Altus Group (UK) Limited of 180 Great Portland Street. London W1W 5QZ, Argus Software (UK) Limited of 91-94 Saffron Hill, London EC1N 8QP and Altus Group SARL of Luxembourg (Altus Group, we, “our”, or us) value our customers, including you (you or your) and we respect your privacy and personal information. Personal information is information about an identifiable individual (as defined by applicable privacy or data protection laws). This privacy notice (Privacy Notice) describes the kinds of information we collect, how we use it, and to whom we disclose it in the course of our commercial activities. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your Decisions About Your Personal Information” section below. It does not apply to personal information of current or former Altus Group employees to the extent that the information is directly related to the employment relationship.
We will post on our website at www.altusgroup.com (the “Website”) an updated version of this Privacy Notice when we make changes to it, together with the date of the latest revision. In addition, where required and where we have your email contact details, we will notify you of material changes to this Privacy Notice by email.
For the purposes of this Privacy Notice, ‘Products’ shall be defined as our advisory services, software and data solutions and products, research content, webinars and Website.
1. Information We Collect
Depending on the Products you use, we collect the following types of information:
(a) Business contact information: The business contact information about our customers or prospective customers and users. This information may include, without limitation, the name of business and/or individual, address, phone number, and email address. We may also obtain this information from searches conducted on public registers, such as Companies House.
(b) Account information: When you sign up for an account with us or purchase advisory services or a subscription to one of our Products, you voluntarily give us certain personal information including your name, postal address, email address, telephone number, username, and password.
(c) Asset information: To the extent that it contains personal information, information relating to (i) property sales, prices, and time on the market to generate data for Products; (ii) accounting associated with appraisals, sales, leases, operating expenses, rentals, taxes, tax assessment appeals, land uses, construction progress, construction costs, valuations, cash flows, and building specifics of Assets; (iii) Asset manager, representative, owner, seller, purchaser, landlord and tenants.
(d) Payment information: If you purchase Products directly from Altus Group or our service providers, Altus Group and third-party processors, who assist us in completing the payment for such Products, may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. When you make a purchase through our Website with your credit card, we collect your credit card information, your credit card billing address, and a mailing address where it is necessary to complete the sales transaction. Additionally, we collect information to administer, manage, and fulfill the purchases you make. For example, we collect your name, email address, account information, what is ordered, the date and time of the order, the quantity and price of the order, whether payment was made, method of payment, purchase history, and if you re-ordered. We call this type of personal information “Sales Information”.
(f) Quality assurance and customer service: Your telephone calls and emails to us and our telephone calls to you, if any, may be recorded, logged, and/or monitored for quality assurance and customer service purposes that assist in addressing your inquiries, troubleshooting, training, and analytics to identify trends and make improvements to our Products and customer service. As part of the recording and logging of the calls and emails, we will collect information such as the identity of the caller or sender of email, the date and time of the call or email, and the subject and resolution of the issue.
(h) Recruitment information: When you apply for a job with Altus Group via the Website, job portals, job boards and third-party recruiters, we will collect certain information, including but not limited to: your personal and work contact details, qualifications, CVs, application letters, employment history, education history, references, candidate assessment (including interview notes and interview video), ID documentation (including passport copy and information, driver’s license copy and information), board memberships, right to work checks.
2. Using Information We Collect
We use the personal information we collect about you:
(a) to fulfil a contract, or take steps linked to a contract, in particular, in order to: provide you with our Products, including their billing, activation, supply, maintenance, support, trouble shooting, deactivation and upgrade or update as well as resolution of disputes over Products; or enter into, and perform, an employment contract with you.
(b) where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:
• understanding and meeting your usage needs and preferences for Products notably by:
analysing, aggregating and generating data from you and others so users of our Products gain insight and recognise value on their real estate, development, building, commercial, or residential investments (collectively, Asset(s)). This insight may include how Assets compare in various aspects to similar assets, enhanced understanding of cash flows and other valuation metrics, help predicting future tax liability or assessing how much construction work has been done and associated costs on a building project;
using information collected to ensure Products are technically functioning as intended;
fulfilling or enforcing any agreements or notices that are associated with a particular Product (“Notices”); and
managing or responding to your inquiries.
• identifying the features or Products that are most valued and to identify gaps or shortfalls in Product offerings, so we can develop new Products and enhance existing ones.
• managing our business and operations, for example:
to detect, monitor, investigate, mitigate, or attempt to prevent fraud and technical or security issues, or to protect our Products and property;
to allow for business continuity and disaster recovery operations;
to enforce our legal rights;
for statistical purposes; and
for managing the recruitment process, in particular: making informed decisions on recruitment and ensuring your suitability for the role or to keep you in mind for future roles; answering your enquiries; and improving our recruitment processes and activities.
(c) to meet legal and regulatory requirements, all applicable laws and to respond to emergency situations, including:
responding to court orders, warrants or other lawful requests or legal processes;
detecting, preventing and suppressing unauthorized or detrimental use of our site or Products; or
providing emergency assistance in situations that may threaten the life or physical safety of you or others.
(d) sending you information by email and/or telephone about similar Altus Products which we think may be of interest to you. You may opt out of receiving any such emails from us by using the unsubscribe link within each email or contact us as provided below to have your contact information removed from our promotional email list.
3. Disclosure of Information
In accordance with this Privacy Notice, we will disclose your personal information:
(a) within the Altus Group member companies;
(b) to our contractors, consultants, service providers, and other third parties who require such information to assist us with establishing, maintaining, and managing our business relationship with you as necessary in relation to the Products ordered, in particular, professional services, software development, software implementation and real estate consulting services in the United Kingdom, European Union, Canada, United States, Singapore, India and Australia.
(c) to a potential acquirer in circumstances where we are contemplating a sale, merger or amalgamation or disposal of substantially all of our assets, to the extent necessary for the purposes of deciding whether to proceed with the proposed transaction and completing it;
(d) if such a sale, merger, acquisition, or disposal is completed, to the purchaser who may use and disclose your personal information only to the extent described in this Privacy Notice and allowed under applicable law; and
(e) to legal advisors, accountants, regulators to comply with law and in connection with our legal rights.
4. Your Decisions About Your Personal Information
At any time, if permitted by and subject always to the provisions of applicable data protection law, you can contact us to: stop receiving direct marketing (including, emails and hard copy materials) from us; access your personal information; where we have asked for your consent to processing, to withdraw this consent; close your account; amend your personal information, where possible, to ensure that it remains accurate, complete and up to date; erase your personal information; restrict your personal information; port your personal information; or object to some processing that is based on our legitimate interests, by writing to us or emailing us at one of the addresses provided below. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of each of our promotional emails. We undertake to honour your request within ten business days.
Please note that if you request that we erase certain of your personal information, we may no longer be able to provide you with the Products you have contracted for. For example, if you request that we erase your log-in credentials we will no longer be able to provide you with access to an online account on the Website.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you before disclosing the existence, use and disclosure of your personal information. The personal information so requested will only be used for the purpose of properly identifying you.
If you contact us about your personal information, we will respond to your request within the period required by law and at minimal cost or no cost to you in accordance with local laws.
There may be instances where we cannot comply with your request to access your rights in respect of your personal information because of exceptions contained in local laws. For example, we may need to refuse access if it would interfere with the safety, health or privacy of others, or if it would result in a breach of confidentiality.
Finally, due to judicial proceedings, to local laws respecting record retention and to appropriate and adequate corporate practices, we might not be able to comply with all requests to destroy personal information.
If we cannot comply with your request to exercise your rights in respect of your personal information, we will notify you in writing and, where applicable, provide you with the relevant sections of legislation dealing with the procedure to be followed should you wish to challenge our determination.
Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the supervisory authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
When you visit the Website or use our Products, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website or use the Products), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website or the Products, such as the links you click on. Embedded scripts are active only when you are accessing the Website or Products).
The information we collect in this manner will include details about the computer, mobile phone, or other devices used to access the Website or Products (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We use third-party web analytics services to help us analyse how visitors use the Website. We may permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you.
At present the following cookies are used on our Website or in our Products:
a. Strictly Necessary Cookies
Some cookies are essential for the operation of the Website or a Product. For example, some cookies allow us to identify registered users and ensure they can access the Website or a Product. If a registered user opts to disable these cookies, the user may not be able to access all of the content of the Website or use a Product.
b. Performance Cookies
Other cookies may be used to analyse how users use the Website or Product features and to monitor Website performance or Product performance. This allows us to provide a high quality experience by customising the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.
c. Functionality Cookies
Functionality cookies are used to allow us to remember users’ preferences and tailor the Website or Products to provide enhanced features.
d. Targeting Cookies
Targeting cookies are used to serve users with adverts, and to collect information about users’ browsing habits and usage of the Website or Products in order to make adverts more relevant to users and their interests. We may use remarketing technologies to enable third parties to display relevant and personalised ads to users through their networks. They are also used to limit the number of times users see an advert as well as help measure the effectiveness of an advertising campaign.
e. Social Media Cookies
These cookies allow users to share what they’ve been doing on the Website on social media such as Facebook and Instagram. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
f. Google Analytics
Google Analytics is a web analysis service provided by Google, Inc. We use Google Analytics to monitor how visitors use our Website and Products, to compile reports and to help us improve the Website and our Products. Please see Google’s Privacy Notice for further information on the data Google collects and how it is processed. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here.
g. Facebook Ads
We use Facebook services to deliver our ads to you during your browsing experience / whilst you are online. You can control how Facebook uses data to show you ads by turning off ads which may be based on interests and / or your relationship with specific advertisers, in your ad preference settings. For further information, please visit the various Facebook pages which allow you to learn more about Facebook ads and tracking technologies and to update your settings:
Further, by visiting the Your Online Choices link above, you can opt out from seeing Facebook’s interest-based ads and you can also use your mobile device settings to configure your advertising preferences.
On your Facebook ad preferences, you will see that ads may be delivered to you according to ‘interests’ or specific advertisers and you can manage your ad preference settings for both of these.
Please note that where you have opted out of receiving our email marketing communications via the methods described above, you may still see our non-targeted adverts whilst you are online, if your interests settings on Facebook are aligned to an audience segment (pre-defined by Facebook) which our business is also associated with. We do not control whether these ads are displayed to you. Please see the relevant links above for details on how to learn more and manage Facebook ad settings.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
Altus Group has offices and facilities in many countries around the world.
Where your personal information is transferred to the US, Singapore, Australia or India, it is transferred on the basis of standard contractual clauses; and where it is transferred to Canada, it is transferred on the basis of a European Commission Adequacy Decision.
7. Children’s Online Privacy Protection
The Products are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.
We will retain your personal information for the duration of our business relationship, or if we do not proceed with your employment application, in both cases, for as long as may be necessary or required for our legitimate business purposes to the extent permitted by applicable law, and in accordance with our Data Retention Policy. Where we no longer need your personal information, we will dispose of it in a secure manner.
9. Questions, Comments, or Complaints
If you have any questions or comments or wish to make a complaint about this Privacy Notice, or if you believe that your privacy has been breached, please feel free to contact us at email@example.com, or by delivery in person, by courier or by mail to us at UK Privacy Officer, 180 Great Portland Street, London W1W 5QZ.
If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. We request that complaints be made in writing. Our Privacy Officer deals with complaints and any complaints should be directed to our Privacy Officer at the contact details set out above. We will attempt to confirm, as appropriate and necessary, with you your understanding of the complaint and what you expect as an outcome. We will let you know whether we will conduct an investigation, the contact details of the person investigating, and the estimated completion date. After we have completed our enquiries, we will contact you to advise you of the outcome and invite your response to our conclusions. If we receive a response from you, we will take this into consideration and let you know if we have changed our view.
Effective Date: May 25, 2018