A) INTRODUCTION

This document is intended to provide you with important information regarding how we process the personal data that we hold for you. This includes details of exactly what data we hold, how it is stored, how we use it and why we hold it.

We have to collect and use information about people with whom we deal as part of the services we offer.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our services as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of our landlords, tenants, students, investors, employees, contractors and companies or individuals that we work with in conjunction with our day to day activities. These are referred to in this policy as relevant individuals.

B) DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is 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.

C) DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

1. 1. processing will be fair, lawful and transparent
   2. data be collected for specific, explicit, and legitimate purposes
   3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
   4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
   5. data is not kept for longer than is necessary for its given purpose
   6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
   7. we will comply with the relevant GDPR procedures for international transferring of personal data

D) TYPES OF DATA HELD

We keep several categories of personal data on our clients in order to carry out effective and efficient processes. We keep this data secure within our computer systems.

Global Propertunities Limited may collect and use the following kinds of personal information:
information about your use of our website

• information that you provide using for the purpose of registering with the website
• information about transactions carried out over this website
• information that you provide for the purpose of subscribing to the website services and
• any other information that you send to us.

Specifically, we hold the following types of data:

First Name	How many dependants	Personal / Secure Loan Details	Criminal Offences / Convictions
Middle Name	Dependants Name(s)	Personal Debt Details	Gender
Surname	Dependants DOB	Personal Ependiture	Marital Status
Previous Name	Primary ID*	Existing Mortgage Details	Salary
Date of Birth	Address ID*	Existing Insurance Details	Accountant Details
Present Address	Bank Statements*	Email Address	Previous employers details
Residential Status	Credit Card Statements*	Phone Numbers	Employers Address
Previous Addresses	Mortgage Statements*	New Property Details	Employers Phone Number
Landlord Details	Proof of Deposit	Solicitor Details	Ethnicity
Nationality	Payslips*	Estate Agent Details	Credit Card Details
NI Number	Self Employed Accounts*	New Mortgage Details	Bank Details
UK National	Employer’s Name	New Insurance Details	Data collected by Google Analytics
*Copies

All of the above information is required for our processing activities. More information on those processing activities are included in our terms of service, which are available from our website, or by emailing enquiries@propertunities.co

E) YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. 1. the right to be informed about the data we hold on you and what we do with it;
   2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
   3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
   4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
   5. the right to restrict the processing of the data;
   6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
   7. the right to object to the inclusion of any information;
   8. the right to regulate any automated decision-making and profiling of personal data.

F) RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

G) LAWFUL BASES OF PROCESSING

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the clients consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate.

H) ACCESS TO DATA

As stated above, clients have a right to access the personal data that we hold on them. To exercise this right, clients should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the individual making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

I) DATA DISCLOSURES

The Company may be required to disclose certain data/information to a third party. The circumstances leading to such disclosures include:

1. 1. To assist with the processing of a tenancy application.
   2. To assist in the purchase or refinance of a property as part of our consultation process.
   3. to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any debt, tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

J) DATA SECURITY

All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.  

Employees are aware of their roles and responsibilities when their role involves the processing of data.  All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops, etc., when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

Where data is computerised, it has been coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself will be kept in a locked filing cabinet, drawer, or safe.

K) THIRD PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

L) INTERNATIONAL DATA TRANSFERS

The Company does not transfer personal data to any recipients outside of the EEA.

M) REQUIREMENT TO NOTIFY BREACHES

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

N) TRAINING

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

O) HOW TO CONTACT US WITH ANY QUESTIONS

Please use the below details if you would like to contact us. Our office hours are 9am – 5pm Monday – Friday. Our office is closed on Saturdays, Sundays and all UK bank holidays and also for the period between Christmas and New Year.

Global Propertunities Ltd, 75H Odhams Walk, London, WC2H 9SD

Email: enquiries@propertunities.co