Privacy Notice

Last updated: 13 July 2026

Contents

1. Introduction

This notice explains how Cooper & Tanner collects, uses, shares, retains and protects personal data when individuals interact with us, use our website, enquire about or receive our services, register for or participate in auctions, submit offers, apply for lettings, engage with our professional services, subscribe to newsletters, contact our teams, make a complaint, or apply for a role with us.

This Privacy Notice applies to personal data processed by Cooper & Tanner as a controller under the UK General Data Protection Regulation and the Data Protection Act 2018. It is intended to be read alongside any additional or more specific privacy information provided to individuals in particular circumstances, including auction terms, tenancy documentation, client engagement terms, finance broking documentation, recruitment communications, cookie notices and platform-specific information.

This Privacy Notice does not apply to employees, workers or contractors in relation to internal employment related processing. A separate employee privacy notice is provided for that purpose. This Privacy Notice does, however, apply to job applicants and recruitment candidates where they submit CVs, applications or related information to us.

2. Important information and who we are

Cooper & Tanner 1908 Limited (“Cooper & Tanner”, “we”, “us” and “our”) is the controller of the personal data described in this Privacy Notice, unless we state otherwise.

Cooper & Tanner provides a range of services, including residential sales, commercial sales and lettings, residential lettings, rural and agricultural services, valuations, development advice, professional services, land and property auctions, machinery and livestock sales, sale room auctions and associated client money, compliance and administrative services.

Where we use third-party platforms, including online bidding or property auction platforms, those providers may process personal data either as independent controllers or on our behalf as processors, depending on the circumstances. Further information about how those providers use personal data can be found in their respective privacy notices.

3. Contact Us and DPO Details

If you have any questions about this Privacy Notice or about how we use your personal data, please contact us using the details below:

Cooper & Tanner 1908 Limited

Address: The Agricultural Centre, Frome Market, Standerwick, Frome, Somerset, BA11 2QB

Email: [email protected]

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions relating to this privacy notice and our data protection practices. If you have any questions about this privacy notice, the way we handle your personal data, or if you wish to exercise your legal rights, please contact our DPO using the details below:

Name: Mr George Trippick

Email: [email protected]

Telephone: 01458 834 28

Alternatively, you may contact us at [email protected]

4. Privacy law and principles

We process personal data in accordance with the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003, and other applicable legal and regulatory requirements.

We process personal data lawfully, fairly and transparently. We collect personal data for specified, explicit and legitimate purposes, and do not use it in a manner that is incompatible with those purposes. We seek to ensure that personal data is adequate, relevant and limited to what is necessary, that it is accurate and kept up to date where required, that it is retained only for as long as necessary, and that it is protected by appropriate technical and organisational measures.

5. Scope of this Privacy Notice

This Privacy Notice applies to personal data processed in relation to buyers, sellers, bidders, online bidders, prospective purchasers, vendors, landlords, tenants, guarantors, occupiers, contractors, property viewers, auction participants, livestock and machinery clients, sale room customers, valuation clients, rural and agricultural clients, development clients, finance broking clients, website users, newsletter subscribers, complainants, professional contacts, job applicants and employees where relevant to recruitment and employment-related processing.

It also applies to individuals whose personal data is processed as part of anti-money laundering checks, customer due diligence, right to rent checks, right to work checks, safeguarding or DBS checks, complaints handling, legal claims, client money administration, regulatory record-keeping, internal governance and data subject rights handling.

6. What types of personal data do we collect?

The personal data we collect depends on the nature of your interaction with us. In line with the services we provide, we may process the following categories of personal data.

We do not intentionally collect more personal data than is necessary for the purposes described in this Privacy Notice.

7. Sensitive, special category and criminal offence data

We do not generally seek to collect special category data unless it is necessary for a particular purpose. Special category data may be processed where it is included in tenancy, employment, safeguarding, DBS, complaint, legal claim, health, accessibility, reasonable adjustment, insurance, dispute or regulatory records.

Criminal offence data may be processed where necessary and permitted by law, including in connection with DBS checks, safeguarding, certain employment checks, fraud prevention, legal claims or compliance obligations. Where we process criminal offence data, we do so only where necessary, proportionate and subject to appropriate safeguards.

We only collect personal data that is necessary for the purposes described in this Privacy Notice.

Further information is set out in Table 2: Special Category and Criminal Offence Data.

8. Children’s privacy

We do not knowingly collect personal data directly from children via our website or services, but we may process data relating to children where it is provided by parents, guardians or applicants in connection with property, tenancy or legal arrangements. Where children’s data is processed, we will take appropriate steps to ensure that the processing is lawful, fair, proportionate and subject to appropriate safeguards.

9. Where we get your personal data?

From you: we collect personal data directly from you when you contact us, complete forms, register for services, apply to bid, submit an offer, request a valuation, ask for a condition report, subscribe to a newsletter, apply for a property, instruct us, attend a viewing, participate in an auction, apply for a role, make a complaint or otherwise communicate with us.

From Third-parties: we also collect personal data from third parties where relevant, including solicitors, lenders, mortgage brokers, surveyors, referencing agencies, landlords, tenants, guarantors, contractors, professional advisers, insurers, auction platforms, online bidding platforms, AML and identity verification providers, credit reference agencies, DBS providers, The Property Ombudsman, HMRC, HM Land Registry, Defra, local authorities, courts, tribunals, regulators and publicly available sources.

Public Sources: we may get your personal data from publicly available sources such as HM Land Registry, Companies House, sanction lists or other regulatory or publicly accessible records where relevant.

Automatically: we collect personal data automatically when you use our website, online services, online bidding systems, account functions or digital communications. This may include technical, usage, cookie, device, session, security and interaction data.

10. Website, cookies, online bidding and platform processing

Our website uses cookies and similar technologies. Cookies are small text files placed on your device by websites you visit. They may be used to make websites work, improve efficiency, support user experience, store preferences and provide usage information. Cooper & Tanner’s cookie policy refers to persistent and session cookies and explains that cookies may be offered to users and can usually be managed through browser settings.

Where you interact with our website, we may process website and technical data to operate the website, recognise returning users, respond to enquiries, manage registrations, provide requested services, monitor usage, maintain security and support marketing and communication activity.

Where you participate in online auctions or online bidding, additional platform data may be processed. Cooper & Tanner’s sale room information confirms that online bidding is offered via the-saleroom.com, and that bidders register directly with that platform before a sale. Cooper & Tanner also handles absentee and telephone bidding, requiring full name, postal address, email address and contact numbers for registration.

For property auctions, Cooper & Tanner also appears through EIG’s property auction platform. EIG identifies Cooper & Tanner Auctions as property auctioneers and refers to property auctions and online auction activity.

Where third-party platforms are used, the platform provider may process technical data, login credentials, account records, passwords, password changes, authentication records, IP addresses, device data, usage data, preferences, suspicious activity logs, login attempts, online bidding records and AML screening data. Cooper & Tanner may not independently access all such technical information where it is held and controlled by the platform provider, but we may receive or use platform information necessary to administer auction participation, compliance checks, bids, sales, settlement, collections, delivery, disputes and records.

Where cookies are not strictly necessary, they are used only with your consent in accordance with the Privacy and Electronic Communications Regulations 2003. You can manage or withdraw your cookie preferences at any time through your browser settings or our cookie controls. You can see our Cookie notice here.

11. How and on what basis do we use personal data?

We process personal data for the purposes set out below and in Table 1: Lawful Basis of Processing.

• We use personal data to provide residential and commercial sales services, including seller onboarding, buyer registration, property listing creation, marketing and portal advertising, handling enquiries and leads, arranging and conducting viewings, managing offers and negotiations, progressing transactions, liaising with solicitors and other professional advisers, managing chains, facilitating mortgage and survey processes, completing transactions, maintaining records, handling fall-throughs, managing complaints and supporting legal claims.

• We use personal data to provide lettings and property management services, including landlord onboarding, tenant enquiries, viewings, applications, referencing, credit checks, affordability assessments, guarantor checks, right to rent checks, AML checks where applicable, tenancy agreement administration, deposit registration, rent collection, arrears management, inspections, maintenance requests, contractor coordination, tenant and landlord communications, possession proceedings, check-out processes, deposit returns, dispute handling and tenancy record retention.

• We use personal data to provide auction services, including buyer and seller registration, identity verification, account administration, absentee bidding, telephone bidding, online bidding, bid recording, lot management, catalogue production, condition report provision, pre-sale enquiries, sale settlement, invoicing, payment handling, collection and delivery arrangements, livestock traceability, Defra-related records, and auction history and account management.

• We use personal data to provide sale room services, including valuation enquiries, consignment and listing of items, specialist auctions for jewellery, watches, silver and collectables, condition report requests, additional images, bidding (including online, telephone and absentee), payment processing, postage and collection, and release of goods to authorised third parties on verification of identity and authority.

• We use personal data to provide rural, agricultural, valuation, development and professional advisory services, including landlord and tenant advice, rent reviews, compensation claims, subsidy applications, planning advice, diversification projects, valuation instructions, inspections, preparation of valuation reports, tax and insurance valuations, lending valuations, acquisition support, appraisals, development cost analysis, financial projections, planning assumptions and land ownership advice.

• We use personal data to provide finance broking and loan facilitation services, including client onboarding, application processing, credit assessment, affordability assessment, security assessment and liaison with lenders and finance providers.

• We use personal data to operate, manage and secure our website, online services and auction platforms, including account creation and management, authentication, password management, monitoring login activity, detecting suspicious activity, fraud prevention, device and behavioural analysis, system administration, platform functionality and performance monitoring.

• We use personal data to manage client money and financial administration in accordance with regulatory obligations, including holding and processing funds, maintaining client accounts, allocating receipts, reconciling accounts, authorising payments, managing unidentified funds, maintaining audit trails and complying with RICS client money rules and financial reporting obligations.

• We use personal data to meet compliance and regulatory obligations, including AML and KYC checks, identity verification, source of funds and source of wealth checks, sanctions screening, politically exposed person checks, ongoing monitoring, suspicious activity reporting, right to rent checks, right to work checks, safeguarding and DBS checks, tax and accounting obligations, complaints handling, data subject rights handling, audit trails, DPIAs, risk assessments and governance record keeping.

• We use personal data to establish, exercise or defend legal claims, including dispute resolution, litigation, enforcement proceedings, regulatory investigations and associated record keeping.

• We use personal data to manage recruitment processes, including applications, CVs, cover letters, interviews, assessments, references, right to work checks and onboarding processes where applicable.

• We use personal data to communicate with individuals, respond to enquiries, manage website forms, handle email and telephone communications and maintain records of interactions.

• We use personal data for marketing and customer relationship management purposes, including sending newsletters, managing subscriptions, maintaining CRM records, segmenting audiences, analysing engagement, maintaining suppression lists and promoting services to existing clients where permitted.

• We use personal data to facilitate international transactions and cross-border participation in auctions and property services where individuals are located outside the United Kingdom.

We rely on the following lawful bases:

• performance of a contract or steps prior to entering into a contract;

• compliance with legal obligations;

• legitimate interests pursued by us or a third party; and

• consent where required.

Where special category or criminal offence data is processed, we rely on the relevant UK GDPR Article 9 condition and Data Protection Act 2018 Schedule 1 condition.

Where we rely on legitimate interests, those interests include operating and administering our property, auction and professional services; managing client, bidder and customer relationships; facilitating transactions and auction participation; assessing financial suitability and risk; preventing fraud and detecting suspicious activity; maintaining the security of our website, platforms and systems; maintaining accurate records and audit trails; improving our services and user experience; and promoting our services to existing clients in accordance with applicable law. We carry out appropriate balancing tests to ensure that such interests are not overridden by the rights and freedoms of individuals.

Further detail on the specific lawful basis relied upon for each processing activity is set out in Table 1: Lawful Basis of Processing.

12. Automated decision-making and profiling

We do not carry out solely automated decision-making that produces legal or similarly significant effects within the meaning of UK GDPR.

However, we may use automated or semi-automated tools to support processing, including AML screening, sanctions checks, fraud monitoring, credit and affordability checks, tenant referencing, marketing segmentation, website analytics, cookie-based tracking, platform security monitoring and behavioural pattern analysis.

These tools support decision-making but do not replace human review where decisions have a significant effect. Where required by law, appropriate safeguards are implemented, including the ability to request human intervention.

13. With whom do we share personal data?

We may share personal data with the following categories of recipients, depending on the nature of our services and legal obligations.

Internal recipients

We may share personal data internally with authorised personnel across relevant teams, including residential sales, lettings, property management, auctions, sale rooms, rural and agricultural services, valuations, development, finance broking, compliance, accounts, HR, recruitment, legal, IT, marketing and management.

Professional advisers and service providers

We may share personal data with third parties who support the delivery of our services, including solicitors, conveyancers, surveyors, valuers, mortgage brokers, lenders, insurers, financial services providers, referencing agencies, credit reference agencies, AML and KYC providers, sanctions screening providers, DBS providers, contractors, maintenance providers, IT suppliers, website providers, CRM providers, email and marketing providers and other professional advisers.

Maintenance, emergency access and property service providers

We may share personal data with maintenance contractors, out-of-hours emergency maintenance providers, locksmiths and property access providers where this is necessary to manage repairs, maintenance, emergency access, property security, tenant safety, tenancy administration, deposit disputes or related property management services.

Property, auction and platform partners

We may share personal data with parties involved in property transactions, lettings and auctions, including buyers, sellers, landlords, tenants, guarantors, property portals, auction platforms, online bidding providers, including the-saleroom.com and EIG, and associated service providers.

Regulatory authorities and legal disclosures

We may share personal data where required or permitted by law with regulatory bodies and authorities, including HM Revenue & Customs, HM Land Registry, local authorities, Defra and livestock movement bodies, The Property Ombudsman, the Royal Institution of Chartered Surveyors (RICS), courts, tribunals, law enforcement bodies and other regulators.

We may also disclose personal data where necessary to comply with legal obligations, enforce our legal rights, respond to legal claims or proceedings, or protect the rights, property or safety of our business, clients or others.

Where third parties process personal data on our behalf, we require them to process personal data only in accordance with our instructions, maintain confidentiality and apply appropriate security measures. Where third parties act as independent controllers, they are responsible for their own compliance with data protection law.

We do not sell personal data.

14. Client money, payments and financial administration

Where Cooper & Tanner handles client money, payments, deposits, invoices or settlement sums, personal data may be processed for payment administration, client account management, ledger allocation, reconciliation, unidentified funds investigation, payment authorisation, audit and regulatory compliance. This may include names, contact details, bank details, payment records, invoice records, transaction references, client ledger information, supporting evidence and correspondence.

Client money records may be shared with banks, auditors, accountants, regulators, insurers, RICS or other appropriate parties where required for client money handling, regulatory compliance, audit, fraud prevention or legal purposes.

15. Business transfers

If Cooper & Tanner is involved in a restructuring, merger, acquisition, sale of assets or transfer of business, personal data may be transferred as part of that transaction. Where this occurs, personal data will continue to be protected in accordance with applicable data protection law.

16. International transfers

Personal data may be transferred outside the United Kingdom where this is necessary for international buyers, sellers, bidders, clients, overseas transactions, online auction platforms, cloud-hosted systems, service providers, professional advisers, or international communications.

Where personal data is transferred outside the United Kingdom to a country that does not benefit from adequacy regulations, we will ensure that appropriate safeguards are in place. These may include the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, adequacy regulations, transfer risk assessments and appropriate due diligence.

Where you access our website from outside the United Kingdom or communicate with us electronically, this may result in the transfer of personal data across international borders.

17. How do we protect personal data?

We apply appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These may include access controls, restricted permissions, authentication controls, secure systems, encryption where appropriate, logging, monitoring, audit trails, staff confidentiality obligations, supplier due diligence, contractual controls, segregation of duties, secure payment processes, secure client money procedures, secure document handling and appropriate retention and deletion processes.

Access to personal data is limited to personnel and service providers who require access for the purposes described in this Privacy Notice.

18. Links to other websites and third-party platforms

Our website may contain links to third-party websites, platforms, portals, auction systems, property websites, finance providers or associated services. We do not control third-party websites and are not responsible for their privacy practices. Individuals should review the privacy notices of third-party websites and platforms they use.

This is particularly relevant where individuals register directly with online bidding platforms, including the-saleroom.com, or use EIG or other property auction platforms.

Please note that information transmitted via the internet, including email, may not be completely secure. While we take reasonable steps to protect personal data, we cannot guarantee the security of data transmitted to us electronically.

19. How long do we keep personal data?

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, contractual, accounting, tax, property transaction, tenancy, AML, client money, safeguarding, dispute resolution and business record-keeping requirements.

Retention periods vary depending on the type of data and purpose. AML and KYC records are generally retained in accordance with applicable AML requirements. Property transaction, lettings, financial, client money, complaint and legal records may be retained for periods reflecting statutory obligations, limitation periods and regulatory requirements. Recruitment data is usually retained for a limited period after the recruitment process unless a longer period is justified or consent has been obtained for future opportunities. Website, cookie, platform and security data may be retained for shorter operational periods unless needed for investigation, fraud prevention, compliance or legal purposes.

Retention periods are determined based on the nature of the data, the purpose of processing, legal and regulatory requirements, limitation periods and business needs.

Where personal data is no longer required, it will be securely deleted, anonymised or archived in accordance with applicable retention requirements.

20. Data subject rights

Under UK data protection law, you have a number of rights in relation to your personal data.

• Right of access: You have the right to request access to the personal data we hold about you.

• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data.

• Right to erasure: You have the right to request deletion of your personal data in certain circumstances.

• Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.

• Right to object: You have the right to object to processing where we rely on legitimate interests, including for direct marketing purposes. Where you object to direct marketing, we will stop processing for that purpose.

• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time.

• Right to data portability: You have the right to request the transfer of your personal data to another organisation, where applicable.

Please exercise your rights by contacting us. Requests to exercise rights will be handled in accordance with applicable law. We will respond within the timeframes required by law, typically within one month, subject to any permitted extensions. We may need to verify your identity before processing a request. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information is available at www.ico.org.uk.

21. Marketing choices

Where permitted by law, we may contact you with information about services, properties, auctions, valuation events, newsletters or updates that may be of interest.

Marketing communications are sent in accordance with the Privacy and Electronic Communications Regulations 2003. Where required, we rely on your consent. In other cases, we rely on the “soft opt-in” rule or our legitimate interests where you are an existing client and marketing relates to similar services.

You can opt out of marketing communications at any time using unsubscribe links or by contacting us directly.

22. Complaints

If you have any concerns about how your personal data is processed, you should contact us in the first instance so that we can seek to resolve the matter.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters. Further information is available at www.ico.org.uk.

Where your complaint relates to property services, it may also be handled in accordance with our internal complaint’s procedure and, where applicable, referred to The Property Ombudsman or other relevant regulatory body.

23. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in legal requirements, business practices, services, systems or regulatory expectations.

Any updates will be published on our website. Where appropriate, we will take reasonable steps to notify individuals of material changes.

Table 1: Lawful Basis of Processing

Table 2: Special Category and Criminal Offence Data