Purpose

This privacy policy aims to give you information on how Searchmove collects and processes your personal data through your use of the main website, access consultant sites from the main website, when the iDAML service is conducted on you, when a source of funds service is requested, and when we undertake marketing activities.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

Searchmove Limited trading as iDAML, is the controller responsible for your personal data (collectively referred to as “Searchmove”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager in the following ways:

Email address: info@searchmove.co.uk

Postal address: Richardshaw Business Centre, Richardshaw Road, Grangefield Industrial Estate, Pudsey, LS28 6RW.

Telephone number: 0113 239 4805

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 on 04 February 2022. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to the Site, as well as to existing information held by us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The websites and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connection may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The information we receive depends on what you do when you visit any of our websites or use any of our services. We do not collect or retain any personal information unless you choose to provide it to us for a specific purpose.

When you visit our website, Searchmove collects and stores non-personally identifiable information such as:

• the name of the domain form which you access the Internet,
• the date and time you access our website,
• and the Internet address of the website from which you linked to our Site.

For more information on how Searchmove collects the non-personally identifiable information (as listed above), please read our Cookies Policy.

Searchmove may also use your information if you opt to receive information about Searchmove or inquire about Searchmove products. We use this information to track the number of visitors to the different pages of our website as well as make our website more convenient to users.

If you contact us, submit ideas to us or request to be contacted by a Searchmove representative, we collect the information you provide, which may include name, email address, postal address and telephone number.

When you use the iDAML service, personal data to verify your identity and money laundering status will need to be provided. This may include (but not limited to): gender, date of birth, address, full name, email address, contact number, photograph of you, real time image scan of your face, driving licence information, passport information or EU Identity Card.

When you use the source of funds service, personal data to verify the source of funds will need to be provided. This may include (but not limited to): open banking data and other financial data to create source of funds reports.

Where we carry out any marketing activities, we will rely on either your consent or the soft-opt in mechanism.

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

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have provided your consent.

For the iDAML service, we rely on your consent to process your personal data.

For the source of funds service, we rely on customer consent to process your personal data.

We may disclose your personal information for the following purposes:

1. To our Searchmove representatives to provide services to you;
2. To organisations that perform services for us or on our behalf, including, without limitation, to provide customer service; conduct research, marketing or data processing; to assist in us providing the iDAML or to provide marketing or promotional services on our behalf, to the extent that information is necessary to provide services to us;
3. To protect the website and our rights; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;
4. In the event of or in connection with the sale, merger, spin-off or other corporate reorganisation of our corporation, where the information is provided to the new controlling entity in regular course of business;
5. If required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with the rules or court relating to the production of records; and
6. If we believe in good faith that a law, regulation, rule or guideline requires it.

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 and in accordance with our instructions.  

When providing the iDAML service, some of our external third parties are either based outside of the UK, or use sub-processors that are based outside of the UK, so their processing of your personal data will involve a transfer of your personal data outside the UK.

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and
• Where we use certain service providers, we may use specific contracts approved for the use in the UK which give personal data the same protection it has in the UK.

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

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contactors 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 confidentiality.

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

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including 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 is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other mean, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us via email at info@searchmove.co.uk or call us on 0113 239 4805.

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

• Request access to your personal data: enables you to receive a copy of your personal data we hold about you and to check that we are lawfully processing it;
• Request correction of your personal data: 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: enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. Note, we may not always be able to comply 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 and there is something about your particular situation which makes you want to object to our processing on this ground as you feel it impacts 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 a compelling legitimate ground to process your information which override your rights and freedoms;
• Request restriction of processing your personal data: enables you to ask us to suspend the processing of your personal data in the following scenarios: a) to establish data accuracy; b) our use is unlawful but you don’t want us to erase; or c) you need us to hold onto the data for longer than we require it to enable you to establish, exercise or defend legal claims;
• Request transfer of your personal data: to you or a chosen third party, in a structured, commonly used, machine-readable format. Note, this right only applies to automated information you initially provided consent for us to use or where we used the information to perform a contract with you; and
• Right to withdraw consent: you exercise this right at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide you with certain products or services and will advise you if this is the case, at the time that you withdraw your consent.

If you wish to exercise any of the above rights, please contact us via email at info@searchmove.co.uk or call us on 0113 239 4805.

You will not have to pay a fee to access your personal data (or t 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 in these circumstances.

We may need to request specific information you to help us confirm your identity and to 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 try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if you request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Product and Service Information
We may, from time to time, contact you regarding products and services. If at any time you wish to be removed from our mailing list, you can email us at customerservices@searchmove.co.uk  with the word UNSUBSCRIBE in the subject header or write to us at:
Searchmove Ltd.
Richardshaw Business Centre
Richardshaw Road,
Pudsey
LS28 6 RW