The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person – i.e the consumer, website visitor, customer or client (you)
Categories of data – Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address – this is information that you are likely to give to us via an online or offline form. Online information that you might share with us can be tracked by some software – identifiers include IP addresses confirming your geographical location, and cookies for example.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we?
Gold Property Development Ltd is the data controller and our nominated contact is Georgina Lock. This means we decide how your personal data is processed and for what purposes. You can contact us at the office: firstname.lastname@example.org or 01959 543810.
The purpose(s) of processing your personal data
We may use your personal data, but only if you have provided it to us, for the following purposes:
- Contacting you to check you are still interested in hearing from us and that your data record is correct
- Contacting you to let you know about new property listings and open days
- Contacting your regarding the conveyancing process if you have decided to purchase a property from us
- Sharing your details with our Solicitor or Estate Agency if you have decided to purchase a property with us
- Contacting you for feedback after you have purchased a property from us
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data – name, phone number, address, email
We do not process Special categories of data
We have obtained your personal data from:
Your completion of the enquiry form online, or, completion of the newsletter sign-up box online.
Your complete of a paper enquiry form at our open days, or with any of our partnered estate agencies.
Your completion of social media competitions or enquiry forms.
What is our legal basis for processing your personal data?
Our lawful basis for processing your general personal data:
Legitimate interest – you have made us aware that you are interested in our properties.
Lawful consent – you have given us permission to contact you and you can retract this consent at any time. We will keep your details for 1 year before contacting you to update them or remind you that you have the option to remove them.
Data is kept on password protected computers that are kept in a locked office. We use secure sharing software including: Dropbox, Mailchimp and Google Drive.
Sharing your personal data
Readers – your personal data will be treated as strictly confidential and will be shared only with the providers of prizes if you have won a Family Grapevine competition.
Advertisers – we will share your personal information only if you have given it to us as part of the contractual process eg to editors of other local Family Grapevines who you are advertising with and who require this information to draw up an invoice, send you an invoice and/or the printed magazine.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of one month after the closing date of a competition so we can ensure that the winner is able to take the prize and the competition doesn’t need to be redrawn.
We keep your personal data as long as you may be advertising or considering advertising with us and to comply with HMRC requirements.
We only keep personal data that you have shared with us for the purpose of contacting you more easily than via your public contact details. We do not share this information with anyone and we will delete it if requested. Further we will check this information at least once a year.
We will check with you at least once a year to make sure you are still happy for us to hold your personal address on file and to bring you copies of our magazines rather than leaving them in a public place.
Providing us with your personal data
We require your personal data so that we can send winners’ details to the company who has offered the prize. We also need this data to ensure that our Terms and Conditions of entry have not been broken; specifically the requirement for no more than one entry per household.
We require your contact details: name, phone number, email and mailing address for invoicing and distribution purposes. We cannot take paid advertising without this information.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Transfer of Data Abroad
We use Google Analytics at the top level to track how many users we have on our website but we do not look at any data relating to individual users and cannot identify you from these reports. The Google statement on GDPR is shown via this link: https://privacy.google.com/businesses/compliance/#?modal_active=none
Automated Decision Making
We do not use automated decision making.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
How to make a complaint
To exercise all relevant rights, queries and complaints please in the first instance contact me
Katie Debczak (email@example.com)
Sales Manager, Gold Property Development Ltd.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the
Information Commissioners Office on – 03031231113
via email – https://ico.org.uk/global/contact-us/email/
at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.