Exchange Train Ltd Privacy Policy

 

ExchangeTrain.co.uk provides an online service owned and operated by ExchangeTrain Ltd or its subsidiary companies (“ExchangeTrain”, “we” or “us”). Please take the time to review this privacy statement which explains the information that ExchangeTrain collects about you, how we use it, and your rights in relation to that information.

ExchangeTrain  Ltd of Meon House, 32 High Street, Petersfield, GU32 3JL, United Kingdom is the data controller of the personal information collected via or in connection with our websites (ExchangeTrain.co.uk) and our app (the “sites”).

What personal information do we collect about you?

We collect personal information from you when you provide it to us directly and through your use of the sites. This information may include:

  • Information you provide to us when you create an account with us, which will include your name, email address and password;
  • Information you provide when using the sites, for example your telephone number, searches, reviews and comments;
  • Any correspondence you have with Solicitors via our sites;
  • Records of your interactions with EchangeTrain (e.g. if you contact our support team). We maintain a record telephone calls to and from Solicitors made in connection with the ExchangeTrain service for quality control and training purposes;
  • Information you provide to us when you enter a competition or participate in a survey; and
  • Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our sites.

We may also receive confirmation from one of our solicitors if you instruct them, for our accounting purposes and to manage the solicitors account with us.

Solicitors and Job Applicants

This privacy statement is primarily aimed at users of our sites. However, if you work for a Solicitor with whom we partner or are applying for a job with ExchangeTrain, please read the below.

Solicitors

If you work for a solicitor with whom we partner, we will collect your business contact details as well as other information relevant to our professional relationship with you, including a photo to display on the sites. We will also maintain a record of your communications with us and with users via our sites.

We may collect information about you from you directly, from your employer, from a user of our sites, or from publicly available sources (e.g. your Solicitors websites).

We will use this information for the purposes of developing and maintaining our partnership with you. If you would like to update or delete your solicitor profile on our sites, please contact us.

Job Applicants

If you apply for a job with ExchangeTrain, we will collect and use the information you provide to us in the course of your application to assess your suitability for the position you have applied for and for other roles in the future, and to monitor diversity and equal opportunities within our recruitment process. Please note that as part of the application process, we may also collect information about you from third parties, for example recruiters, referees, or from publicly available sources (e.g. LinkedIn). Please visit our sites for more information about careers at ExchangeTrain or contact us using the details below.

 

What do we use this personal information for?

Depending on how you use our Sites, your interactions with us, and the permissions you give us, the purposes for which we use your personal information include:

  • To fulfil requests submitted via the sites and maintain your online account;
  • To contact you about your use of the sites and send your solicitor quotes;
  • Where you contact a solicitor via our sites, ExchangeTrain (or its service provider) may telephone you to confirm whether you instructed a solicitor;
  • To manage and respond to any queries or complaints to our customer service team;
  • To personalise the sites to you and show you content we think you will be most interested in, based on your account information and your history on the sites;
  • To fulfil our obligations to the solicitors we work with;
  • To improve and maintain the sites, and monitor its usage;
  • For market research, e.g. we may contact you for feedback about your experience on our sites;
  • To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so;
  • For security purposes, to investigate fraud and where necessary to protect ourselves and third parties; and
  • To comply with our legal and regulatory obligations.

Our basis for processing under UK data protection law

Generally, we rely on your consent to process the personal information collected via our sites, so that we can provide you with the services we offer; for example, when you create an account with us, browse for conveyancing or correspond with solicitors via our sites, and you ask us to send you quotes. You can withdraw your consent at any time (see ‘Storage and Deletion’ below), but if you do so we will need to delete your account and you will no longer be able to conduct any transactions via our sites.

We may also process your personal information where it is in our legitimate interests to do so, in order to maintain our sites and conduct our business. For example:

  • We conduct an analysis on our user base and the searches made via our sites;
  • We may contact you after you have used our sites to ask if you have instructed a solicitor (so that we can collect commission from the relevant party, and for our own internal research purposes); and
  • Where you or a solicitor confirm that you have instructed via the sites, we will process your personal information in order to fulfil our obligations to the solicitors we work with and collect any commission due.

We may, in order to acquire the full information needed to produce your quotes provide the selected solicitors with your details.

Marketing & Advertising

We love to communicate with our users and so, depending on your marketing preferences, we may use your personal information to send you marketing, including by email, SMS or post. Some of these messages may be tailored to you, based on your previous use of our sites.

If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting ExchangeTrain.co.uk, clicking on the ‘unsubscribe’ link in any email, or visiting ‘Settings’ in your account.

If you unsubscribe from marketing, please note we will still contact you with service messages from time to time, including to send you offers from solicitors in response to a request you make on the sites.

You may also see adverts for our sites on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to users who have visited our sites) and/or similar technologies. Where you see an ad on third-party websites or social media, this may be because we have engaged the third party or social network to show ads to our users, or others who match the demographic profile of our users. In some cases, this may involve sharing your email address with the third party or social network so that they can identify you as one of our users. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.

Who do we share this personal information with?

We share users’ personal information with third parties in the following circumstances:

  • With solicitors, to pass on your interest or specific query. Please note, the only information which they may receive from Exchange Train would be your name, email, phone number and details of your enquiry.
  • With our suppliers and service providers, for example, we use a service provider to contact you via telephone you to confirm whether you instructed a solicitor via our sites;
  • With our professional and legal advisors;
  • With third parties engaged in fraud prevention and detection;
  • With law enforcement or other governmental authorities, in response to a lawful request or court order;
  • In the event that we are involved in a merger or sale of any business assets, the personal information of our users may be disclosed to a potential customer. In this event, we will make reasonable attempts to ensure the customer will be bound by the terms of this Privacy Policy; and
  • Otherwise where we have your consent or are otherwise legally permitted to do so.

We also disclose aggregated data, which does not identify any user personally, including to third parties working in media, consumer research and the Legal Service Industry (for example, as analysis of popular solicitors in a given year).

Cookies

Our sites use cookies and similar technologies to provide certain functionality to the sites, to understand and measure its performance, and to deliver targeted advertising.

Your rights

You have certain rights in respect of your personal information, including the right to access, correct, and request the erasure of your personal information.

You also have the right to object to your personal information being used for certain purposes, including to send you marketing. See ‘Marketing’ above, for more details of how to opt-out of marketing.

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, please contact us using the details below. You are also entitled to contact the UK’s supervisory authority for data protection, the Information Commissioner’s Office, or your local supervisory authority.

Contact us

If you have any queries on any aspect of our Privacy Policy, please contact us by email at abeagrie@exchangetrain.co.uk or by post at the address below. VAT Number – 339088179