Introduction and General Terms

Simplify Moving Limited (“Simplify”, ‘we’, ‘our’ and ‘us’) collects, uses, and shares information about you so that we can provide you with this online portal and other services. This eWay Privacy Notice explains how we collect, use, and share your information when you use eWay, including information about the device that eWay is used on, or the eWay app is installed on, for example, your mobile phone or tablet. eWay is provided by Simplify, all services accessed via eWay are provided by Simplify, Simplify ‘s group companies or selected partners.

The law firm carrying out the relevant conveyancing transaction are the Data Controllers of the information you supply as part of your conveyancing file. Where we decide the purpose and means for which personal data you supply through this website is processed, we are the “data controllers”.

If you have any questions or comments about this privacy policy or how we use your personal data, please contact our Data Protection Officer:

The Data Protection Officer
Simplify Moving Limited
1 Frances Way
Grove Park
Enderby
Leicester
LE19 1SH
Email: dataprotection1@simplify.co.uk

The Types of Personal Data We Collect and Use

Customers

Whether or not you become a customer of one of our brands, we may use your personal data for the reasons set out below. If you become a customer, we will use it to either provide the conveyancing services to you or to fulfil our contract with you. We will collect most of the data directly, but information collected both directly and indirectly are mentioned in this statement.

• Full name and personal details including contact information (e.g. work and home address, email addresses, telephone numbers (home and work), job title and company details and comments)
• IP address/location
• Personal data about other individuals involved in the transaction. You must have their authority to provide their personal data to us and share this data protection statement with them beforehand.

Providing Your Personal Data

We will tell you if providing some personal data is optional, including asking for your consent to process it. In all other cases, you must provide your personal data to enable us to provide services to you.

Monitoring of Communications

Subject to applicable laws, we may monitor and record your calls, emails, text messages, social media messages, and other communications in relation to your dealings with us. We will do this for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of our communication systems and procedures, to check for obscene or profane content, for quality control, and staff training.

Using Your Personal Data: The Legal Basis and Purposes

We process your personal data for the following reasons:

As necessary to perform our contract with you for the relevant conveyancing service:
a) To take steps at your request prior to entering into the contract.
b) To allow you to decide whether to enter into the contract.
c)To manage and perform that contract.
d) To update your records.

As necessary for our own legitimate interests or those of other persons and organizations, for example:

a) For good governance, accounting, and managing, and auditing of our business operations.
b) To monitor emails, calls, other communications, and activities on the website.
c) For market research, analysis, and developing statistics.
d) To send you marketing communications.
e) To monitor the progress of the conveyancing service provided to you.
f) To enable satisfaction surveys to be conducted.
g) To use artificial intelligence, machine learning and trained reviewers to process information to improve our services to you, to troubleshoot and train our staff. These tools are used on data collected directly and indirectly over electronic communication, call recording and post.

As necessary to comply with a legal obligation, for example:

a) When you exercise your rights under data protection law and make request.
b) For compliance with legal and regulatory requirements and related disclosures.
c) For the establishment and defence of legal claims.
d) For activities in relation to the prevention, detection, and investigation of crime.
e) To monitor emails, calls, other communications, and activities.

Based on your consent, for example:

a) When you request us to disclose your personal data to other people or organizations, such as a company handling a claim on your behalf, or otherwise agree to disclosures.
b) When we process any special categories of personal data about you at your request (e.g., your biometric data, data concerning your health).
c) To send you marketing communications where we have asked for your consent to do so.
Please note that you are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot do certain things for you.

Who we might share your information with

Subject to applicable data protection laws, we may share your data with:

• Our group of companies which means our subsidiaries, our ultimate holding company, and its subsidiaries.
• Sub-contractors and other persons who help us provide the website, conveyancing service, and quote.
• Companies and other persons providing services to us.
• Our legal and other professional advisors, including our auditors and insurers.
• Courts, to comply with legal requirements, and for the administration of justice.
• In an emergency or to otherwise protect vital interests.
• To third parties to protect the security or integrity of our business operations.
• To third parties when we restructure or sell our business or its assets or reorganize or merge.
• Market research organizations who help to improve our services.
• Anyone else where we have your consent or as required by law.

International Transfers

Information which you provide to us is stored on our secure servers located in the UK. However, data that we collect from you may be also transferred to, or processed in, a destination outside the UK. We have operations centres in India which access, and process data and we engage some third parties that may store or process personal data outside of the UK. Where it is transferred outside the UK, we will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with our Privacy Notice. If you require further information as to where your personal data is transferred to, and the measures we have implemented to safeguard that information, please contact our Data Protection Officer by emailing Dataprotection1@simplify.co.uk

Direct Marketing Communications

If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services we can introduce from selected businesses.

You have a right to opt-out of our direct marketing communications at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication or by emailing Dataprotection1@simplify.co.uk.

Links to Websites of Other Providers/Third Parties

Please note that this data privacy policy only applies to us, and we are not responsible for, and have no control over, information that is submitted to or collected by third parties, such as those where eWay may provide links and banner advertisements to third-party sites. Since we do not control those websites, you are responsible for reviewing and abiding by the privacy policies of these third-party sites to ensure they comply with the applicable data protection regulations.

Cookies

Please refer to our cookie policy for information about cookies, what they are used for, and your rights to object to them.

How long we’ll keep your information?

Where possible, we will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for its processing and retention.

The following criteria are used to determine data retention periods for your personal data:

Retention in accordance with legal and regulatory requirements: We will retain your personal data based on our legal and regulatory requirements.
Retention in case of claims: We will retain your personal data for as long as you may bring a legal claim.
Retention in case of queries: We will retain your personal data for as long as we are legally able to do so to enable us to deal with any queries you may have.

Protecting Your Privacy

To protect the personal data collected from you by us against accidental or deliberate manipulation, loss, destruction, or the access of unauthorized persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors, and other support staff are obligated to observe confidentiality and data privacy.

Any access to your data that is stored at our company only takes place through an encrypted connection. By using the most up-to-date firewall systems, we provide the best possible protection for your data. Our website, as well as our internal case management systems and our external case management portals (Client eWay and Introducer eWay), are encrypted using an SSL/TLS (Secure Sockets Layer/Transport Layer Security) connection. SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers.

Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognize that your use of the Internet and our website is entirely at your own risk, and we have no responsibility or liability for the security of personal information transmitted via the Internet. All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorization. You must not use any false identity or email, or other network communications and you must not attempt or participate in the unauthorized entry or viewing of another user’s account or into another system.

You must not use the services and/or network systems or any part thereof for fraudulent activities, or to breach another organization’s security (cross-network hacking). You must not use any computer, computer equipment, network resources, or any services provided by us for any illegal purpose, or for accessing, receiving, or transmitting any material deemed illegal, indecent, offensive, or otherwise unacceptable under UK Law.

We will monitor network traffic from time to time for the purposes of backup and problem-solving and to ensure that you are not misusing any of the services provided to you.

Your Rights Under Applicable Data Protection Law

The right to be informed about how we are processing your personal data.

The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed.

The right to object to the processing of your personal data.

The right to restrict processing of your personal data.

The right to have your personal data erased.

The right to request access to your personal data and information about how we process it.

The right to move, copy, transfer your personal data (“data portability”).

Rights in relation to automated decision-making including profiling.

If you would like to exercise any of the above rights, please contact our Data Protection Officer in writing:

Data Protection Officer
Simplify Moving Limited
1 Frances Way
Grove Park
Leicester
LE19 1SH
Dataprotection1@simplify.co.uk

Right to Complain

You have the right to complain about Data Protection to our supervisory authority, the Information Commissioner’s Office (ICO). It has enforcement powers and can investigate compliance with data protection laws. You can contact the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk.

Changes to the Privacy Policy

This policy will be reviewed and may change from time to time as a result of further development of our website, changes to legislation, or the implementation of new technologies. We reserve the right to change this data protection information at any time with effect for the future. The revised policy will be posted on this page so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. We, therefore, recommend you read the current data protection information again from time to time.

Last updated: September 2024
Date of Next Review: September 2025