International Realty Limited (‘’United Kingdom Sotheby’s International Realty’’) gather and process your personal information in accordance with this privacy policy and in compliance with the relevant data protection Regulation and laws. This policy provides you with the necessary information regarding Sotheby’s your rights and our obligations, and explains how, why and when we process your personal data. 

By using our Service you acknowledge you have read and understood this privacy policy.

United Kingdom Sotheby’s International Realty registered office is at 48 Conduit Street, London, England, W1S 2YR and we are a company registered in England and Wales under company number 01266162. We are registered on the Information Commissioner's Office Register registration number Z6320862, and act as the data controller.  

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by email. This policy was last updated on 28 November 2023. 

This policy (together with our terms of use) sets out:

• Information we collect about you
• How we use your information
• Our promotional updates and communications
• Who we share your information with
• Where we store your information
• Public forums
• Child safety (Sotheby's website is not intended for children and we do not knowingly collect) personal data from children. 
• How we protect your information
• How long we keep your information
• Your rights
• Changes to this policy
• Contacting us

Information that we collect

United Kingdom Sotheby’s International Realty processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this policy. 

Personal data, or personal information, means any information about an individual from which that individual can be identified. Personal data does not include personal information where the identity of the individual has been removed or anonymised.

As a business we collect, use, store and transfer different types of personal data depending on who you are (for example, a client, customer, or job applicant) and how you interact with Sotheby’s. 

We may collect, use, store and transfer the following categories of personal data about you: 

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and copies of identification documents.
• Contact Data including current address, email address and telephone numbers.
• Residential Data including residential status and past addresses. 
• Financial Data including salary, payslips, bank account, payment card details and financial statements. 
• Transactional Data including details about your property requirements, details of property you have sold, purchased, let and/or rented, details of payments to and from you, and details of other related services we have provided to you. 
• Profile Data including your username and password, transactions entered into by you, your interests, preferences, feedback and survey responses. 
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical Data including internet protocol (IP) address, time zone setting and location, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
• Usage Data includes information about how you use our website, products and services. 

We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your response data to evaluate the response to a specific marketing campaign. In the event that we associate your Aggregated Data with your Personal Data to the extent that it directly or indirectly identifies you, we will treat the combined data as Personal Data, and the data will be processed and managed in accordance with this privacy policy. 

We do not collect “Sensitive Personal Information” 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, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In certain circumstances however, you may provide us with such Sensitive Personal Information, for example if you have a disability related requirement or if you provide details of your dependents, or we may receive such Sensitive Personal Information for example where it is included in a credit or referencing report. We will treat that Sensitive Personal Information as Personal Data, and it will be processed and managed in accordance with this privacy policy. 

In instances where the provision of personal data is a legal requirement or a prerequisite for the fulfilment of a contract, and an individual fails to supply such data upon request, it is important to understand the implications of this non-compliance. Under these circumstances, we are compelled to inform you that our ability to perform the contractual obligations may be hindered or rendered impossible. Consequently, we reserve the right to terminate the services being provided to you. Please be assured that if such a situation arises, we will communicate this decision to you in a timely and clear manner. This measure is a necessary step to maintain compliance with legal and contractual requirements, and to ensure the integrity and effectiveness of our services.

How we use your personal data 

United Kingdom Sotheby’s International Realty takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this policy. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. 

The purposes and reasons for processing your personal data are detailed below:

• (Article 6(1)(b) UK GDPR): Where we need to perform the contract we are about to enter into or have entered into with you or your potential landlord
• (Article 6(1)(c) UK GDPR): Where we need to comply with a legal obligation
• (Article 6(1)(f) UK GDPR): We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests

The following additional grounds may also apply where we process special category data:

• (Article 9(2)(a) UK GDPR): Explicit consent received from you  
• (Article 9(2)(e) UK GDPR): Publicly available personal data 
• (Article 9(2)(f) UK GDPR): Establishing, exercising or defending a legal claim 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email, text message or social messaging platform. 

You have the right to withdraw consent to marketing at any time by contacting us in the following ways: 

• By email: [email protected] 
• By post: FAO the Data Privacy Representative, Sotheby's International Realty Limited, 48 Conduit Street, London, England, W1S 2YR.

Purposes for which we will use your personal data 

We have set out below, the details of all the ways in which we intend to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate business interests are. 

• Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. 
• Promotional offers from us: You will receive marketing communications from us if you have requested information from us or obtained services from us and you have not opted out of receiving that marketing information. 
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 
• Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
• Unrelated purpose: If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis for our decision to use your personal data. 
• Legal purpose: Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules where this is necessary, or permitted by law. 
• Opting out: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 
• Cookies: You can set your browser to refuse all or some cookies. Please be aware that if you disable or refuse cookies, some parts of the website may become inaccessible or not function properly. 

Your right to opt out of marketing messages will not preclude you from receiving services from us or to our rights and obligations in relation to the personal data provided to us in order to receive a service from Sotheby's.

How we collect your personal data 

We use different methods to collect data from and about you including through: 

• Direct interactions. You may give us details of your identity, contact and financial data by filling in forms (including electronically submitted forms) or by corresponding with us by phone, email, post or on any communication channel that Sotheby's uses. This includes personal data you provide when you: 

⁃ Use or apply for our products or services. 

⁃ Create an account on our website. 

⁃ Subscribe to our service or publications. 

⁃ Request marketing to be sent to you. 

⁃ Enter a competition, promotion or survey. 

⁃ Give us feedback or contact us. 

• Enter or attempt to enter into a business or employment relationship with us ○ call us or participate in online web facilities, including chat bots. 
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below from technical data from the following parties:

⁃ Analytics providers such as Google based outside the UK. 

⁃ Advertising networks based inside or outside the UK. 

⁃ Search information providers based inside or outside the UK. 

⁃ Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK. 

⁃ Identity and Contact Data from data brokers or aggregators based inside or outside the UK. 

⁃ Identity and Contact Data from publicly available sources such as Companies House, the Electoral Register and the Land Registry.

Sharing and disclosing your personal information

We do not sell or otherwise disclose your personal data except as set out in this privacy policy or as indicated via the consent process at the time the data is collected. 

We may share your personal data internally within the Sotheby's Group and with external third parties that may include: 

• Landlords 
• Water and other utilities companies 
• Credit and reference agencies 
• Service providers based in the United Kingdom who provide IT, cloud, backup and system administration services. 
• Professional advisers including lawyers, accountants, finance partners and auditors based in the United Kingdom who provide legal, accounting and insurance services. 
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom including Councils (Council tax purposes) and the Land Registry.
• Tenancy Deposit Schemes and Deposit Protection Schemes. 

Third parties include those to whom or with whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

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. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 

We may also share your personal data if required by law to do so, to prevent financial or reputational loss or for investigation of suspected or actual fraudulent or illegal activities.

International transfer  

Some of our external third parties may be located outside the UK. Consequently, processing of your personal data could involve a transfer of data outside the UK. 

Whenever we transfer your personal data to a third party who may transfer it out of the UK, we aim to ensure a similar degree of protection is applied to the handling of your data by following at least one of the following safeguards: 

• 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 European Commission (Adequacy) 
• Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK (Standard Contractual Clauses for the transfer of personal data to third countries).

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, accessed, altered, disclosed or used in an unauthorised way. 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 care and confidentiality. Sotheby's has put in place procedures to address any suspected personal data breach. We will notify you and any applicable regulator of a breach, where we are legally required to do so. 

Data retention 

We will retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including whilst you use our services and for at least 6 years after the conclusion of those services for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there to be the prospect of litigation during or following our relationship with you. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) while maintaining the context for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In certain circumstances, you can ask us to delete your data. Please see below for further information. 

Your legal rights 

You have the following rights under data protection laws in relation to your personal data:

• The right to request access to your personal data. Commonly known as a “data subject access request”, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• The right to request information about the personal data we hold on you at any time. You can contact Sotheby's by email or post and we will provide you with your personal data via your preferred channel. 
• The right to request correction of the personal data that we hold about you. You have the right to request that any inaccuracies in your personal data be rectified, including the right to have incomplete personal data completed. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. 
• The right to request erasure of your personal data. You have the right to request the removal of your personal data from the Sotheby's data records. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law 

Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

• The right to 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 if 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override this right. 
• The right to request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

⁃ If you want us to establish the data’s accuracy. 

⁃ Where our use of the data is unlawful but you do not want us to erase it. ○ Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims. 

⁃ You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

• The right to request the transfer of your personal data to you or to a third party. Whenever Sotheby's processes your personal data, whether by automated means based on your consent or where done based upon your contractual agreement, you have the right to request that a copy of your data be transferred to you. This right is limited to the personal data that you have submitted to Sotheby's. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• The right to 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. Please be aware that 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. 

Our policy is designed to facilitate your access to personal data without any fees in most situations. However, we reserve the right to charge a reasonable fee or refuse requests that are clearly unfounded, repetitive, or excessive, to cover administrative costs and protect our resources. In terms of timing, we aim to respond to all legitimate data requests within one month of receipt. This period ensures accurate processing and provision of the necessary information. Should your request be complex or involve multiple queries, we may extend this timeframe by up to two additional months. In any case of a delay or the need to charge a fee, we commit to keeping you fully informed, providing clear explanations for our decisions, and maintaining open communication to ensure transparency throughout the process

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

• We may need time to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 
• You will not have to pay a processing fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request if your request is clearly unfounded, repetitive or excessive.