Last updated: September 2018
Scope
This Privacy Notice (Notice) describes how Property Publishing Group Ltd collects and uses your personal data.
Aims
This Notice tells you what personal data Property Publishing Group collects, why we need it, how we use it and what protections are in place to keep it secure.
Key Terms
The terms PPG, we, us and our mean or refer to Property Publishing Group Ltd.
Personal data means information about individuals (including you), and information from which such individuals could be identified.
GDPR means the EU General Data Protection Regulation
You means any individual whose personal data we process.
Data Controller
PPG is the Data Controller in relation to your personal data and we take care to protect the privacy rights of individuals.
How does PPG obtain your personal data?
We obtain your personal data from you directly, including through your use of this website.
What personal data does PPG collect from (and about) you?
We may collect and use various types of personal data about you, which will vary in nature depending on the circumstances and purpose of processing. Here are some illustrative and non-exhaustive examples:
- personal data about you: name, address, email address;
- personal data to contact you at work or home: name, address, telephone, and email addresses;
- personal data which may identify you: photographs, passport and/or driving licence details, electronic signatures;
- personal data to process any payment we might need to make to you personally: bank account details; and
- personal data to monitor your use of our website: see the ‘website cookies’ section below.
Why do we need to collect and use your personal data?
We may need to collect and use your personal data for one or more of a number of reasons, the primary purpose being to provide our services to our users and subscribers, and this may involve the use of your personal data in one or more of the following (non-exhaustive) ways:
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- to provide you with information requested from us, relating to our products or services;
- to provide information on other products which we feel may be of interest to you, where you have consented to receive such information;
- to meet our contractual commitments to you;
- to notify you about any changes to our website, such as improvements or service/product changes, that may affect our service;
- to provide you with information about goods and services similar to those which were the subject of a previous sale to you;
- to provide you with information about unrelated goods and services which we consider may be of interest to you, where you have consented to such contact at the time your information was collected; and
- to assist fraud protection and minimise credit risk.
What is PPG’s lawful basis for processing your personal data?
Under the GDPR, we must identify a lawful basis for processing your personal data, and that basis may vary according to the type of personal data processed and the individual to whom it relates, and the nature of the processing.
Performance of a contract with you (where applicable)
If you are a subscriber or user of our products or services, or a supplier, or another individual with a direct contractual relationship with us, we are entitled to process the personal data we require in order to fulfil our obligations under our contract with you.
The legitimate interests of PPG or a third party
We may process your personal data on the lawful basis that it is in our legitimate interests and/or the legitimate interests of a third party to do so. This will primarily apply when we provide services to our users and subscribers. Our legitimate interest in such instances is the proper performance of our role as a provider of services.
We may also process your personal data on the basis that it is necessary for our legitimate interest in the effective management and running of our company, which may include (but is not limited to): engaging suppliers; ensuring that our systems are secure and running efficiently; for regulatory and legislative compliance and related auditing and reporting; for marketing and general business development purposes; for insurance purposes; and to facilitate, make and receive payments.
We do not consider that the processing of your personal data on the basis of our legitimate interests as described above (whatever such interests might be) is likely to result in any unwarranted prejudicial effect on your rights and freedoms or your own legitimate interests.
Compliance with a legal obligation to which PPG is subject
In certain circumstances, we may be obliged process your personal data in order to comply with our legal obligations. This might include, but is not limited to, processing required for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation.
More information relating to the lawful bases for processing personal data can be found on the Information Commissioner’s website (see details below).
Special category personal data
If we process any special category personal data, which is data relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data or sexual orientation, we will obtain your explicit consent to that processing, unless this is not required by law (because, for example, it is processed for the purpose of exercising or defending legal claims) or the information is required to protect your health in an emergency. Where we are processing personal data based on your consent, you have the right to withdraw that consent at any time.
To whom do we disclose your personal data?
We may disclose your personal data to third parties (outside PPG), but only when it is necessary to do so, and subject to our obligations of confidentiality. Such circumstances may include but are not limited to: (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and (b) if our business is bought by a third party, in which case personal data held by it about its customers will be one of the assets to transfer to the buyer.
We take suitable steps to ensure that, where the other party concerned is a data processor, they have appropriate data security systems in place and process data solely in accordance with our instructions.
Is your personal data transferred outside the EEA, and if so what safeguards are in place?
Some of the third party service providers we use are based in, or carry out their activities in, countries outside the European Economic Area (EEA). If in the course of providing services to us any of these service providers process personal data, we will take suitable steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this Notice. If you use our services while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with those services.
How do we protect your personal data?
We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any personal data we hold is not accessed by anyone unauthorised to access it, and where applicable to ensure client confidentiality.
When we use third-party organisations to process your personal data on our behalf, we require them to have appropriate security arrangements in place, they must comply with our contractual requirements and instructions, and they must ensure compliance with the GDPR and any other relevant data protection legislation, all as required under the GDPR.
How long will your personal data be retained by PPG?
It is our policy to retain your personal data for no more than the length of time required for the specific purposes for which it is processed by us and which are set out in this Notice. However, we may be obliged to keep your personal data for a longer period, for example, where required by our legal and regulatory obligations, or in order to ensure we have effective IT back-up systems. In such cases, we will ensure that your personal data will continue to be treated in accordance with this Notice, we will restrict access to any archived personal data, and ensure that all personal data is held securely and kept confidential.
Website cookies
On occasion, we may gather information about your computer to facilitate log in and website speed and to provide statistical information regarding the use of our website to our advertisers. Such information will not identify you personally – it is statistical data about our visitors and their use of our site. We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the services that we provide to you.
Our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our website.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our website.
For more information about cookies generally, please visit All About Cookies.
What are your rights?
You have various rights in relation to your personal data under the GDPR:
- the right of access to a copy of the personal data we hold about you;
- the right to require us to correct any inaccuracies in your personal data;
- the right to object to decisions about you being taken by automated means (although we do not make any decisions by automated means);
- where we have sought your consent, the right to withdraw your consent at any time; and
- the right to ask us not to process your personal data for direct marketing purposes.
You may also have the following rights in relation to your personal data in certain circumstances:
- the right to restrict or object to our use of your personal data;
- the right to require us to provide a copy of your personal data to others; and
- the right to require us to erase your personal data.
If you wish to exercise any of your rights please contact us at [email protected].
There are exceptions to the rights of individuals in relation to their personal data and, in certain circumstances, your rights may be limited.
How to make a complaint
If you have a question about the information provided in this Notice, or you have a concern or complaint about the way in which we process your personal data, please contact us at [email protected]. In any event you have the right to address a complaint to the Information Commissioner. The Information Commissioner can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk. The ICO helpline number is 0303 123 1113.