1. I N T R O D U C T I O N
- what information we collect;
- how we use that information;
- how this information is shared; and
- your rights;
We hope you take the time to read this policy. It is important to check for updates to this policy to ensure that the information reflects the most up to date version. The latest update version is identified in section 16 of this document.
2. WHO IS THE DATA CONTROLLER?
The Data Controller is Select Property Management & Lettings, Karibu, La Collinette, Route Orange, St Brelade, JE3 8GP, Jersey.
3. THE DATA PROTECTION OFFICER
Select Property Management & Lettings has appointed a Data Protection Officer (DPO). Richard D’Ulivo-Rogers, Director, will be your initial point of contact if you wish to exercise your rights. You can contact our DPO at email@example.com
4. WEBSITE VISITORS
Like most website operators, we collect non-personally identifying information of the sort that web browsers and servers typically make available such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personally identifying information is to better understand how visitors use our website.
We also collect potentially personally identifying information like Internet Protocol (IP) addresses for users completing forms on our website. We only disclose logged in user IP addresses under the same circumstances that we use and disclose personally identifying information as described below.
We may also collect statistics about the behaviour of visitors to our website. For instance, we may monitor the most popular pages on the site. We do not display this information publicly or provide it to others.
5. COOKIE COLLECTION
A cookie is a small text file that may be stored on your computer or mobile device that contains data related to a website you visit. It may allow a website to “remember” your actions or preferences over a period of time, or it may contain data related to the function or delivery of the site and which are deleted the moment you move away from the website. These are known as “persistent” and “session” Cookies.
6. THIRD PARTY COOKIES USED ON THIS SITE
Created by other websites. A site you visit can embed content from other sites, for example images, ads and text. Any of these sites can save cookies and other data to personalize your experience. Google Analytics is used on this site. It collects information entirely anonymously and reports website trends without identifying individual visitors.
Third parties may also read cookies on your browser to collect information or to serve content or advertisements to you. We have no control over these cookies or how the third parties use them. They are used to allow that third party to provide a service to us, for example analytics. For more information on these cookies and how to disable them, please see: –
Internet Advertising Bureau website at http://www.youronlinechoices.com/ where you will be able to opt-out of receiving Interest-Based Advertising cookies from some of the third parties listed below: –
If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium’s website.
These Cookies enable core functionality such as security, verification of identity and network management. These Cookies cannot be disabled.
These Cookies are used to track advertising effectiveness to provide a more relevant service and deliver better adverts to suit your interests. You can disable these Cookies.
These Cookies collect data to remember choices users make to improve and give a more personalised experience. You can disable these Cookies.
These Cookies help us to understand how visitors interact with our website, discover errors and provide better overall analytics. You can disable these Cookies.
7. COLLECTION OF INITIAL IN FORMATION
We collect information about you during the registration process for any of our services. This information may include, but is not limited to your name, e-mail address, phone number and any other details as might be requested from you for the purpose of registration and/or continued use of our services.
We may also collect information from you if you request information or customer support and your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account.
8.COLLECTION OF ADDITIONAL INFORMATION AND DOCUMENTATION
We may also collect the following additional information and documentation: –
- Property particulars, including residential address.
- Verification of identity documentation, e.g. passport or driving licence.
- Verification of residential address documentation, e.g., utility bill or bank statement.
- Confirmation of your financial history, source of wealth and source of funds.
- Residential and employment status.
- Information from third party databases to comply with credit underwriting, legal and regulatory obligations.
9. THIRD PARTY AND PUBLICLY AVAILABLE SOURCES
Not all the personal and financial information we hold about you will always come directly from you. We may also collect information from third parties such as credit reference providers and publicly available websites (i.e., social media platforms), to comply with legal and regulatory obligations.
10. HOW WE USE THIS INFORMATION
We only process your data in the way you would reasonably expect us to. We use your data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our websites. We keep the information we hold about you to a minimum.
We will, from time to time, send you marketing material which may be of particular interest to you based upon your preferences, i.e., your desired location, property type or price category. These marketing messages will provide you with information about the products and services available to you via Select Property Management.
Except where we use your personal data for marketing purposes, on the basis of your prior written consent, and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.
11. HOW INFORMATION IS SHARED
Your personal and financial information may be transferred or disclosed to trusted third parties for the processing of that personal information based on our instructions and in compliance with this policy and any other appropriately confidential and secure measures. Our third-party service providers include: –
- IT hosting platforms.
- Credit reference agencies.
- Regulatory authorities, government agencies and law enforcement agencies.
- Trading Standards and other consumer bodies.
- Auditors and accountants.
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. We only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested. Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services.
12. CONSENT TO PROCESSING AND ACCEPTANCE OF THIS POLICY
By providing personal information to us as part of the registration process, you fully understand and expressly consent to the processing of that data as described within this policy. If you do not consent to this policy process, please advise the DPO in writing at Select Property Management & Lettings.
13. RECORD RETENTION
We retain personal information for as long as necessary to fulfil the purpose for which it was collected. Your information will not be kept for longer than 10 years following that date on which your relationship with us ceases. We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention. When your information reaches the end of its retention period, electronic data will be deleted, and any hard copy information will be destroyed.
We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and Select Property Management and Lettings will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.
15. YOUR RIGHTS
Under the General Data Protection Regulation (GDPR) and more specifically the Data Protection (Jersey) Law 2018, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
Access to personal data
You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the ‘How to contact us’ section for information on how to contact us. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible but no later than within 4 weeks.
Right to rectification
You can request us to rectify and correct any personal data that we are processing about you which is inaccurate.
Right to withdraw consent
Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent at any time.
Right of erasure
You can request your personal data to be erased. This right will be undertaken without delay where one of the grounds for its erase complies with Article 32(1) of the DATA PROTECTION (JERSEY) LAW 2018 (jerseylaw.je). Any regulatory or legal requirement to retain your records will take precedence.
Right to data portability
This right allows you to obtain your personal data that you have provided to us with your consent, or which was necessary for us to provide you with our products and services in a format which enables transfer of that personal data to another organisation.
Right to restrict processing of personal data
You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
Right to object to processing of personal data
You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so, or we need to process your personal data in connection with any legal or regulatory claims.
Rights relating to automated decision making and profiling
You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect, or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make any automated decisions of this nature.
17. HOW TO CONTACT US
For any requests related to your personal information or any of your rights referenced within the policy, please contact us via email at firstname.lastname@example.org or in writing to Select Property Management & Lettings, Karibu, La Collinette, Route Orange, St Brelade, JE3 8GP, Jersey.
18. FILING A COMPLAINT
Should you wish to make a complaint relating to your personal data held by Select Property Management & Lettings, you can contact the Jersey Office of the Information Commissioner (JOIC) if you are unhappy with how we have used your personal data. JOIC’s address: 2nd Floor, 5 Castle Street, St. Helier, Jersey JE2 3BT or via email email@example.com or telephone +44 (0) 1534 716530.