"Agreement" means an agreement between Thirdfort and a Thirdfort Client for the provision of Thirdfort Services.
“Consumer” means an individual who has registered as a consumer via the Thirdfort App and set up a Thirdfort Consumer Account.
“Data Protection Laws” means any data protection legislation from time to time in force in the UK including the Data Protection Act 2018 or any successor legislation and (for so long as and to the extent that the law of the European Union has legal effect in the UK) the General Data Protection Regulation and any other directly applicable European Union regulation relating to privacy.
“Personal Information” means information relating to an identified or identifiable individual, including all information that is considered to be “personal data” under Data Protection Laws.
“Thirdfort App” means Thirdfort’s proprietary mobile app that enables Consumers to:
(i) upload, store and share personal ID, financial and other information;
(ii) communicate with Thirdfort Clients;
(iii) E-sign documents; and
(iv) use and benefit from such additional features and functionality that may from time be made available by Thirdfort.
“Thirdfort Client" means a client of Thirdfort which has purchased Thirdfort Services.
“Thirdfort Client Account” means an account created by a Thirdfort Client (or created by Thirdfort for the benefit of the Thirdfort Client) to enable the Thirdfort Client to purchase, access and use the Thirdfort Services.
“Thirdfort Consumer Account” means an account created by a Consumer via the Thirdfort App.
“Thirdfort Portal” means Thirdfort’s web platform that may be accessed by Thirdfort Clients at https://app.thirdfort.io/, or such other URL as Thirdfort may from time to time designate.
“Thirdfort Services” means the provision by Thirdfort of access to proprietary web applications via the Thirdfort Portal to enable Thirdfort Clients to:
(i) request and obtain ID verification reports;
(ii) request address searches on individuals’ credit files for Know Your Client (KYC) and Anti Money Laundering (AML) purposes;
(iii) collect and analyse open banking data and other financial data to create source of funds reports;
(iv) communicate with Consumers;
(v) E-sign documents; and
(vi) benefit from such additional services that may from time be made available by Thirdfort.
“Thirdfort Website” means Thirdfort’s website at https://www.thirdfort.com/, or such other URL as Thirdfort may from time to time designate.
This section applies to everyone who visits, or otherwise interacts, with the Thirdfort Website, the Thirdfort Portal or the Thirdfort App
What Personal Information does Thirdfort collect when you visit the Thirdfort Website, the Thirdfort Portal or the Thirdfort App?
When you visit the Thirdfort Website, or use the Thirdfort Portal or the Thirdfort App, we may collect and process the following information (which may include your Personal Information):
We process your Personal Information on the basis that we have a legitimate interest:
We may disclose Personal Information that we collect when you visit the Thirdfort Website, the Thirdfort Portal or the Thirdfort App to our personnel and to third party suppliers or subcontractors (including our independent consultants, data analytics providers and cloud-based data processing and hosting providers). If we share this Personal Information, we will only do so insofar as it is reasonably necessary for the purposes for which we have collected it.
Legal basis for processing Personal Information
Our legal basis for collecting and using the Personal Information will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect Personal Information from you only where:
In some cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your PersonalInformation).
Who do we share your Personal Information with?
We may disclose your Personal Information to the following categories of recipients:
How do we keep your Personal Information secure?
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could been countered via the use of the Thirdfort Website, the Thirdfort Portal or the Thirdfort App, taking into account the likelihood and severity those risks might pose to your rights and freedoms.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the Personal Information transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of the Thirdfort Website, the Thirdfort Portal and the Thirdfort App and your Personal Information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your Personal Information with us, you accept the aforesaid and provide your information at your own risk.
Your data protection rights
You have the following data protection rights:
If you wish to exercise any of the rights set out in 1 – 7 above you can do so at any time by sending us an email at email@example.com or by writing to us at Belle House,Platform 1 Victoria Station, London SW1V 1JT. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with Data Protection Laws.
Platform 1 Victoria Station,
London SW1V 1JT
Data Protection Service
You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s web site at: https://ico.org.uk/your-data-matters/
This section describes what information is collected by Thirdfort from Consumers, how that information is used by Thirdfort, and for how long Thirdfort keeps the information.
What Personal Information do we collect from Consumers?
When you set up your Thirdfort Consumer Account we will ask you to provide some or all of the following Personal Information, depending on the type of transaction that your solicitor, estate agent or other adviser (ie the Thirdfort Client) has asked us to provide:
We may also collect and process Personal Information that you provide in response to requests from your solicitor, estate agent or other adviser, including information relating to the transaction or other activities that you are involved with.
What do we do with the Personal Information that we collect from Consumers?
We will process the information that we have collected for the following purposes:
Who do we share Consumers’ Personal Information with?
We will share your Personal Information with your solicitor, estate agent or other adviser, who has purchased Thirdfort Services from us, this is the Thirdfort Client. The Thirdfort Client is likely to be the solicitor, estate agent or other adviser who requested that you download the Thirdfort App and will be named in SMS invite messages from Thirdfort. Within the Thirdfort App it is clearly indicated at the top of your tasks list which Thirdfort Client your Personal Information will be shared with. If you are sharing data with multiple Thirdfort Clients, you will see multiple task lists within the Thirdfort App giving you full control of what Personal Information is shared with each Thirdfort Client.
If your solicitor, estate agent or other adviser has purchased Thirdfort Services via one of the Thirdfort Partners listed here, then we may share your Personal Information with that Thirdfort Partner to the extent reasonably necessary in order for us to provide the Thirdfort Services.
Note that where we share your Personal Information with a credit reference agency for the purpose of carrying out an identity or credit check, the credit reference agency may keep a record of the search being made but this should not impact your credit score.
If you decide to contact us via a social media platform such as Facebook, LinkedIn or Twitter then you should be aware that you will be sharing your personal data and any information contained in your message via that social media platform. We interact with social media messaging platforms for inbound enquiries only and do not proactively share personal information with them. We endeavour to respond to social media enquiries via our other channels, typically email or over the phone.
International data transfers
Our servers are located in the European Union and the Personal Information that we collect directly from you will be stored on these servers. We may also transfer your Personal Information to one or more of our third party service providers listed here, some of which may be located outside of the EU, or operate from multiple locations (including non-EU locations). If your lawyer or other adviser is located outside the EU then we may also transfer your Personal Information to them.
There are agreements in place to ensure that any international transfers of Personal Information to our third party service providers have appropriate safeguards that meet the requirements of DataProtection Laws.
Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. Alternatively, where Personal Information is transferred to the US, many of those US third party service providers are certified under the EU-US Privacy Shield framework approved by the EuropeanCommission.
To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
To find out more about the EU-US Privacy Shield certification, please visit: https://www.privacyshield.gov/Program-Overview
If you would like to find out more about these safeguards or about our international transfer of data, please let us know by emailing us at firstname.lastname@example.org.
How long do we keep Consumers’ Personal Information?
In order to create and maintain your Thirdfort Consumer Account we retain your mobile number as a unique identifier for up to two years after you use the App. Please see the Maintaining your Thirdfort Consumer Account section below for further detail.
We will store your other Personal Information only for the period of time that is necessary to conduct the relevant checks and provide the services (the Thirdfort Services) requested by your solicitor, estate agent or other adviser(the Thirdfort Client). This period is usually less than one month. As soon as we have provided the Thirdfort Services we will within 30 days delete all your information(or remove all identifiers from the information so that it no longer contains any Personal Information) other than your mobile number.
If the process takes longer than usual and we hold any of your PersonalInformation (other than your mobile number) for six months from the date on which you provided the data, we will notify you and ask for your permission via the Thirdfort App to hold the information for a further six months in order to continue providing the Thirdfort Services to the Thirdfort Client.
Maintaining your Thirdfort Consumer Account
We retain your mobile number so that we can identify you if you decide to use the Thirdfort App for another property transaction or other legal matter after you have completed your initial transaction and we have deleted all your other PersonalInformation. If you do not use the Thirdfort App for a period of two years following the deletion of all your other Personal Information, we will also delete your mobile number and stop maintaining your Thirdfort Consumer Account.
Local device storage feature
After we have provided the Thirdfort Services to the Thirdfort Client and deleted all your data (apart from your mobile number) on our systems, the Thirdfort App automatically continues to stores the data on your mobile device. Note that the data stored on your device is not accessible by Thirdfort. This enables you to reuse this data via the Thirdfort app if you need to provide it to another solicitor, agent or other adviser in relation to a different transaction or other legal matter. In practice this means that you do not have to to rekey the data the next time you need it.
In order for us to enable you to reuse your data this way we must maintain your Thirdfort Consumer Account, for which we need to retain your mobile number to use as a unique identifier or username. To access data stored on your device via the Thirdfort App you must use the same mobile number (user-ID) and device (device-ID)as when the data was originally saved. We then combine your user-ID and device-ID to create a unique encryption key which can access and upload the data stored on your device. This is a security feature to prevent someone else borrowing your mobile device and logging into another Thirdfort account via your app and thereby accessing your data.
If you do not want to use this local device storage feature, you can delete your Thirdfort Consumer Account at any time. We will then stop maintaining you Thirdfort Consumer Account and within30 days permanently delete your mobile number. You can also uninstall the Thirdfort App (and delete the associated app data) to delete the data stored on your device. If we delete your mobile number and you then wish to create a new Thirdfort Consumer Account with the same mobile number, we will generate a new user-ID. We will not recognise your previous user-ID which means you will not have the unique encryption key to be able to reuse the data stored on your device.
This section describes what information is collected by Thirdfort from Thirdfort Clients, how that information is used by Thirdfort, and for how long Thirdfort retains the information.
What Personal Information do we collect from Thirdfort Clients?
During the on-boarding process we will collect the following Personal Information:
We will also collect Personal Information that you provide to us in connection with the Thirdfort Services. For all Thirdfort Services other than Lite ID this will typically be your client’s name and mobile phone number and a brief transaction description for us to use as an identifier. For Lite ID, we will collect your client’s name, address and date of birth.
What do we do with the Personal Information that we collect from Thirdfort Clients?
We will use the information that you provide during the on-boarding process for the following purposes:
If you provide us with Personal Information relating to your client in connection with the Thirdfort Services:
Who do we share Thirdfort Clients’ Personal Information with?
Third party service providers that we engage for the purposes of collecting, exporting, storing and otherwise processing our data, including your Personal Information, are listed here.
How long do we keep your Personal Information?
As stated above, Personal Information relating to your client that you provide to us in connection with the Thirdfort Services is deleted on completion of those relevant Thirdfort Services.