment providers, we may store transaction records), and details about the source of your funds.
- Transaction Data: Includes details about payments to and from you, and other details of products and services you have purchased from us or through our platform.
- Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data: Includes information about how you use our website and services.
- Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.
- User-Generated Content: Any information, comments, or materials you upload or post to our platform.
We do not 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 information about criminal convictions and offences, except where legally required for anti-money laundering purposes.
3. How Your Personal Data is Collected
We use different methods to collect data from and about you, including through:
- Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Apply for our services;
- Create an account on our website;
- Subscribe to our services or publications;
- Request marketing to be sent to you;
- Provide feedback or contact us.
- Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including:
- Estate Agents: Who introduce you to our services.
- Identity verification providers, such as IDYourClient.com, for anti-money laundering (AML) and ‘Know Your Customer’ (KYC) checks, which may involve checking details supplied against various databases and potentially logging a footprint on your credit file.
- Organisations involved in fraud prevention.
- Publicly available sources such as Companies House and the Electoral Register.
4. How We Use Your Personal Data
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:
- To provide our services: To register you as a new client, to process your property auction transactions, and to manage payments and fees. This includes preparing and managing Auction Contracts and bills.
- To fulfill legal obligations: To comply with anti-money laundering (AML) regulations, identity verification (KYC) requirements, and fraud prevention measures. This includes using IDYourClient.com and, for buyers, requesting confirmation of the source of all monies.
- To manage our relationship with you: Including notifying you about changes to our terms or privacy policy, responding to your queries, and providing customer support.
- To ensure platform security: To maintain a secure online environment and to prevent unauthorized access, viruses, or other harmful activities as outlined in our Terms and Conditions. This may involve disclosing your identity to law enforcement agencies in case of security breaches.
- To administer and protect our business and this website: Including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
- To deliver relevant website content and advertisements to you: And to measure or understand the effectiveness of the advertising we serve to you.
- To send you marketing communications: We may use your Identity and Contact Data to send you information which we think might be of interest to you, in line with your communication preferences. You can opt-out of these communications at any time.
- To handle user-generated content: Any content you upload to our platform may be used, reproduced, distributed, and disclosed to third parties for any purpose. We also retain the right to reveal your identity to any third party asserting that content you have posted infringes upon their intellectual property rights or right to privacy.
5. Lawful Basis for Processing
We rely on the following lawful bases to process your personal data:
- Performance of a Contract: Processing your data is necessary for the performance of a contract to which you are a party (e.g., Auction Contract) or to take steps at your request before entering into such a contract.
- Legal Obligation: Processing is necessary for compliance with a legal obligation that we are subject to (e.g., anti-money laundering regulations, fraud prevention).
- Legitimate Interests: Processing is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests. This includes improving our services, maintaining platform security, and business administration. We ensure 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.
- Consent: In certain circumstances, we may rely on your consent to process your personal data, particularly for marketing communications. You have the right to withdraw consent at any time where we are relying on consent to process your personal data.
6. Sharing Your Personal Data
We may share your personal data with the following categories of third parties:
- Internal Third Parties: Other companies within the Click A Brick group who provide IT and system administration services.
- External Third Parties:
- Estate Agents: To facilitate the auction process.
- Service providers: Acting as processors who provide IT and system administration services, payment processing, data verification (e.g., IDYourClient.com), and other business support services.
- Professional advisors: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- HM Revenue & Customs, regulators, and other authorities: Who require reporting of processing activities in certain circumstances.
- Fraud prevention agencies: With whom we may share information to protect ourselves and our clients from theft and fraud.
- Any third party to whom we may choose to sell, transfer, or merge parts of our business or our assets.
- Law enforcement agencies: In response to a valid legal request or where we believe disclosure is necessary to prevent harm.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Transfers
We store your personal data within the UK. If, in the future, we transfer your personal data outside the UK, we will 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 government.
- Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK.
8. 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
For example, we generally keep client files for a period of six years after completion of a transaction, on the understanding that we have your authority to destroy them after this period. This is for record-keeping and compliance purposes.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- 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.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details provided in Section 1.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
11. Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our website, like most professional online platforms, uses “cookies” to enhance your Browse experience and improve our services. Cookies are small text files that are placed on your device (computer, tablet, or mobile) by websites that you visit. They are widely used to make websites work more efficiently, as well as to provide information to the site owners. Specifically, we use cookies to distinguish you from other users, which helps us to remember your preferences, understand how you interact with our site, and allows us to continually refine and improve our platform for your benefit. By using our website, you agree to our use of cookies as described in this policy. For more detailed information on the types of cookies we use, their purpose, and how you can manage your cookie preferences, please refer to the sections below.
12. Changes to This Privacy Policy
We keep our Privacy Policy under regular review. Any changes we make to our Privacy Policy in the future will be posted on this page. We encourage you to review this policy periodically to stay informed about how we are protecting your information.
