Irving Palmer Sales and Lettings are an independent Agent who offer all aspects of Property services in the UK.
Irving Palmer have its registered office at 18-20 High Street, Ringwood, Hampshire, BH24 1AF. Full contact details can be found at www.irvingpalmer.co.uk.
The protection of your personal data is important to Irving Palmer. The purpose of this Data Protection Notice is to let you know which personal data we collect about you, the reasons why we use and share such data, how long we keep it, what your rights are and how you can exercise them.
Further information may be provided where necessary when you apply for a specific service.
1. WHAT PERSONAL DATA DO WE COLLECT?
We collect and use your personal data to the extent necessary to fulfil our contractual obligations to our clients and to achieve a high standard of personalised products and services.
Depending on the type of product or service we provide to you, the personal data we collect about you may include:
- identification information (e.g. name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, IP address);
- contact information (e.g. postal address and e-mail address, phone number);
- family situation (e.g. marital status, number of children);
- education and employment information (e.g. level of education, employment, employer’s name, remuneration);
- banking, financial and transactional data (e.g. bank account details, credit card number, money transfers, assets, declared investor profile, credit history, debts and expenses);
- data relating to your habits and preferences:
- data which relates to your use of our products and services in relation with banking, financial, transactional data and any other property data;
- data from your interactions with us (e.g. our internet website, our social media pages, telephone, email, written correspondence, requests for information or documents);
- connection and tracking data (e.g. audit trail, timestamping, cookies, connection to online service)
- data necessary to fight against fraud, money laundering and terrorist financing.
We never ask for personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning your sex orientation, unless it is required through a legal obligation.
The data we use about you may either be directly provided by you or be obtained from the following sources in order to verify or enrich our databases:
- publications/databases made available by official authorities and third parties;
- our service providers;
- third parties such as credit reference agencies and fraud prevention agencies or data brokers in conformity with the data protection legislation;
- websites/social media pages containing information made public by you (e.g. your own website or social media);
2. SPECIFIC CASES OF PERSONAL DATA COLLECTION, INCLUDING INDIRECT COLLECTION
In certain circumstances, we may collect and use personal data of individuals with whom we have, could have, or used to have a direct relationship such as:
For some reasons, we may also collect information about you even if you have no direct relationship with us.
This may happen for instance when your employer provides us with information about you or your contact details are provided by one of our clients if you are for example:
- Family members;
- Co-borrowers / guarantors;
- Legal representatives (power of attorney);
- Beneficiaries of payment transactions made by our clients;
- Beneficiaries of insurance policies and trusts;
- Ultimate beneficial owners;
- Clients‘ debtors (e.g. in case of bankruptcy);
- Company shareholders;
- Representatives of a legal entity (which may be a client or a vendor);
- Staff of service providers and commercial partners.
3. WHY DO WE USE YOUR PERSONAL DATA?
a. To comply with our legal and regulatory obligations.
We use your personal data to comply with various legal and regulatory obligations, including:
- Property regulations
- banking and financial regulations in compliance with which we:
- set up security measures in order to prevent abuse and fraud;
- detect transactions which deviate from the normal patterns.
- detect transactions which deviate from the normal patterns.
- reply to an official request from a duly authorised public or judicial authority;
- prevention of money-laundering and financing of terrorism;
- compliance with legislation relating to sanctions and embargoes;
- fight against tax fraud and fulfilment of tax control and notification obligations.
b. To perform a contract with you or to take steps at your request before entering into a contract.
We use your personal data to enter into and perform our contracts, including to:
- provide you with information regarding our products and services;
- assist you and answer your requests;
- evaluate if we can offer you a product or service and under which conditions.
- proof of transactions;
- fraud prevention;
- IT management, including infrastructure management (e.g. shared platforms) & business continuity and IT security;
- establishing individual statistical models, based on the analysis of transactions, for instance, in order to help define your credit risk score;
- personalising our service to you through:
- improving the quality of our products or services;
- advertising products or services that match with your situation and profile which we achieve.
This can be achieved by:
- segmenting our prospects and clients;
- analysing your habits and preferences in the various channels (emails or messages, visits to our website, etc.);
- monitoring transactions to identify those which deviate from the normal routine.
4. WHO DO WE SHARE YOUR PERSONAL DATA WITH
In order to fulfil the aforementioned purposes, we do not sell your information to third parties. We only disclose your personal data to:
- Service providers which perform services on our behalf;
- Independent agents, intermediaries or brokers, banking and commercial partners, with which we have regular relationships;
- Financial or judicial authorities, arbitrators and mediators, state agencies or public bodies, upon request and to the extent permitted by law;
- Certain regulated professionals such as lawyers, notaries or auditors.
5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA
In case of international transfers originating from the European Economic Area (EEA), where the European Commission has recognised a non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis.
For transfers to non-EEA countries whose level of protection has not been recognised by the European Commission, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment) or implement one of the following safeguards to ensure the protection of your personal data:
- Standard contractual clauses approved by the European Commission;
- Binding corporate rules.
To obtain a copy of these safeguards or details on where they are available, you can send a written request.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will retain your personal data for the period of time required, in order to comply with applicable laws and regulations or another period with regard to our operational requirements, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests. For instance, most of client’s information is kept for the duration of the contractual relationship and 6 years after the end of the contractual relationship.
7. SAFEGUARDING CHILDREN
Our services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.
8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
In accordance with applicable regulations, you have the following rights:
- To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
- To rectify: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
- To erase: you can require the deletion of your personal data, to the extent permitted by law.
- To restrict: you can request the restriction of the processing of your personal data.
- To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
- To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
- To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.
If you wish to exercise the rights listed above, please send a request to firstname.lastname@example.org or a letter to the following address: 18-20 High Street, Ringwood, Hampshire, BH24 1AF. Please note, we will need to verify your identity before responding.
In accordance with applicable regulation, in addition to your rights above, you are also entitled to lodge a complaint with the relevant authority, e.g. The Information Commissioners Office (ICO).
Irving Palmer takes security seriously. To protect your information from loss, misuse, or unauthorised access or disclosure, we have put into place suitable, physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include:
- Data minimisation
- Password best practise
- Security best practise concerning devices (e.g. PC’s, laptops, mobile devices)
- Online accounts, website hosting, physical access and storage.
- Staff training and accountability on data protection,
10. USE OF ‘COOKIES’
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our site.
11. HOW CAN YOU KEEP UP WITH CHANGES TO THIS DATA PROTECTION NOTICE?
12. HOW TO CONTACT US?
If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact our data protection officer at, email@example.com who will investigate your query.
ISSUE DATE OF POLICY: MAY 2018