Propertypal

Privacy Policy




www.propertypal.com,INTRODUCTION Changes to the Privacy Notice and your Duty to Inform us of Changes,This is the privacy notice or policy (notice) of PropertyPal.com Limited (we, versions can be obtained by contacting us. ,us or our). ,We respect your privacy and are committed to protecting your personal current. Please keep us informed if your personal data changes during ,data. This privacy notice will inform you as to how we look after your your relationship with us.,personal data when you visit and use our website (regardless of where you ,visit it from) http://www.PropertyPal.com (our website), whether as an Third-party Links,estate agent, letting agent, property developer or property owner seeking This website may include links to third-party websites, plug-ins and ,to display a property you are marketing to users of our website interested applications. Clicking on those links or enabling those connections may ,in viewing properties for sale or for rental, as an interested party seeking to allow third parties to collect or share data about you. We do not control ,gather information shared by users of our website, or however otherwise. these third-party websites and are not responsible for their privacy ,It also informs you how we will look after your personal data when you privacy notice of every website you visit.,generally interact with us as one of our customers, and about your privacy ,rights and how the law protects you. It does not cover any website you 2. THE DATA WE COLLECT ABOUT YOU,have used to access our website or any website that you access from it.,This Policy also includes a series of disclosures in relation to and which individual from which that person can be identified. It does not include ,provides more detail on the third-party service providers we partner with, data where the identity has been removed (anonymous data).,the kinds of personal data they may gain access to, and what they do with ,it, including in our Cookie Policy, available at https://www.propertypal.com/We may collect, use, store and transfer different kinds of personal data ,cookie-policy.about you which we have grouped together as set out below. ,It is important that you read this privacy notice so that you are fully aware It is important that the personal data we hold about you is accurate and ,of how and why we are using your data. current. Please keep us informed if your personal data changes during ,Please use the Glossary to understand the meaning of some of the terms you can update your details or delete your account at any time. ,used in this privacy notice.,1. WHO WE ARE•General Personal Data - This is personal information about you ,Under the UK General Data Protection Regulation or the EU General email, through the post, on the telephone or by any other means. ,Data Protection Regulation (collectively GDPR) and other relevant data ,protection legislation, we act as both a data controller (i.e. where we Typically, when you visit, register or use the services on our website, ,make decisions) in relation to your personal data that we collect, as well as an ordinary user you will be asked to provide certain information ,as a data processor (i.e. process data broadly in accordance with your about yourself, including your full name, email address, home ,instructions. address and mobile phone number and other contact details, or ,When we act as a Data Processor: When as a customer or user you use ,our services to process personal data, we act as a data processor. Under Where you are an estate agent or property developer using the ,these circumstances, the customer or user may act as a data controller site as a member, you will be asked to provide the above details, ,or data processor itself, and we will act as either a processor or a sub-as well as your business name, bank account details for the purposes ,processor. of administering your account, and addresses of properties that you ,When we act as a Data Controller: By contrast, when we collect personal ,data and determine the purposes and means of processing that personal If you provide verbal personal information that you give us consent ,data – for example, when we store account information for account to use you will have such consent confirmed back to you in writing. ,registration, administration, services access, or contact information as ,explained below – we act as a data controller.Where payment is made, additional personal information we ask you ,Contact Detailschecks, such as credit checks. We do not collect personal bank ,Our full details are:personal data shared is likely to include your employment history, ,Full Name of Legal Entity: PropertyPal.com Limited, a company proof of identity, qualification checks, health information, or ,incorporated in Northern Ireland under company number NI603400whatever other information you volunteer to us. ,Email Address: help@propertypal.com,Postal Address: Unit 2D Jennymount Business Park, North Derby Street, You may also communicate your preferences in receiving marketing ,Belfast, BT15 3HNfrom us and our third parties and your communication preferences ,ICO Registration Number: ZA128377 (this is the number under which we (including details you provide when you opt-in to receive marketing ,are registered with the ICO for the processing of personal data) communications from us).,You have the right to make a complaint at any time to the Information IMPORTANT NOTE,Commissioner’s Office (ICO), the UK supervisory authority for data Unless submitted by the property owner or members of your social ,protection issues (www.ico.org.uk). We would, however, appreciate the network, details held by us about a property do not comprise ,chance to deal with your concerns before you approach the ICO so please personal data as defined by the GDPR. We may use the data held ,contact us in the first instance. about properties advertised to provide services to third parties.,If you would like to make a complaint to the ICO, their contact details are:We do not accept property listings directly from consumers, with the ,By phone - 0303 123 1113exception of registered members of a government approved ,Online - https://ico.org.uk/concernsproperty redress scheme (including, in the Republic of Ireland, those ,This version two of this Policy was last updated on Aug 2021 and historic ,It is important that the personal data we hold about you is accurate and ,statements. When you leave our website, we encourage you to read the ,Personal data, or personal information, means any information about an ,your relationship with us. Where you have registered to use our website ,DATA THAT YOU SUPPLY TO US,that you share with us through filling in online or offline forms, by ,comments provided through our contact form.,submit. ,to supply may include your information needed to carry out any ,account details. If you apply for a role with our organisation, other ,PRIVACY POLICY,www.propertypal.com,licensed by the Property Services Regulatory Authority). If you are the •Other - from time to time, we may receive personal information from ,owner of a property being displayed for sale or for rent on our other sources. We will always endeavour to ensure such information ,website this is because the agent you have chosen to use for the sale is provided from reputable sources, who are GDPR compliant to do so.,or the letting of your property has a contract with us to display the ,details of your property on our website and thereby place the We may also collect, use and share Aggregated Data such as statistical or ,information about your property fully in the public domain.demographic data for any purpose. Aggregated Data may be derived from ,If the agent you have chosen to use for the sale or the letting of your does not directly or indirectly reveal your identity. For example, we may ,property has a contract with us and has not elected to display the aggregate your Usage Data to calculate the percentage of users accessing ,details of your property on our website, you can request for such a specific website feature. However, if we combine or connect Aggregated ,details to be displayed via the agent.Data with your personal data so that it can directly or indirectly identify ,•Marketing Data: You may also communicate your preferences accordance with this privacy notice.,in receiving marketing from us and our third parties and your ,communication preferences (including details you provide when you We do not collect any Special Categories of Personal Data about you ,opt-in to receive marketing communications from us).(including details about your race or ethnicity, religious or philosophical ,•Project Specific Personal Data: This also includes specific personal membership, information about your health and genetic and biometric ,data that we may gain technical access to (from you) through the data). Nor do we collect any information about criminal convictions and ,services that we provide for you, including where we host websites offences.,or software solutions on your behalf, and can include numerous ,different kinds of personal data, depending on the nature of the If you fail to provide personal data,databases or other information to which you grant us access. We Where we need to collect personal data by law, or under the terms ,have a separate data processing agreement that supplements this of a contract we have with you and you fail to provide that data when ,policy and which applies where we provide hosting services on your requested, we may not be able to perform the contract we have or are ,behalf. trying to enter into with you (for example, to provide you with services). ,If you provide verbal personal information that you give us consent notify you if this is the case at the time. ,to use you will have such consent confirmed back to you in writing.,Where you are sharing personal data that does not directly relate to A Cookie is a small text file that is added to your device’s hard drive by ,you (e.g. your representatives that legally act on your behalf), you a web server within our domain. Cookies cannot used to run software ,must ensure you have the consent to do so and have shared this programs or add a virus to your device. They are unique to you and avoid ,Notice with that person/those people.you having to input the same information and preferences each time you ,PERSONAL DATA THAT WE COLLECTwebsite, please see our Cookies Policy which is available at: https://www.,•Telephone Recordings - Telephone conversations may be recorded ,to improve training and to ensure a high level of consistent customer Our website’s servers automatically record ‘log files’ containing ,service.information about the volume and characteristics of our website’s website ,•CCTV - We may use CCTV cameras on our premises and may record on our website). Log files are used to build pictures of how our website ,footage of you where you attend our premises in person, and use is used that help to monitor and improve the service provided by our ,such footage as required in our legitimate interests, including to website. You cannot be identified from your log files.,ensure the safety and well-being of our staff.,•Technical Data - We may use the following technical services to ,gather technical data as set out in our Cookie Policy from time to We will only use your personal data when the law allows us to. Most ,time, available at https://www.propertypal.com/cookie-policy. commonly, we will use your personal data in the following circumstances:,INFORMATION WE RECEIVE FROM THIRD-PARTIES•Where we need to perform the contract we are about to enter into or ,•Business Partners - where we have formal relationships with separate terms of use for our website that you have entered ,business partners who may introduce new customers or sales into, including for the purposes set out in the “Our Standard Business ,opportunities to us, personal data would include personal contact Operations” section below.,details, information on the areas of interest and data required to fulfil •Where it is necessary for our legitimate interests (or those of a third ,a request, product or service. This would include referrals from estate party) and your interests and fundamental rights do not override those ,agents, personal referrals, and referrals from our affiliated company, interests.,PropertyPal Mortgages Limited. •Where we need to comply with a legal or regulatory obligation.,•Social Media - where you have responded to a promotional item or Generally we do not rely on consent as a legal basis for processing your ,offer from us through social media facilities such as Facebook, personal data other than in relation to sending third party direct marketing ,LinkedIn etc., we can receive profile information about you which can communications to you via email or text message (which is something ,include your name, address, telephone number(s) and/or your that we do not typically do). If we do implement direct marketing in future, ,business contact details. This information would be used to respond and you have consented to this, you have the right to withdraw consent to ,to your interest, to fulfil a request from you and/or to send you future marketing at any time by contacting us.,information and offers, where you have given clear consent to do so.,•Publicly Available Information - we may collect personal depending on the specific purpose for which we are using your data. Please ,information about you from publicly available sources. This can contact us if you need details about the specific legal ground we are relying ,include your name, address and other publicly available information. on to process your personal data. ,As far as passible, we ensure that where any third-parties are ,involved in suppling such information, that they are compliant to do Our Standard Business Operations:,so. This may include credit reference agencies such as Experian or ,public registers such as the Companies House registry or the ,Electoral Register. ,your personal data but is not considered personal data in law as this data ,you, we treat the combined data as personal data which will be used in ,beliefs, sex life, sexual orientation, political opinions, trade union ,In this case, we may have to cancel a service you have with us but we will ,Cookies,visit our web site(s). For more information on the cookies used by our ,propertypal.com/cookie-policy. ,traffic (e.g. IP address, numbers of pages viewed, length of time spent ,3. HOW WE USE YOUR PERSONAL DATA,have entered into with you, for the purposes contemplated in any ,We may process your personal data for more than one lawful ground ,•To provide the services that we contract to do so with you;,•To provide you with information that you request from us;,•To confirm your identity as a natural living person. and,•As part of our billing, payments and recovery processes. ,www.propertypal.com,MarketingGeneral Disclosures,We may use your personal data to form a view on what we think you may •with any member of our group, which means our subsidiaries, our ,want or need, or what may be of interest to you. This is how we decide ultimate holding company and its subsidiaries, as defined in section ,which products, services and offers may be relevant for you (we call this 1159 of the Companies Act 2006, or our affiliated companies, ,marketing). including PropertyPal Mortgages Limited. ,We will only send you specific property alerts using our Site in relation to •with HM Revenue &amp. Customs, regulators and other authorities acting ,properties that you have subscribed to see. as processors or joint controllers based in the United Kingdom who ,You will only receive marketing communications from us if you have opted ,to receive it. This includes where you have consented to being contacted •with anyone, where your data has been disclosed to us for the ,by us by email or telephone to discuss our products or services or other purposes of public advertising on our website, on the basis outlined ,related information. above. ,We strive to provide you with choices regarding personal data uses for •with third party purchasers, if we buy, sell or merge any business ,marketing and advertising and currently use E-Keeper (and will shortly be or assets of our business and are required to share data as part of ,migrating to SalesForce) to manage our email correspondence. You can the buying, selling or merger agreement. or if our assets are acquired ,ask us to stop sending you marketing messages at any time by following by a third-party, and data is transferred as part of the purchased ,the opt-out links on any marketing message sent to you or by contacting assets. If any such change happens, we will ensure that it is under ,us, as appropriate, at any time. terms that preserve the confidentiality of your personal data, and ,Where you opt out of receiving these marketing messages, this will not your personal data. Any purchaser would be bound by the terms of ,apply to personal data provided to us as a result of a service purchase, this notice as regards your data;,service experience or other transactions.,Change of purposeincluding lawyers, bankers, auditors and insurers based in the ,We will only use your personal data for the purposes for which we collected European Union or United Kingdom who provide consultancy, ,it, unless we reasonably consider that we need to use it for another reason banking, legal, insurance and accounting services, where they have a ,and that reason is compatible with the original purpose. If you wish to get need to know same for any of the purposes set out above. or,an explanation as to how the processing for the new purpose is compatible ,with the original purpose, please contact us. •with reputable and trusted third-parties where we have asked them ,If we need to use your personal data for an unrelated purpose, we will notify part of our contractual agreement, is a legal requirement or there is ,you and we will explain the legal basis which allows us to do so.clear legitimate interest between us(these services may include ,Please note that we may process your personal data without your through the post etc). and,knowledge or consent, in compliance with the above rules, where this is ,required or permitted by law.•with specific selected third parties, determined by us, if you breach ,Legal requirementsyou, including credit-reference agencies, debt-collection firms or ,We will keep and use your data in terms of any legal or regulatory service providers, solicitors or barristers and law enforcement ,requirements that we have and can use your data to protect our agencies (if applicable). ,legal position, if legal action is required, including the recovery of any ,outstanding debts.•with service providers acting as processors based in the European ,By way of further example, we will share your personal data with the services. Below we have set out a non-exhaustive list of the critical ,relevant agencies and without notice, where we are requested to or third-party services providers whose software and services we utilise, ,suspect fraudulent activities, money laundering, terrorist related activities.and with whom your account might otherwise interact, and a brief ,Enhancing our Services,We may use personal data (other than that comprised in private personal •Email Marketing Providers: We may use your personal data in ,data) for the purposes of providing, enhancing, or improving our services.marketing communications, as noted above, and collaborate with ,Website Administration and Customisationsend e-mails to you, where you have opted in to receiving them. You ,We may use the information we collect about you for a variety of website can unsubscribe directly from any mailing list using the unsubscribe ,administration and customisation purposes. For example, we use your links provided within emails. ,information to process your registration request, provide you with ,services and communications that you have requested, send you email •Payment Processors: We may use third-party services for payment ,updates and other communications, customise features and advertising processing (e.g. payment processors) or payment analytics, for ,that appear on our websites, deliver our websites content to you, measure example, Stripe. Any payment processor we use will adhere to ,website traffic, measure user interests and traffic patterns, and improve the standards set by PCI-DSS as managed by the PCI Security ,our websites and the services and features offered via our websites.Standards Council, which is a joint effort of brands like Visa, ,Children under thirteenhelp ensure the secure handling of payment information.,Our website and services are not intended to be used by children under ,13 years old. We will never knowingly collect data from or on children •Remarketing Providers: We use third-party vendors’ remarketing ,below 13 years old. If you become aware of such a child (or another services to advertise on third-party websites to you after visiting ,person) supplying data on that child to us, please contact us. our website(s). These third-party vendors collect information about ,4. DISCLOSURES OF YOUR PERSONAL DATAadvertisements for our products or services to you on third-party ,We may have to share your personal data with the categories of data advertising campaigns. ,processors or data controllers set out below for the purposes set out in ,paragraph 4 above, or otherwise below.Some third-party vendors may use non-cookie technologies that may ,require reporting of processing activities in certain circumstances;,we will notify you on our website or by email before any transfer of ,•with professional advisers acting as processors or joint controllers ,to contact you on our behalf, where you have given us consent, it is ,sending you email, calling you by telephone, sending you information ,any agreement with us, including so as to enforce our rights against ,Union or United Kingdom who provide IT and system administration ,note of how we use them. ,e-mail marketing services providers, e.g. Mailchimp to manage and ,Mastercard, American Express and Discover. PCI-DSS requirements ,your activity on our website to enable us to: (a) measure and ,analyse traffic and browsing activity on our site. (b) show ,websites. (c) measure and analyse the performance of our ,not be impacted by browser settings that block cookies. Your browser ,may not permit you to stop such technologies. You can use the ,www.propertypal.com,following third-party tools to decline the collection and use of 5. INTERNATIONAL TRANSFERS,information to serve you interest-based advertising:The EEA, UK and other countries outside the EEA and the UK have ,a. The NAI’s opt-out platform: http://www.networkadvertising.org/choices/ protection of privacy. ,b. The EDAA’s opt-out platform http://www.youronlinechoices.com/ ,c. The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=ENIt is sometimes necessary for us to share your personal data to countries ,We may share information, such as hashed e-mail addresses (if and EEA laws designed to ensure the privacy of your personal data (for ,available) or other online identifiers collected on our website with example by putting in place model clauses designed to secure the privacy ,these third-party vendors. This identification allows these third-party of your personal data). For example, we will transfer your personal data to ,vendors to recognise and deliver ads to you across devices and Asana and Google Drive, providers of third-party software services to us, ,browsers. To read more about the technologies used by these who are located in the USA. ,third-party vendors and their cross-device capabilities, please refer to ,the Privacy Policy of each vendor.As we are based in the UK we will also transfer your personal data from ,•Hosting &amp. Backend Infrastructure: We use this type of service ,to host data and provide the Service. These are protected by We will also ensure all protections required by applicable UK and EEA laws ,standard authentication and authorisation provided elsewhere.are in place before transferring personal data to any organisation or body ,•Infrastructure Monitoring: We use this type of service to up by, or on the basis of, an agreement between two or more countries ,monitor our applications and the site, to detect issues with and (international organisations). We may transfer your personal data to the ,measure performance, operation, uptime, maintenance, and usage. following international organisations insert.,The personal data that is processed depends upon the ,implementation of these services and may include log centralisation Under data protection laws, we can only transfer your personal data to a ,and application usage.country outside the UK/EEA or to an international organisation where:,•Customer Feedback and Support Management: We use this •in the case of transfers subject to UK data protection law, the UK ,type of service to manage any customer feedback and support, government has decided the particular country ensures an ,including feature requests and roadmap insights. The personal data adequate level of protection of personal data (known as an ,processed depends on what is offered by you when using the site.‘adequacy regulation’) further to Article 45 of the UK GDPR;,•Service Applications: We also use third-party service providers •in the case of transfers subject to EEA data protection laws, the ,to better our services, including reCAPTCHA, an invisible captcha European Commission has decided that the particular country ,service operated by Google, Inc. The reCAPTCHA service may collect ensures an adequate level of protection of personal data (known as ,information from you and your Device for security purposes.an ‘adequacy decision’) further to Article 45 of the EU GDPR;,•Analytical Service Applications: We may share appropriate •there are appropriate safeguards in place, together with enforceable ,information with providers in order to analyse our website traffic to rights and effective legal remedies for you. or,improve products and services. ,•Support Platform: We may share information with our support ,platform provider, SalesForce, where you contact us via social media Where we transfer your personal data outside the UK we do so on the ,or via our helpdesk email, and a record is created in of your email basis of an adequacy regulation or (where such is not available) insert, e.g. ,address, name or social media profile name, to see a history of legally-approved standard data protection clauses recognised or issued ,contact between you and our support team. further to Article 46(2) of the UK GDPR. In the event we cannot or choose ,We require all third parties to respect the security of your personal data not transfer your personal data outside the UK unless we can do so on ,and to treat it in accordance with the law. We do not allow our third-party the basis of an alternative mechanism or exception provided by UK data ,service providers to use your personal data for their own purposes and protection law.,only permit them to process the minimal personal data required for ,specified purposes and in accordance with our instructions. We may also Where we transfer your personal data outside the EEA we do so on the ,share personal data with your permission, so we can perform services you basis of the UK interim bridge or an adequacy decision or (where such ,have requested, or use it in other ways you may have authorised. is not available) insert, e.g. legally-approved standard data protection ,We do not share, sell, rent, or trade personal data with third parties for cannot or choose not to continue to rely on either of those mechanisms at ,their commercial purposes. any time we will not transfer your personal data outside the EEA unless we ,Third-party marketingby applicable data protection law.,We will get your express opt-in consent before we share your personal ,data with any company outside of our own (or our affiliated companies) Any changes to the destinations to which we send personal data or in the ,for marketing purposes. transfer mechanisms we use to transfer personal data internationally will ,If you have consented, we may provide your information to carefully Notice’ below.,screened third parties for the purposes detailed above, including ,advertisers, estate agents and advertising networks that require the ,data to select and serve relevant adverts to you and others. We do not 6. DATA SECURITY,disclose information about identifiable individuals to our advertisers, We have put in place appropriate security measures to prevent your ,but we may provide them with aggregate information about our users personal data from being accidentally lost, used or accessed in an ,(for example, we may inform them that 500 men aged under 30 have unauthorised way, altered or disclosed. In addition, we limit access to ,clicked on their advertisement on any given day). We may also use such your personal data to those employees, agents, contractors and other ,aggregate information to help advertisers reach the kind of audience they third parties who have a business need to know. They will only process ,want to target (for example, women in BT1). We may make use of the your personal data on our instructions and they are subject to a duty of ,personal data we have collected from you to enable us to comply with confidentiality. ,our advertisers’ wishes by displaying their advertisement to that target ,audience. We have put in place procedures to deal with any suspected personal data ,differing data protection laws, some of which may provide lower levels of ,outside the UK and EEA. In those cases we will comply with applicable UK ,the EEA (where you are based in the EEA) to the UK.,(or its subordinate bodies) governed by public international law or set ,•a specific exception applies under relevant data protection law. ,not to continue to rely on either of those mechanisms at any time we will ,clauses issued further to Article 46(2) of the EU GDPR. In the event we ,can do so on the basis of an alternative mechanism or exception provided ,be notified to you in accordance with the Section 10 on ‘Changes to this ,breach and will notify you and any applicable regulator of a breach where ,we are legally required to do so.,www.propertypal.com,No method of transmission, or method of electronic storage, is 100% Request erasure of your personal data. This enables you to ask us to ,secure. Although we will take all reasonable measures to protect your delete or remove personal data where there is no good reason for us ,personal data, we cannot guarantee its security. Any transmission is at continuing to process it. You also have the right to ask us to delete or ,your own risk.remove your personal data where you have successfully exercised your ,7. DATA RETENTIONpersonal data to comply with local law. ,How long will you use my Personal Data for?erase your data within three months of your request, subject to retention ,We will only retain your personal data for as long as necessary to fulfil the of any data which we are required to keep for legal or regulatory reasons ,purposes we collected it for, including for the purposes of satisfying any (as outlined above).,legal, accounting, or reporting requirements. ,To determine the appropriate retention period for personal data, we request of erasure for specific legal reasons which will be notified to you, ,consider the amount, nature, and sensitivity of the personal data, the if applicable, at the time of your request. ,potential risk of harm from unauthorised use or disclosure of your ,personal data, the purposes for which we process your personal data and Object to processing of your personal data where we are relying on a ,whether we can achieve those purposes through other means, and the legitimate interest (or those of a third party) and there is something about ,applicable legal requirements.your particular situation which makes you want to object to processing ,We will keep your personal data for the term you have consented to, the freedoms. You also have the right to object where we are processing ,contracted term between us where there is a legitimate interest for us to your personal data for direct marketing purposes. In some cases, we may ,remain in contact with you, or for the legally required period, whichever is demonstrate that we have compelling legitimate grounds to process your ,the longest.information which override your rights and freedoms.,By law we have to keep basic information about any of our customers Request restriction of processing of your personal data. This enables ,(including contact, identity, financial and transaction data) for six years you to ask us to suspend the processing of your personal data in the ,after you cease being a customer for tax purposes.following scenarios: (a) if you want us to establish the data’s accuracy. (b) ,CHANGING THE INFORMATION HELD(c) where you need us to hold the data even if we no longer require it as ,Registered members of our website can update their information, change objected to our use of your data but we need to verify whether we have ,settings or cancel their membership at any time to ensure that such overriding legitimate grounds to use it. ,information is accurate and kept up-to-date.,In some circumstances you can ask us to delete your data - see Section 8 will provide to you, or a third party you have chosen, your personal data ,below for further information.in a structured, commonly used, machine-readable format. Note that this ,In some circumstances we may anonymise your personal data (so that it consent for us to use or where we used the information to perform a ,can no longer be associated with you) for research or statistical purposes contract with you. ,in which case we may use this information indefinitely without further ,notice to you. Withdraw consent at any time where we are relying on consent to ,No fee usually required of any processing carried out before you withdraw your consent. If you ,You will not have to pay a fee to access your personal data (or to exercise withdraw your consent, we may not be able to provide certain products ,any of the other rights). However, we may charge a reasonable fee if your or services to you. We will advise you if this is the case at the time you ,request is clearly unfounded, repetitive or excessive. Alternatively, we may withdraw your consent.,refuse to comply with your request in these circumstances.,What we may need from you,We may need to request specific information from you to help us confirm You will not have to pay a fee to access your personal data (or to exercise ,your identity and ensure your right to access your personal data (or to any of the other rights). However, we may charge a reasonable fee if your ,exercise any of your other rights). This is a security measure to ensure that request is clearly unfounded, repetitive or excessive. Alternatively, we may ,personal data is not disclosed to any person who has no right to receive it. refuse to comply with your request in these circumstances.,We may also contact you to ask you for further information in relation to ,your request to speed up our response.Where you exercise one of your rights, we may need to request specific ,Time limit to respondright to exercise such rights. This is a security measure to ensure that ,We try to respond to all legitimate requests within one month. personal data is not disclosed to any person who has no right to receive it. ,Occasionally it may take us longer than a month if your request is We may also contact you to ask you for further information in relation to ,particularly complex or you have made a number of requests. In this case, your request to speed up our response.,we will notify you and keep you updated. ,8. YOUR LEGAL RIGHTSparticularly complex or you have made a number of requests. In this case, ,Under certain circumstances, you have rights under data protection laws ,in relation to your personal data. You have the right to:,Request access to your personal data (commonly known as a “data REQUIREMENTS?,subject access request”). This enables you to receive a copy of the ,personal data we hold about you and to check that we are lawfully We may disclose personal data or other information we collect about you ,processing it.to law enforcement in response to a valid subpoena, court order, warrant, ,Request correction of the personal data that we hold about you. This disclosure is reasonably necessary to protect our property or rights, or ,enables you to have any incomplete or inaccurate data we hold about you those of third parties or the public at large.,corrected, though we may need to verify the accuracy of the new data you ,provide to us.In complying with court orders and similar legal processes, we strive for ,right to object to processing (see below), where we may have processed ,your information unlawfully or where we are required to erase your ,Generally, if requested whenever you cancel your membership, we will ,Please note, however, that we may not always be able to comply with your ,on this ground as you feel it impacts on your fundamental rights and ,where our use of the data is unlawful but you do not want us to erase it. ,you need it to establish, exercise or defend legal claims. or (d) you have ,Request the transfer of your personal data to you or to a third party. We ,right only applies to automated information which you initially provided ,process your personal data. However, this will not affect the lawfulness ,If you wish to exercise any of the rights set out above, please contact us. ,information from you to help us confirm your identity and ensure your ,We try to respond to all legitimate requests within one month. ,Occasionally it may take us longer than a month if your request is ,we will notify you and keep you updated.,9. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE ,or similar governmental order, or when we believe in good faith that ,www.propertypal.com,transparency. When permitted, we will make a reasonable effort to notify ,users of any disclosure of their information, unless we are prohibited by ,law or court order from doing so, or in rare, exigent circumstances.,10. LEGAL,Changes to this Notice,We may change this notice from time to time. Any material changes to this ,notice will be notified to you.,Choice of Law and Jurisdiction ,This notice shall be governed by and interpreted in accordance with the ,laws of Northern Ireland and you irrevocably agree that the courts of ,Northern Ireland shall have exclusive jurisdiction to settle any dispute ,which may arise out of, under, or in connection with this policy.,GLOSSARY,Comply with a legal or regulatory obligation,means processing your personal data where it is necessary for compliance ,with a legal or regulatory obligation that we are subject to,Personal Data,means any personal information we hold on you;,Performance of a Contract,means processing your data where it is necessary for the performance of ,a contract to which you are a party or to take steps at your request before ,entering into such a contract. ,EEA,means European Economic Area;,GDPR,has the meaning given in Section 1;,ICO,means the Information Commissioner’s Office - the UK data protection ,regulatory body;,Legitimate Interest,means the interest of our business in conducting and managing our ,business to enable us to give you the best service and the best and most ,secure experience. We make sure we consider and balance any potential ,impact on you (both positive and negative) and your rights before we ,process your personal data for our legitimate interests. We do not use ,your personal data for activities where our interests are overridden by the ,impact on you (unless we have your consent or are otherwise required or ,permitted to by law). ,Third party(ies),refers to external suppliers who your personal data may be shared with;,We, us, our,means PropertyPal.com Limited;,You, your, data subject,,relates to you as a natural living person. and,Your representative,means someone or some people who legally acting on your behalf.





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