- what information we collect;
- how we use that information;
- how this information is shared;
- your rights; and
- other useful privacy and security related matters.
We hope you take the time to read this policy. It is important to check back often for updates to this policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant service.
Who is the Data Controller?
Columbia Estates, International House, Don Road, St Helier, Jersey, JE2 4JE
The Data Protection Officer (DPO)
Columbia Estates has appointed a Data Protection Officer (DPO). Our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the ‘Your Rights’ section below. You can contact our DPO at firstname.lastname@example.org
Like most website operators, we collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non- personally identifying information is to better understand how visitors use our website.
We also collect potentially personally-identifying information like Internet Protocol (IP) addresses for users completing forms on our website. We only disclose logged in user IP addresses under the same circumstances that we use and disclose personally-identifying information as described below.
We may also collect statistics about the behaviour of visitors to our website. For instance, we may monitor the most popular pages on the site. We do not display this information publicly or provide it to others.
Collection of initial Information
We collect information about you during the account registration process for any of our Services.
This information may include, but is not limited to your name, postal address, e-mail address, phone number and any other details as might be requested from you for the purpose of registration and/or continued use of our Services.
We may also collect information from you if you request information or customer support and your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account.
Third party and publicly available sources
Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, credit service and publicly available websites (i.e. social media platforms), to comply with legal and regulatory obligations.
How we use this information
We will, from time to time, send you marketing material which may of particular interest to you based upon your behaviours i.e. your recent property searches. These marketing messages will provide you with information about the services, news and offers available to you by any subsidiary company of Columbia Estates and information about products and services provided by our selected partners and third parties.
Except where we use your personal data for marketing purposes, on the basis of your prior written consent, and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our services.
How information is shared
Your personal and financial information may be transferred or disclosed to trusted third parties, for the processing of that personal information based on our instructions and in compliance with this policy and any other appropriately confidential and secure measures.
Our third-party service providers and partners include, but not limited to:-
- IT hosting platforms.
- Credit reference agencies (merchants only).
- Payment gateway providers.
- Regulatory authorities, government agencies and law enforcement agencies.
- Trading Standards, SoJ Housing Department, Social Security and other consumer bodies.
- Auditors and accountants.
Consent to processing and acceptance of this policy
By providing personal information to us as part of the subscription services, you fully understand and expressly consent to the processing of that data as described within this policy. If you do not agree to this policy, please unsubscribe from property updates and disable your online account.
Under the General Data Protection Regulation (GDPR), you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
- Access to personal data
You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the Contact Us section for information on how to contact us.
You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible but no later than within one month.
- Correction of personal data
You can request us to rectify and correct any personal data that we are processing about you which is incorrect.
- Right to withdraw consent
Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
- Right of erasure
You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances and is not a guaranteed or absolute right. Any regulatory or legal requirement to retain your records will take precedence.
- Right to data portability
This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation.
- Right to restrict processing of personal data
You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
- Right to object to processing of personal data
You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal or regulatory claims.
- Rights relating to automated decision making and profiling
You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect, or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make any automated decisions of this nature.
How to contact us
For any requests related to your personal information or any of your rights referenced above, please feel free to contact us in one of the following ways:-
Post: The DPO, Columbia Estates, International House, Don Road, St Helier, Jersey, JE2 4JE.
Filing a complaint
If you are not satisfied with how we manage your personal data, you have a right to make a complaint to your local Information Commissioner.
Other useful privacy & data security-related matters
We retain personal information for as long as we reasonably require it for legal or business purposes. For the jurisdictions in which operate, and subject to us not having a legal or regulatory requirement or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 5 years following that date on which your relationship with us ceases. We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and Columbia Estates will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.