InfoTrack Limited - eCOS App Privacy Policy

Introduction

This Privacy Policy relates to the business operated in the United Kingdom by InfoTrack Limited (“InfoTrack” or “we”, “our” or “us” or “Data Processor”), a company registered in England with company number 09474590 and whose registered office is at 10 John Street, London, United Kingdom, WC1N 2EB. InfoTrack understands that your privacy is of paramount importance to you and that you care about how your personal data is collected and used. InfoTrack are committed to the protection of privacy in accordance with all applicable laws (including (without limitation) the UK General Data Protection Regulation). We will only collect and process personal data in ways that are described within this Privacy Policy and in a way which is consistent with our obligations and your rights in law.

This policy (together with our terms and conditions as set out at https://www.infotrack.co.uk/terms-conditions/ (“Terms of Use”) applies to your use of the eCOS Legal mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

Any of the services accessible through the App (Services) that are available on the App site or other sites of ours (Our Sites), unless the Terms of Use states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This Privacy Policy sets out how we treat personal data that we collect from you (the “Data Controller”) or that you provide to us (including our procedures regarding the handling of personal data, including collection, use, disclosure and storage of information, as well as your rights to access and correct that information).This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

1. Controller and Processor

The Client is the data controller of your personal data on the App and Our Site and we are the data processor. Our third-party providers (as outlined below) processing such data will assume the role of sub-processor.

 

2. Information about Us

The  App and Our Sites are owned and operated by InfoTrack Limited, a limited company registered in England and Wales under company number 09474590

Registered Address:	10 John Street, London, United Kingdom, WC1N 2EB
VAT Number:	GB214140659
Data Protection Officer:	Jon Buckle
Email address:	DPO@infotrack.co.uk
Telephone number:	02071868090
Postal address:	Level 11, 91 Waterloo Road, London, SE1 8RT

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. If you are an EU Citizen you have additional rights of complaint, see below for further detail.

 

3. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in April 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App and Our Site. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App, Our Sites or the Services.

 

4. What is Personal Data and how does InfoTrack collect it?

Personal Data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal Data relates to any information about you which enables you to be identified.

Depending on your use of the  App and Our Sites, we may collect some or all of the following categories of Personal Data:

Identity Data: includes first name, last name, middle name, username (or similar identifier), company name, marital status, date of birth, gender and job title

Contact Data: includes email address, telephone number, postal and billing address(es)

Financial Data: includes bank account and payment card details.

Device Data: includes the type of mobile device being used, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser being used and time zone settings.

Content Data: includes information stored on your Device, including login information, photos, videos and digital content.

Profile Data: includes your username and password, in-App purchase history, notification settings, preferences and feedback.

Usage Data: includes details relating to your use of our App or your visits to any of Our Sites including, but not limited to, traffic data and other communication data.

Location Data: includes your current location disclosed by GPS technology

Biometric Data: includes face recognition for login purposes, voice recordings and facial images

 

5. Special Categories of personal data

As part of our Services, we offer digital identity verification checks to our clients who are law firms, conveyancers and estate agents (Client) to enable them to comply with anti-money laundering legislation.  Identity verification checks are a legal requirement in any property transaction.  As part of the digital identity verification service your personal data will be subject to cross referencing checks to establish your identity.

An element of this service involves Biometric Data which shall include processing an image of you next to other key identifiers – like your name – as shown on the identity information you provide to us. The use of biometric data is necessary for the provision of the digital identity verification and as this involves Special Categories of Personal Data we need your express consent to engage in this processing.

You provide us with this express consent by selecting “confirm consent for verification” prior to completing the identity verification task.

We do not collect any other 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 data) other than Biometric Data as outlined above. Nor do we collect any information about criminal convictions and offences.

 

6. How is personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, Biometric, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey and when you report a problem with an App, our Services, or any of Our Sites. It includes information you provide when you:

- Access the App by way of link sent by the Client;

- Logon to the workspace using a 2-Factor Authentication code sent to a mobile device – further logins can then be made via Face or Fingerprint ID;

- Digitally verify the identity and address;

- Complete property information forms;

- Digitally sign documents;

- Report a problem with the App and Our Site; and

- Contact us for technical or helpdesk support.

• Information given to us. This is information the Client who has a professional relationship with you will provide to us with Identity and Contact Data on the App and Our Site so that they can create and fulfil a workspace for the Services and so that we can make initial contact with the App user about the App and Our Site. This is in accordance with the agreement with the Client, who has warranted to seek consent from you before providing us with Identity and Contact Data.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our infotrack.co.uk/cookies for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

 

7. How we use the personal data collected?

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us on dpo@infotrack.co.uk. As we are a data processor, we will also inform the Client as the data controller of your withdrawal request.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure Our Site experience. We make sure 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

We will use your personal data where we need to comply with a legal or regulatory obligation.

 

8. Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To send you an email communication detailing how to complete the workspace for Services as requested by the Client	Identity Contact	Your consent (provided to the Client who then instructs us accordingly)
To install the App and register you as a new App user Third party: AWS, Google and Apple	Identity Contact Financial Device	Your consent
To process in-App purchases and deliver Services	Identity Contact Financial Transaction Device Location	Your consent Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App, Our Site and any Services	Identity Contact Financial Profile	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver the Services by instructing and prompting you via the App or App Site to: a.     Digitally verify your identity and address by way of submission of certain documents and taking an image of your face; b.     Complete the requested property information forms; and c.     Digitally sign the requested documents	Identity Contact Device Financial Content Profile Usage Location Biometric	Your consent Necessary for our legitimate interests (to fulfil the purpose of Our Site and to perform the Services as requested by the Client)
To enable us to collate reviews about your services	Identity Contact Device Profile	Your consent Performance of a contract with you
To manage our relationship with you including: (a) when you report an issue with the App or Our  Site to us; and (b) when you contact us for technical or helpdesk support you may require when using the App or Our Site.	Identity Contact Financial Profile	Your consent Necessary for our legitimate interests (to ensure we provide the best and secure App and/or Our Site experience through provision of support services)

 

 

9. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:

Third Party	Third Party Service and Certification	Location
GB Group Plc The Foundation, Herons Way, Chester Business Park, Chester, UK, CH4 9GB	Digital identity verification checks (ISO/IEC 27001:2013)	UK and EEA
Truelayer Ltd 1 Hardwick Street, London, UK, EC1R 4RB	Verification of funds search (ISO/IEC 27001:2013)	UK and EEA
Tink Financial Services Limited 1 Sheldon Square, London, W2 6TT	Verification of funds search (ISO27001:2013)	UK and EEA
Amazon Web Services, Inc 410 Terry Avenue North Seattle, WA 98109, United States	Cloud infrastructure (hosts our platform) (ISO/IEC 27001:2013, 27017:2015, 27018:2019, 27701:2019, 9001:2015, and CSA STAR CCM v3.0.1)	EEA
DocuSign, Inc 221 Main Street, Suite 1000, San Francisco, CA 94105	Facilitation of digital execution/signature of documents (property forms) (ISO 27001:2013, SOC 1 Type 2, SOC 2 Type 2, PCI DSS)	USA and EEA

 

10. International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will ensure that you have provided explicit consent to the proposed transfer after being informed of any potential risks.
• Where possible, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• We will conduct transfer risk assessments and data protection impact assessment where applicable to identify and minimise any risks associated with such third-party processing and transferring any personal data.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
• We shall remain responsible for the acts and omission of any such third-party processor as if they were our acts and omissions.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

11. Data Security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.  We will never ask you for your password and nor will the Client.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

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 in accordance with our instructions. We cannot, however, guarantee the absolute protection and security of your personal data stored with the use or with any third parties.

 

12. Data Retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you no longer wish to use the App and Our Site then you may request deletion of your workspace by contacting the Client or us. We will then delete any personal data we store within the App and Our Site however, any personal data already transferred to the Client will not be deleted and you will need to make a separate request to them for deletion.

 

13. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have 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.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of 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; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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.

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. 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.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at InfoTrack Limited, Level 11, 91 Waterloo Road, London, SE1 8RT or on dpo@infotrack.co.uk.

 

14. Rights of EU Citizens

As we do not have a base inside the EEA and in order to meet the requirements of Article 27 of EU GDPR, we are required to appoint a representative in the EEA.

We have appointed DataRep as our Data Protection Representative in the European Union so that you can contact them directly in your home country. DataRep has locations in each of the 27 EU countries including Norway & Iceland in the European Economic Area (EEA), so that EU Citizens are able to exercise their rights in respect of personal information.

If you are a citizen of the European Union, you will be able to raise any questions or concerns regarding how to process your personal information with DataRep. To do this, you will need to:

• Send an email to DataRep at datarequest@datarep.com and quote ‘<InfoTrack Limited>’ in the subject line of the email; or
• Contact DataRep through their online webform at www.datarep.com/data-request; or
• Send a letter with your enquiry or complaint to DataRep at the relevant address as outlined in the table below. Please note that any mail correspondence must be addressed to ‘DataRep’ and not InfoTrack Limited as the same may not be received.

 

15. Data Rep Locations

Country	Address
Austria	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium	DataRep, Rue des Colonies 11, Brussels, 1000
Bulgaria	DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia	DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus	DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic	DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic
Denmark	DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia	DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland	DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France	DataRep, 72 rue de Lessard, Rouen, 76100, France
Germany	DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece	DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece
Hungary	DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary
Iceland	DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland
Ireland	DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Italy	DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
Latvia	DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
Liechtenstein	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Lithuania	DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
Luxembourg	DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta	DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands	DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
Norway	DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
Poland	DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal	DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
Romania	DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania
Slovakia	DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia	DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain	DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
Sweden	DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden
Switzerland	DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland