Professional, Trusted, Valued

Introduction

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).

Data protection principles.

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.

The data we collect about you

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:

• Identity Data such as title, names, employment status, occupation, username or similar identifiers, marital status, date of birth
• Contact Data such as addresses, email addresses and telephone numbers
• Credit File Data collected from credit reference agencies (Skyfall Credit Checks)
• Financial Data such as your income, credit card details, payment card details
• Account Data such as details of your account, history of changes, financial summaries, statements and account/user/policy or reference numbers
• Transaction Data such as purchases/other transactions made on your account and payments to and from you
• Profile Data such as passwords on your accounts, preferences, feedback
• Survey and Research Data such as your responses to questionnaires, surveys, feedback requests and design or research activities
• Usage Data such as information about when and how you use our services
• Marketing Data such as your preferences on receiving marketing from us and information used in your interactions with our (or our partners) marketing activities (e.g. cookie data used for behavioural advertising)
• Communications Data such as details about any contact made between you and us (e.g. phone calls made or received) and/or the content of those communications (e.g. call recordings)
• Special Categories of Personal Data this may include, criminal convictions and offences. We will only collect and use these types of data where we have obtained your explicit consent or if the Law allows us to do so.

2.2 If you fail to provide personal data

• We think it is important to tell you that where we need to collect certain personal data, and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our service you have with us but we will notify you if this is the case at that time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. This is data that we collect directly from you and includes personal data you may provide or we may obtain when you:
  • apply or register for our services;
• use our services;
• use our website;
• make contact with us (e.g. making a phone call);
• communicate with us (e.g. when you talk to us on the phone or send emails, letters or SMS);
• request marketing to be sent to you;
• enter a competition or promotion;
• give us feedback or take part in research or surveys.
• Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect data including Technical Data about your equipment, browsing actions and patterns. This personal data may be collected by using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties (and public sources) as set out in 'Our third parties'.
• Other. We may receive personal data about you from people appointed to act on your behalf, family members, and others who are acting in your best interests or providing us with information in relation to your contact details.

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:

• Where it is necessary for us to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• When you consent to it.
• In the case of Special Categories of Personal Data, where there is a Substantial Public Interest to process the data or we have obtained explicit consent to do so.

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.

Purposes and Legal Grounds

1. We may process your information to:
   1. Understand how you use our services
2. Inform the way that we manage our services
3. Monitor usage and performance of our services
4. Tell you about our services, events and activities that may be of interest to you;
5. Understand how you interact with our marketing; develop, test or change our marketing activities;

When processing your information for these purposes, we are relying on our Legitimate Interest to help us understand, develop, improve and market our services.

1. We may process your information to:
   1. Allow you to begin using or register for our services;
2. Performing creditworthiness, affordability and other checks including, but not limited to, fraud checks, anti-money laundering checks, vulnerability assessments, identity checks;
3. Report activities to credit reference agencies (CRAs), fraud prevention agencies (FPAs) and/or crime prevention agencies in line with our legal, regulatory or business requirements;
4. Communicate with you to provide updates following a credit eligibility check;
5. Communicate with you to provide updates and information while you are using, registering or continuing to use our services;
6. Communicate with you research purposes or to ask you about our current or potential services, processes and customer experiences.

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.

1. We may process your information to:
   1. Enable you to access and use our online services and functionality;
2. Understand how you use and navigate our online services;
3. Tailor online experiences or develop and/or change these services;
4. Service and fulfil on our services (e.g. processing transactions, managing account information and settings);
5. Manage requests from you where you are exercising your data privacy rights;
6. Communicate with you for any purpose relating to the servicing of your account;
7. Develop, improve or change the services that you are using;
8. Offer you additional services and promotions;
9. Assess, collect or recover outstanding debts from you;
10. Transfer ownership of your account to a third party. This may include activities we carry out with third parties including the assessment and handover of any debt;
11. Inform strategies around how we collect, recover outstanding debts. This may involve sharing data with third parties to help inform this strategy including which third parties we work with;
12. Monitor usage and performance of our services, processes and perform analysis (e.g. statistical, market, analysis), reporting, forecasting and accounting.

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.

1. We may process your information to:
   1. Perform checks to prevent, detect, investigate and report fraud, crime and/or terrorist activity;
2. Protect the security and resilience of our networks/applications and respond to technical and security incidents;
3. Carry out our obligations required by relevant laws and regulations (e.g. anti-money laundering (AML) checks.
4. Devise defence strategies (e.g. in relation to fraud, crime, terrorist or cyber-attack risks) and develop, test or change our defences.

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.

1. We may process your information to:
   1. Improve, test, investigate and remediate any issues with our internal processes and practices;
2. Maintain your data and ensure the data that we hold about you is accurate and up to date.

When processing your information for these purposes, we rely on our Legitimate Interest to manage and improve our business processes.

1. We may process your information to:
   1. Co-operate with (and respond to) requests from courts, regulators, law enforcement bodies and other institutions (e.g. fraud prevention agencies);
2. Appropriately handle and process complaints or disputes – this may include contacting relevant parties;
3. Exercise our rights in relation to complaints, disputes or litigation;
4. Manage policy affairs, public relations issues, media enquiries or customer interactions with the media;
5. Manage complaints with third parties;
6. Manage disputes and charge backs;
7. Manage litigation against third parties;
8. Enable us to provide legal and/or regulatory advice in line with our business activities;
9. Share your online account information with regulated third parties, known as Account Information Service Providers (AISPs) where you have asked them to access this information.

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:

1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
2. When the data subject withdraws their consent;
3. When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
4. When the personal data is processed unlawfully (i.e. in breach of the GDPR);
5. When the personal data has to be erased to comply with a legal obligation;
6. Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of;

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.

enquiries@oicjersey.org

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.