We have collected information about real estate agencies which is publicly available on the internet and which may include information about you or the agency that you work for. This information may include your personal data, more specifically your name, the contact details of your agency and the property listings. If available, we include a photo of your agency or you. This information allows us to create a profile of your agency that will facilitate matching you to prospective buyers and sellers on our platform. Our legal basis is our legitimate interest in providing a professional directory and facilitating relevant matches between agents, buyers and sellers. You can ask us to correct or delete your profile information by contacting support@anyone.com.

When you decide that you want to create an account to use our platform, you must provide the information required for the services you use, which may include your name, address, email address, date of birth, phone number and payment information. We indicate which information is required; without it, we may be unable to provide the relevant service. You will also be asked to create a user name and password upon first log-in and we will verify using multi-factor authentication. If you are an agent and we have not yet created a profile of you, you can provide additional information to create such profile yourself. This information may include photo and video data, your preferences and activities on social media platforms and any other information you wish to upload.

In addition, we collect technical and usage data about how you use our website and services, including details about your device, browser and operating system. For technical monitoring, this may also include IP addresses, page and request URLs, timestamps, technical user or session identifiers, error messages, stack traces and performance measurements, depending on the features and settings in use.

Once you have created an account you can add your own content (such as listings, new properties for sale or properties which you have sold in the past) and start communicating through our platform with buyers and sellers (‘customers’), including potential new customers. When you are an agent, you or the agency that you work for shall be the controller of any such personal data that you process for operating your own business. To the extent we process this information solely on your documented instructions, we act as your processor. We act as controller for the processing purposes that we determine ourselves, as described in this Privacy Statement. When you are a buyer or seller, you can use our platform to find an agent or to buy or sell directly. We process the property information, viewing requests, offers, messages and transaction documents that you provide or generate through the features you use. Our system also uses the data you provide to facilitate relevant matches.

We do not knowingly collect any special categories of personal data about you, such as about your race or ethnicity, religious or philosophical beliefs, political preferences, your health, genetics or biometric data. Nor do we process any information about criminal convictions and offences. We also do not knowingly collect personal data relating to children, which are under 18 years old.

We use your personal data for a number of different purposes, which we have listed below. As under GDPR it is required to have a legitimate basis for each processing activity, we have added the applicable legal basis per purpose. Your personal data is used by us to:

communicate with you to a) manage our relationship with you and b) to provide our service to you which may include support and responding to any inquiries or complaints you may have. We may also contact you via e-mail in case of any relevant update to our services. Where this is necessary to perform our agreement with you, that agreement is our legal basis. Other enquiries and relationship communications are processed on the basis of our legitimate interest in responding to enquiries and managing our business relationships;

perform our services and to execute our agreement with you, so managing payments and providing you with access to the platform and its functionalities. To protect the integrity of our platform and its users, we will be verifying your identity and carry out relevant checks, including a credit check where appropriate to the service used. Our legal basis for providing the agreed services is performance of our agreement with you. Where applicable law requires identity or other checks, our legal basis is compliance with that legal obligation. Otherwise, necessary and proportionate checks are based on our legitimate interest in preventing fraud and protecting the platform and its users;

further improve the availability and functionality of our website and services, for which we use data on how we solved performance issues and includes trouble shooting and testing, support and maintenance of our system and hosting of the personal data. We use Sentry for error reporting and technical performance monitoring to identify and resolve technical problems. The use of personal data for these purposes is based on our legitimate interests in maintaining a reliable and secure platform and protecting us and our customers from fraud. Where consent is required for a monitoring feature, we obtain it before activating that feature and rely on consent for the associated processing.

comply with our contractual or regulatory obligations and to prevent or detect crime to protect our business, to investigate security incidents on our website, to secure our website against fraud, and to comply with requests from regulators and other supervisory authorities. Necessary and proportionate fraud prevention and security processing is based on our legitimate interests in protecting our business and users against fraud and security incidents. Where we process your personal data to cooperate with regulators and other supervisors, this is to comply with legal obligations that we are subject to.

to improve our services by asking you to complete surveys or respond to customer care calls and to perform market research. Our use of your personal data for these purposes is our legitimate interests, which is to gain a more profound knowledge of the market we operate in and to further grow our business;

send you newsletters about developments in the real estate market or relevant changes to our services with your consent. We may also send direct electronic marketing by email, SMS or direct social media messages with your consent or, where applicable law permits, about our own similar services to existing customers whose contact details we obtained in connection with a sale. In the latter case, we offer an opt-out when collecting the details and in every marketing message, and rely on our legitimate interest in informing existing customers about our services. You may unsubscribe or withdraw consent at any time. We may also display general or tailored online advertisements, including on social media platforms using profiles and audience segments. Where this involves processing your personal data, we rely on consent where required and otherwise on our legitimate interest in promoting our services, subject to your right to object.

Where we use cookies or similar technologies for purposes requiring consent, we ask for your consent before using them and provide information about those technologies and your choices. You can refuse optional technologies or withdraw your consent through the relevant consent controls. Technologies exempt from consent are used only within the applicable legal conditions.

We may share your personal data with the parties that we have listed here:

other platform users and transaction participants, such as buyers, sellers and agents, to the extent needed for the features and transactions you use. Information you choose to publish in a property advertisement or professional profile is accessible to the public; private messages, offers and documents are shared with the relevant participants and authorised service providers;

communications platform providers (e.g. for sending and managing email communications);

third party providers of social media platforms;

IT and system administration service providers, including data storage providers and data management platform providers, including Amazon Web Services and Sentry (Functional Software, Inc., United States), which processes diagnostic information on our behalf;

service providers such as solicitors, accountant and insurance companies;

regulators, local authorities and government bodies to comply with applicable legal or regulatory obligations or courts, parties to litigation and professional advisers where needed in connection with the establishment, exercise or defence of legal claims;

All third parties that we share your personal data with shall be required by us to respect the security of your personal data and to comply with applicable laws. Should the third party act as our processor, we ensure to have the required data processing agreements in place.

Our platform is available in multiple countries, including in the EU, Canada and the United States. This means that if you are a buyer and you are interested in buying property in another country, your personal data shall be transferred to an agent located in such other country if this agent will support you with your search. Transfers outside the European Economic Area may also occur when our service providers or their subprocessors process or access personal data abroad, including in the United States. We make such transfers only where covered by an applicable adequacy decision or another lawful transfer mechanism, including the European Commission’s Standard Contractual Clauses and any necessary supplementary safeguards. The EU–US Data Privacy Framework adequacy decision applies to eligible transfers to participating US organisations. You may request information about the safeguards and a copy of the applicable contractual safeguards at support@anyone.com.

We take reasonable measures to ensure that your personal data is secure from being used or accessed unauthorised and from being accidentally lost. These shall include technical and organisational measures which shall be appropriate taking into account among others the scope, context and purposes of processing and the risks of varying likelihood and severity for the rights of individuals.

We will retain your personal data for as long as needed to provide you our services and for you to be able to retrieve the relevant information about previous purchases or sales. When you are a buyer or seller and have not used your account for over 1 year, we will regularly send you a reminder to verify if you wish to continue the access to your account. When you are an agent and our agreement with you ends, we will keep the content that you store in your account available for ten (10) days to give you the chance to extract this data. After the ten-day period we will delete the account, the content and other personal data directly relating to your account, unless we are legally required to retain any such information for a longer period. Where payment, contract or other administrative records are subject to statutory retention obligations, we retain them for the applicable statutory period, generally seven years for basic tax records. Other personal data is deleted or anonymised when it is no longer needed, taking into account ongoing transactions, support requests, account inactivity and any legal claims or obligations. Diagnostic information, including Sentry reports, is retained only as long as needed to investigate and resolve technical issues and verify fixes, subject to the retention schedule applicable to the monitoring service, data type and plan. Backup copies are removed through the applicable backup replacement cycle.

Under the GDPR you have several rights in respect of the personal data we process of you. You have the right to ask us to confirm if and which personal data we process of you and to ask for copies of this personal data. You may also ask us to correct information that you think is inaccurate and to complete information that according to you is incomplete. In certain circumstances, you have the right to ask us to delete your personal data or to restrict our processing of your personal data. Where we rely on our legitimate interests for processing your personal data (as explained in Section 2. above), or where we use your personal data for conducting direct marketing, you have the right to object to us processing your personal data. If you object to direct marketing, we will stop processing your personal data for that purpose. Should we rely on your consent to use your personal data, you may withdraw it at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Where we process personal data you have provided to us by automated means on the basis of your consent or a contract with you, you may ask to receive it in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred directly to another controller. We will respond to your requests within one month, which period we may extend with another two months should we need more time if you have made a number of requests or if your request is complex. We will notify you of any extension and the reasons for it within the initial one-month period.

To exercise your privacy rights, ask a question or make a complaint about our processing of your personal data, you can contact us at support@anyone.com.

You can also always make a complaint to the Dutch supervisor for data protection issues, the Autoriteit Persoonsgegevens (www.autoriteitpersoonsgegevens.nl), or to the competent data protection or other supervisory authority in your country.

We may update this Privacy Statement from time to time and we will take appropriate measures to inform you of this. In any event, you will always find the latest version on our website.