Privacy Policy.
INTRODUCTION
This is the privacy notice or policy (notice) of PropertyPal Data Services Limited (we, us or our).
We respect your privacy and are committed to protecting your personal data. This notice will inform you as to how we look after your personal data when you interact with us as one of our customers or suppliers (or as an employee or representative of same), visit us at our premises, visit or use our websites (including https://www.propertydatainsight.com) (regardless of where you visit them from) (our websites), including using our Property Data Insight software application tools (the PDI Tools) available through our websites.
Effectively, it applies to all processing of personal data undertaken by us other than processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies.
It also informs you how we will look after your personal data, and about your privacy rights and how the law protects you. It does not cover any website you have used to access our website or any website that you access from it.
Any data that we collect through the PDI Tools, or when providing you or the customer on whose behalf you are accessing and using the PDI Tools shall be known as the PDI Data in this Notice.
This Policy also includes a series of disclosures in relation to and which provides more detail on the third-party service providers we partner with, the kinds of personal they may gain access to, and what they do with it, and our Cookie Policy, available here.
It is important that you read this notice so that you are fully aware of how and why we are using your data.
Before using the PDI Tools, you individually will also need to agree to our end user licence agreement (EULA) and be authorised to access the PDI Tools on behalf of a person or entity (the Commercial Licensee) who has paid for access to the PDI Tools and has agreed to enter into a commercial licence agreement with us (Commercial Licence), typically on our general terms.
Please use the Glossary to understand the meaning of some of the terms used in this notice.
1. Who we are
Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, we act only as a data controller (i.e. where we make decisions) in relation to your personal data that we collect. We do not act as a data processor (i.e. where we process data in accordance with your instructions).
We act as a data controller when we collect personal data and determine the purposes and means of processing that personal data – for example, when we store account information for account registration, administration, services access, or contact information as explained below – we act as a data controller.
IMPORTANT: We do not intentionally act as a data processor as we require all users and customers of the PDI Tools not to use our services to process personal data relating to third party individuals (e.g. homeowners). You should not store any personal data when using the PDI Tools (other than your name or email address which we will collect as part of the registration process, which you may provide or which may be provided by third parties on your behalf) and if you do so, you will be in breach of our EULA and put the Commercial Licensee in breach of the Commercial Licence and should delete such data immediately.
Contact Details
Our full details are:
Full Name of Legal Entity: PropertyPal Data Services Limited, a company incorporated in Northern Ireland under company number NI673817
Email Address: help@propertydatainsight.com
Postal Address: Unit 2D Jennymount Business Park, North Derby Street, Belfast, BT15 3HN
ICO Registration Number: ZB037606 (this is the number under which we are registered with the UK Information Commissioner’s Office as a fee paying data controller)
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
If you would like to make a complaint to the ICO, their contact details are:
By phone - 0303 123 1113
Online - https://ico.org.uk/concerns
Changes to the Notice and your Duty to Inform us of changes
This version 1 of this notice was last updated on August 2021. If it is updated in future, historic versions may be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
This websites and the PDI Tools may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as set out below.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data that you supply to us
General Personal Data - This is personal information about you that you share with us by online forms on our website, through email, through the post, on the telephone, when you register to use the PDI Tools, when you complete customer surveys, engage with our customer services team, engage us to provide services or by any other means.
Typically, when you contact us through our website you will be required to provide general personal information about yourself, including your name, email address, and mobile phone number or other contact details, together with any comments provided through our contact form.
PDI Data: When you register as a new user of the PDI Tools you will be required to provide your name and email address, alongside other non-personal details, including your qualifications and details of the organisation that has subscribed for a licence to the PDI Tools. When using the PDI Tools you will need to provide the address of the property in question, but may not provide any third party personal data when commenting on the property in question (including any homeowner details).
Feedback Data: If you agree to take part in feedback sessions to improve the user experience when using the PDI Tools, we will record the session, including your face and voice, and we will ask you to share the screen to record how you are interacting with the PDI Tools. In addition, if you put in a suggestion for an event, content, feature, discussion, this will also be shared among the team to feed into our roadmap if applicable.
We may also collect personal data when you report any technical or service issues in relation to our websites or the PDI Tools on an ad hoc basis, including relevant notes about any issues and how we responded to resolve these.
Financial Details: Where you are a supplier and provide us with your financial details in order to facilitate payments by us to you or a customer contacting us to provide your financial details in the context of any returns or overpayment, we will collect these financial details. All such details will be kept securely.
Where you make payments for the PDI Tools via our websites, which will be processed via a PCI compliant third party payment processor, additional personal information we ask you to supply may include your information needed to carry out any checks, such as credit checks.
Marketing Data: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us, e.g. email address).
Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.
Data that we collect
Telephone Recordings - Telephone conversations may be recorded to improve training and to ensure a high level of consistent customer service.
CCTV Footage - We may use CCTV cameras on our premises and may record footage of you where you attend our premises in person, and use such footage as required in our legitimate interests, including to ensure the safety and well-being of our staff.
Cookie Data and Other Technical Data- A Cookie is a small text file that is added to your device’s hard drive by a web server within our domain. Cookies cannot be used to run software programs or add a virus to your device. They are unique to you and avoid you having to input the same information and preferences each time you visit our Website(s).
We may use cookies and similar technical services to gather technical data using the means specified and of the nature specified in our Cookies Policy.
This information would typically include details about your device and your visits to our websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
Typically, you are not personally identifiable from this data, unless otherwise specified in respect of data collected whilst you are logged into the PDI Tools.
Data we receive from third-parties
Device Data - analytics providers such as Google Analytics based inside the EU (as specified in the Cookies Policy).
Customers - when a customer signs up for a licence to use the PDI Tools (and you are not the customer in your own personal capacity) we may receive personal data about you from them, for example, if and when they send us lists of any authorised users who have registered under their Commercial Licence.
Business Partners - where we have formal relationships with business partners who may introduce new customers or sales opportunities to us, personal data would include personal contact details, information on the areas of interest and data required to fulfil a request, product or service. This would include referrals from banks, other customers, estate agents, personal referrals, and referrals from our affiliated companies, PropertyPal.com Limited and PropertyPal Mortgages Limited.
Social Media - where you have responded to a promotional item or offer from us through social media facilities such as Facebook, LinkedIn etc., we can receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.
Publicly Available Information - we may collect personal information about you from publicly available sources. This can include your name, address and other publicly available information. As far as possible, we ensure that where any third-parties are involved in supplying such information, that they are compliant to do so. This may include credit reference agencies such as Experian or public registers such as the Companies House registry or the Electoral Register.
Other - from time to time, we may receive personal information from other sources. We will always endeavour to ensure such information is provided from reputable sources, who are GDPR compliant to provide us with that information.
IMPORTANT – PLEASE NOTE: As noted above, our EULA and the Commercial Licence both require users to refrain from uploading or processing any personal data using the PDI Tools and not to infringe any third party’s other rights or violate any laws whilst using the PDI Tools. As noted, we require all users of the PDI Tools to adhere to these terms at all times, but we do not typically actively monitor content uploaded or processed using the PDI Tools, and are not responsible to third parties for enforcing those terms. If you are reviewing this policy because you believe your or your organisation’s data has been processed in violation of those terms, please contact us.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Data we do not collect
Special Category Data: We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences. As noted above, our terms include restrictions on any users using the PDI Tools to collect such data (or financial information) but as noted we do not proactively monitor this, and cannot be held responsible where users breach these restrictions.
Data relating to Children: If you're a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not have a user account for the PDI Tools or provide personal information to us via our websites. We do not knowingly collect information from or direct any of our content specifically to children under relevant ages.
If we learn or have reason to suspect that you are a user who meets these criteria, we will, unfortunately, have to close your account. Please see our EULA for information about individual account closure.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you, for the purposes contemplated in any separate terms of use for our website that you have entered into, including for the purposes set out in the “Our Standard Business Operations” section below.
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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We will only use the PDI Data (which should not include any personal data) as specified in the Commercial Licence.
Our Standard Business Operations
- 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.
We may also use contact information to notify you of any issues which might impact the provision of our services to you or your use of the PDI Tools.
Marketing
We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our services.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to be contacted by us by email or telephone to discuss our products or services or other related information.
We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use SalesForce to manage our email correspondence. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, experience or other transactions.
We will never sell your personal data to any third party (as noted below).
Testimonials
We may post customer testimonials and comments on our websites or other platforms, which may contain personal data. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis 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 rules, where this is required or permitted by law.
Legal Requirements
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.
Enhancing our Services
We may use personal data (other than that comprised in private personal data) for the purposes of providing, enhancing, or improving our services.
Website Administration and Customisation
We may use the information we collect about you for a variety of website administration and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.
Aggregated or Non-Identifying Data
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Non-identifying Data includes information collected from or about you that does not personally identify you – including aggregated information. We treat IP addresses, log file information, anonymised feedback, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. We may use non-identifying information for any purpose.
Certain jurisdictions, including the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Data as described in this policy should be assumed to include IP address and Unique ID data.
4. Disclosures of your personal data
We do not generally disclose personal data, but may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in above or otherwise below.
General Disclosures
with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, or our affiliated companies, including PropertyPal.com Limited and PropertyPal Mortgages Limited;
with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
with users of our website, where your data has been disclosed to us for the purposes of public advertising of a testimonial on our website, on the basis outlined above;
with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data. Any purchaser would be bound by the terms of this notice as regards your data;
with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union or the United Kingdom who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above;
with the Commercial Licensee, who may share your data with its other authorised users of the PDI Tools. In certain circumstances, we may also share your data with other users of the PDI Tools who access them pursuant to the same Commercial Licence as you, provided that the Commercial Licensee and such third parties have entered into a relevant data sharing agreement;
with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us(these services may include sending you email, calling you by telephone, sending you information through the post etc);
with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable);
with service providers acting as processors based in the European Union or the United Kingdom who provide IT and system administration services, including for the performance of our contract with you, as set out below. When we transfer your data to our service providers, we remain responsible for it:
Email Marketing Providers: We may use your personal data in marketing communications, as noted above, and collaborate with e-mail marketing services providers, e.g. Mailchimp to manage and send e-mails to you, where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails.
Payment Processors: We may use third-party services for payment processing (e.g. payment processors) or payment analytics, for example, Stripe. Any payment processor we use will adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Remarketing Providers: We use third-party vendors' remarketing services to advertise on third-party websites to you after visiting our website(s). These third-party vendors collect information about your activity on our website to enable us to: (a) measure and analyse traffic and browsing activity on our site; (b) show advertisements for our products or services to you on third-party websites; (c) measure and analyse the performance of our advertising campaigns.
Some third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to stop such technologies. You can use the following third-party tools to decline the collection and use of information to serve you interest-based advertising:The NAI's opt-out platform:http://www.networkadvertising.org/choices/
The EDAA' opt-out platform:http://www.youronlinechoices.com/
The DAA' opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
We may share information, such as hashed e-mail addresses (if available) or other online identifiers collected on our website with these third-party vendors. This identification allows these third-party vendors to recognise and deliver ads to you across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the Privacy Policy of each vendor.
Hosting & Backend Infrastructure: We use this type of service to host data and provide the Service. These are protected by standard authentication and authorisation provided elsewhere.
Infrastructure Monitoring: We use this type of service to monitor our applications and the site, to detect issues with and measure performance, operation, uptime, maintenance, and usage. The personal data that is processed depends upon the implementation of these services and may include log centralisation and application usage.
Customer Feedback and Support Management: We use this type of service to manage any customer feedback and support, including feature requests and roadmap insights. The personal data processed depends on what is offered by you when using the site.
Service Applications: We also use third-party service providers to better our services, including reCAPTCHA, an invisible captcha service operated by Google, Inc. The reCAPTCHA service may collect information from you and your Device for security purposes.
Analytical Service Applications: We may share appropriate information with providers in order to analyse our website traffic to improve products and services.
Support Platform: We may share information with our support platform provider, where you contact us via social media or via our helpdesk email, and a record is created in of your email address, name or social media profile name, to see a history of contact between you and our support team.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for specified purposes and in accordance with our instructions. We may also share personal data with your permission, so we can perform services you have requested, or use it in other ways you may have authorised.
We do not share, sell, rent, or trade personal data with third parties for their commercial purposes.
Third Party Marketing
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) for marketing purposes.
If you have consented, we may provide your information to carefully 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 disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in BT1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
5. International Transfers
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
For example, we may transfer your personal data to [Asana and Google Drive], providers of third party software services to us, who are located in the USA.
As we are based in the UK we will also transfer your personal data from the EEA (where you are based in the EEA) to the UK.
We will also ensure all protections required by applicable UK and EEA laws are in place before transferring personal data to any organisation or body (or its subordinate bodies) governed by public international law or set up by, or on the basis of, an agreement between two or more countries (international organisations).
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA or to an international organisation where:
in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR;
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available), by another acceptable legal mechanism e.g. legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR.
In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where such is not available), by another acceptable legal mechanism e.g. legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR.
In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you by way of an update to this notice.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We follow generally accepted industry standards to protect the personal data we hold, both during transmission and once we receive it.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
No method of transmission, or method of electronic storage, is 100% secure. Although we will take all reasonable measures to protect your personal data, we cannot guarantee its security. Any transmission is at your own risk.
7. Personal Data Retention
How long will you use my Personal Data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
By law, we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes.
Changing the information held
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
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 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 processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Generally, if requested whenever you close your account, we will erase your data within three months of your request, subject to retention of any data which we are required to keep for legal or regulatory reasons (as outlined above).
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. How do you respond to compelled disclosure requirements
We may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.
In complying with court orders and similar legal processes, we strive for 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, either by email to the email address associated with your account, or generally by drawing your attention to the updated notice when you next access our website or login to use the PDI Tools.
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 Data Services 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. |
In association with
