Privacy notice for business contacts

If you have been contacted by CRE Communications Limited about telecoms, broadband or IT services and you did not give us your details yourself, this notice explains where we got them, what we do with them, and how to make us stop.

Who we are

CRE Communications Limited is the data controller for this information.

Address: Unit 17 Lloyds Court, Manor Royal, Crawley, RH10 9QU

Email: privacy@cregroup.co.uk

Telephone: 01903 952733

ICO registration number: ZC078436

What information we hold

We hold business contact information about people who work at UK estate agency, lettings and property management firms. Depending on the record, this may include:

your name and job title
your business telephone number and business email address
the name, address and website of the business you work for
information filed publicly about you as a company director - for example your name as it appears on the register, and your directorship of that company
information about the business itself, such as its company number, incorporation date, filed accounts, branch network and the software and communications platforms it appears to use

We do not hold any special category data about you - nothing about health, beliefs, political opinions, ethnicity, sexual orientation, trade union membership, genetics or biometrics. We do not hold criminal offence data.

Where we got it

We did not obtain this information from you. It came from the following sources, all of which are publicly accessible or commercially available:

Source

What we took from it

Companies House - the public register of UK companies

Company number, registered office, incorporation date, company status, filed accounts and the names of current directors

Your employer’s website

Named staff and their job titles where published, contact email addresses, office addresses

Property portals - Rightmove, OnTheMarket and similar public branch listings

Branch names, addresses and telephone numbers

Ofcom’s National Numbering Plan

Which communications provider holds a telephone number range. This is information about the number, not about you

The Royal Mail postcode register

Verification that an address exists

Publicly published DNS records

The email platform a business domain uses. This is information about the domain, not about you

Commercially available business contact lists

Business contact details, where purchased from a supplier

Business contact databases such as Apollo/Clay

Names and job titles of senior staff at larger groups

We also combine and cross-check these sources against one another to correct errors, and we record which source each piece of information came from.

Why we hold it, and our lawful basis

We use it for one purpose: to contact businesses about telecoms, broadband and IT services we think may be relevant to them.

Our lawful basis is legitimate interests - UK GDPR Article 6(1)(f). The legitimate interest is our interest in marketing our services to businesses that are likely to need them, and the interest of those businesses in hearing about options relevant to them. We have carried out a legitimate interests assessment weighing that against your rights and freedoms, and you can ask us for a summary of it using the contact details above.

We consider the impact on you to be low, because:

the information is business contact information, used to contact you in your professional capacity, not your private life
almost all of it is already published - by you, your employer, or on a public register
we do not build profiles about you as an individual, and we make no automated decisions about you
you can stop it completely at any time, and we will

Who we share it with

We use third-party service providers who process this information on our behalf:

Zoho Corporation - our customer relationship management system
Clay - data verification and enrichment
Instantly - sending business communications

Each of these is bound by a written contract requiring them to process the information only on our instructions and to keep it secure. Some of them are based outside the UK; where that is the case we rely on the UK International Data Transfer Addendum to protect the information.

We do not sell or rent your information to anyone.

How long we keep it

We keep prospect records for 24 months from the last meaningful contact, and review them annually. If you tell us you are not interested, we delete the marketing record but keep a minimal suppression entry - your name, business and contact details - indefinitely, so that we do not contact you again by mistake.

That suppression record is used for no other purpose.

Fuller detail is in our retention policy, available on request.

Your rights

You have the right to:

Object to this processing. For direct marketing this right is absolute. If you object, we must stop, and we will. There is no balancing test and nothing for you to justify.
Ask what we hold about you and get a copy.
Have inaccurate information corrected. Some of what we hold is inferred rather than confirmed, so please do tell us if something is wrong.
Ask us to delete it.
Ask us to restrict what we do with it.
Complain to us directly. We will acknowledge your complaint within 30 days and resolve it without undue delay.
Complain to the Information Commissioner’s Office at ico.org.uk or 0303 123 1113. You can do this at any time, and you do not have to complain to us first.