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Real Property Limited operates the following businesses and may share client information from time to time across the 4 groups of the business to assist clients in cross selling activities;
1. Important information and who we are
1.1 Purpose of this Privacy Policy
Welcome to Real Property Limited’s Privacy Policy.
You trust us with your personal data and we want to be open about what we do with it. This Privacy Policy relates to our range of services and also our web sites and also outlines your privacy rights including how you can access your data, correct it, restrict use of it, erase it and/or object to it being processed.
Real Property Limited is committed to protecting your personal information when you use our services and websites. This Privacy Statement relates to our use of any personal information you provide through any of our business websites above (“the web Sites”).
In order to provide you with the best experience, we are sometimes required to collect information about you.
Real Property Limited is committed to safeguarding your personal information. The material contained on the web Sites is for information only and does not constitute legal or other advice. Real Property Limited will act in accordance with the requirements of the Data Protection (Jersey) Law 2018.
1.2 What is Real Property Limited’s Role?
Real Property Limited is responsible for deciding why and how your personal data is collected and processed. This makes Real Property Limited the Data Controller (referred to as Real Property Limited in this Privacy Policy).
We will ensure that the processing of personal data in relation to which the controller is the controller complies with the data protection principles, namely that data are – (a) processed lawfully, fairly and in a transparent manner in relation to the data (“lawfulness, fairness and transparency”); (b) collected for specified, explicit and legitimate purposes and once collected, not further processed in a manner incompatible with those purposes (“purpose limitation”); (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”); (d) accurate and, where necessary, kept up to date, with reasonable steps being taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”); (e) kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed (“storage limitation”); and (f) processed in a manner that ensures appropriate security of the data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).
Our contact details are: Real Property Limited, 31-33 New Street, St Helier, Jersey, JE2 3RA
We have appointed a Data Protection Officer ("DPO") to help make sure we are transparent and fair about how we use your data and comply with any law that may affect your privacy. Our DPO can be contacted at the above address and also by telephone on 01534 507781.
1.3 Changes to the Privacy Policy and your duty to inform us of any changes
You have a role to play in managing your data too!
It is important that the personal data we hold about you is accurate and current so please let us know if your personal data changes during your relationship with us.
This Privacy Policy was last updated on 25 May 2018.
2.1 What is personal data?
Personal data, or personal information, means any information about an individual from which that person can be identified (either on its own or when combined with other information). It does not include data where the identity has been removed (anonymised data). Different services may ask for different information.
By entering your details in the fields requested on our websites, you enable Real Property Limited to provide you with the services you selected.
Real Property Limited also uses cookies and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). We use analysis software (Google Analytics, Awstats) to look at IP addresses and cookies for the purpose of enhancing your user experience. This information is not used to develop a personal profile of you and the log files are regularly purged.
We may process different kinds of personal data about you, Process means anything we do with your data such as collecting, using, storing, sharing, monitoring, analysing and deleting it, which we have grouped together as follows:
2.2 If you fail to provide personal data
We use different methods to collect data from and about you including through:
4. How we use your personal data
We collect and use your personal data for different reasons and we tell you what these are in this Privacy Policy. Most commonly, we will use your personal data in the following circumstances:
We're only allowed to use your personal data if we have legal grounds to do so.
4.1 Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, the purposes for this usage and which of the legal grounds we rely on to do so. We have also identified what our Legitimate Interests are where appropriate. Note that we may process your personal data for more than one legal ground depending on the specific purpose for which we are using your data.
When processing your information for these purposes, we are relying on our Legitimate Interest to help us understand, develop, improve and market our services.
When processing your information for these purposes, we rely on our Legitimate Interest to allow you to access our services. In addition, in relation to some of the purposes, it is necessary for us to process your information for the Performance of the Contract between us.
When processing your information for these purposes, we rely on our Legitimate Interest to fulfil on our products and services. In addition, in relation to some of the purposes, it is necessary for us to process your information for the Performance of the Contract between us.
When processing your information for these purposes, we rely on our Legitimate Interest to manage risk security and crime prevention. In addition, in relation to some of the purposes, we may process your information to comply with a Legal Obligation.
When processing your information for these purposes, we rely on our Legitimate Interest to manage and improve our business processes.
When processing your information for these purposes, we rely on our Legitimate Interest to satisfy our industry, regulatory and legal requirements and exercise our rights. In addition, in relation to some of the purposes, we may process your information to comply with a Legal Obligation or it may be necessary to assist in relation to a task performed in the Public Interest.
We may use third parties for any of the purposes listed above.
4.2 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or provided us with your details when you applied or registered for one of our services and, in each case, you have not opted out of receiving that marketing. However, you can ask us to stop sending you direct marketing at any time.
If you ask us to stop sending you marketing messages, you will still receive communications pertaining to the servicing or fulfilment of your relationship with us (such as statements, communications about outstanding debts or relevant updates about services that you are already using).
We may also use third parties to conduct marketing activities on our behalf.
4.3 Cookies, Web Statistics and third party monitoring
For more information about the cookies we use, please see our Cookie Policy.
Real Property Limited maintains continuous logs of its web server activity. These log files include the details of website users’ IP address, browser type and page last visited etc. The log files are used to analyse how the website is being used by visitors and may be kept in an anonymised form for historical records.
The Sites use hosted web analytics software. This hosted service is provided and managed by a third party company (Google, Inc). The service ‘Google Analytics’ uses ‘cookies’ (a text file sent to users’ computers as they browse our website) to help analyse how users navigate our website. The information generated by the cookie regarding our website (including IP addresses) will be anonymised and transmitted to and stored by Google, Inc. on servers that may be hosted in the United States. Google, Inc. will use this information for the purpose of evaluating use of our website, compiling reports on website activity for website operators and providing other related services to Real Property Limited.
Google, Inc. may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google, Inc’s. behalf. Google, Inc. will not associate your IP address with any other data held by Google, Inc. You may decline the use of cookies by configuring your web browser to do so, but it may affect your user experience. By using this website, you consent to the processing of data about you by Google, Inc. in the manner and for the purposes set out above.
4.4 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above.
5. Retention of Data
Personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).
The GDPR defines personal data as any information relating to an identified or identifiable natural person (a “data subject”).
6. Data Subject Rights
In addition, personal data includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:
7. Offensive or inappropriate content on the Real Property Limited websites
If you post or send offensive, inappropriate or objectionable content anywhere on or to the Sites or otherwise engage in any disruptive behaviour on the Site, Real Property Limited may use your personal information to stop such behaviour.
Where Real Property Limited reasonably believes that you are or may be in breach of any of the laws of Jersey (e.g. because content you have posted may be defamatory), we may use your personal information to inform relevant third parties such as your employer, school email/Internet provider or law enforcement agencies about the content and your behaviour.
8. Can I find out what personal information Real Property Limited hold about me?
You have the right to access any of the information that we hold on you, you have the right to general access requests, you have the right to have any inaccurate information corrected, you have the right to have your information erased, you have the right to restriction of processing, you have the right to object to processing for the purpose of public functions or legitimate interests, you have the right to object to processing for historical or scientific purposes, you have the right to data portability and you have the right to object to the use of your information for direct marketing. To exercise any of these rights, please contact us by writing to Real Property Limited at 31-33 New Street, St Helier, Jersey, JE2 3RA
9. Data transfers
Controllers or processors will not transfer personal data for processing or in circumstances where the controller or processor knew or should have known that it will be processed after the transfer to a third country or an international organisation, unless that location or country or organisation ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
10. Making a Complaint
You also have the right to make a complaint to the Office of the Information Commissioner.
10. References -
Data Protection (New Law)
The Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 came into effect on 25 May 2018
https://oicjersey.org/data-protection-new-law/
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10. Changes to the Real Property Limited Privacy Statement
This Privacy Statement may be updated from time to time.