Dartmouth Website Privacy Notice

Dartmouth Capital Advisors Ltd on behalf of Pinenorth Properties Ltd  (“Dartmouth“, “we” and “us“) are committed to protecting the privacy of those with whom we interact and we recognise the need to respect and protect information that is collected or disclosed to us (called “personal information”, explained below).

This Privacy Notice is intended to tell you how we use your personal information, and we’ve tried to explain what we do in enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can’t find the information you need, you can email us at patrickaschan@dartmouthcapital.co.uk.

The Privacy Notice applies to products and websites that refer to or link to the Privacy Notice (collectively, our “Services”)and will apply whether you access our Services using a computer, mobile phone, tablet, TV, or other device.

Please click on the links below for further information on our privacy practices:

1.    Who we are?

2.    What is Personal Information?

3.    How is your Personal Information collected?

A.    Personal Information you provide directly
B.    Automated technologies or interactions
C.   Third parties or publicly available sources

4.    How do we use your information?

5.    To whom do we disclose your information?

6.    What do we do to keep your Personal Information secure?

7.    Accessing your Personal Information and other rights you have

8.    DataRetention – How long will we store/keep your Personal Information

9.    Third-Party Links and Products on Our Services

10.  Cookies

11.  Your Choices (e.g. marketing related emails or otherwise)

12.  Changes to this Privacy Notice

13.  Contact Us /Further Information

1.    Who are we?

We are a leading property advisory  company. We are the controller and responsible for this website.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy Notice, including any requests to exercise you rlegal rights, please contact the Data Privacy Manager using the details set out below.

Contact details

Our full details are:                                    DartmouthCapital Advisors Ltd

Name or title data privacy manager:       Patrick Aschan

Email address:                                           patrickaschan@dartmouthcapital.co.uk

Postal address:                                         Riverbank House, 2Swan Lane, London,EC4R 3TT

 

2.    What is Personal Information and what Personal Information does Dartmouth collect about you?

For the purposes of this Privacy Notice “PersonalInformation” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

—     Identity and Contact Data includes your first name, last name and title, date of birth, postal address, email address and telephone number, payment information(such as credit card and bank account details).

—     Technical Data includes internet protocol (IP) addresses, the type of browser used while visiting our website and the numbers of users who visit our website, usage session dates and duration, page views, and how you use our website, products and services.

—     Marketing Data includes your preferences in receiving marketing from us and your communication preferences.

3.    How is your Personal Information collected?

Dartmouth collects information when a user visits our website, when a customer contacts us whether by the telephone, email or post. We use different methods to collect data from and about you including:

          I.        Personal Information you provide directly. You may give us your Identity and Contact Data andMarketing Data by filling in forms or by corresponding with us by email, phone or otherwise. This includes Personal Information you provide when you:

–       Enquire about any of our developments;

–       Purchase any of our products or services, ; or

–       Otherwise communicate with us.

–       Respond to one of our satisfaction surveys.

         II.        Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies. Please see section 11 below for further details.

       III.        Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:

–       Technical Data from Google Analytics.

–       Identity and Contact Data from our third party agents, including our real estate agents.

–       Identity and Contact Data from publicly available sources such as the Land Registry.

 

4.    How do we use your information?

We may use the PersonalInformation we collect for the following purposes:

I.        Deliver our products and services – as well as to administer systems and accounts;

II.        Process payment for purchases or other services.

III.        Product Improvement – to enhance our products and the user experience and to develop new products;

IV.        Customer Support Services – to answer your questions or respond to your requests and to provide other customer support services;

V.        Analysis Purposes – for assessment and analysis of our market, customers, products, and other services, and to create sales, marketing and promotional plans and programs;

VI.        Crime Prevention – for protecting against or identifying possible fraudulent or other illegal transactions;

VII.        Business Purposes – for business monitoring and internal record keeping;

VIII.        Legal Obligations – to comply with our legal obligations; and

IX.        Updates – to communicate with you, including communicating with you about your transactions with us, giving you important information about your products, sending you notices about any material changes to our Privacy Notice, and, where permitted by you and applicable laws, marketing, sending you offers and promotions for our products.

The law allows us to use thePersonal Information as set out above on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our “legitimate interests” in the promotion and efficient running of our business. Where we need to protect you against or identify possible fraudulent transactions, we will do so in accordance with our legal obligation placed on us under law.

Marketing communications

Dartmouth may use your Personal Information to provide you with email notifications and other communications by email and and/or text message (SMS), on the basis that such use is necessary for the purposes of the legitimate interests pursued by us in promoting our business. For further information on this, see the ‘Your Choices’ section of this Privacy Notice.

5.    To whom do we disclose your information?

We will only use your PersonalInformation for our internal business purposes, some of which are mentioned above. However, we may disclose your information to the following entities:

                       I.        Property Agents and otherBusiness Partners

We may need to transfer your Personal Information to our property agents and other business partners including contractors and developers to provide the products you require or any other services/assistance you request. All of our business partners are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.

                      II.        Service Providers

We use third party service providers to help us to administer certain activities and services on our behalf, such as providing IT support and CRM services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:

a.    IT Provider – we use an external IT services provider to provide our website and support our services. The IT provider we currently use is AF ITLtd.

b.    CRM system – we use an external client relationship management system implemented by Reapit Limited.

                     III.        Third parties when required byLaw or to Protect our Services

We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our products);to operate and maintain the security of our products (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property ofDartmouth, including enforcing any terms or agreements governing the use of our products.

                    IV.        As part of the sale of Dartmouth to another company.

                      V.        Other Parties At Your Direction

We may share Personal Information about you with third parties when you request to such sharing, including your financial adviser, solicitor or accountant.

 

6.    What do we do to keep your information secure?

We have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our products. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

International Transfer of Data

The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area (“EEA“),including but not limited to Serbia or in any other country where Dartmouth orDartmouth’s service providers maintain facilities.

By using or participating in any Service and/or providing us with your PersonalInformation, you acknowledge that we will collect, transfer, store and process your information outside of the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located. Where we transfer your Personal Information outside the EEA to our IT provider, Alteacasa LLC, which is located in Serbia, we use the EU Model Clauses to ensure the recipient provides an adequate level of protection to your Personal Information.

Where we transfer your PersonalInformation outside the EEA to other third parties, we will ensure that appropriate transfer agreements and mechanisms are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information.

7.     Data Retention – How long we will store/keep your PersonalInformation

Dartmouth retains PersonalInformation for as long as necessary to fulfil the purposes for which yourPersonal Information has been collected as outlined in this Privacy Statement unless a longer retention period is required by law. When your PersonalInformation is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

8.    Your Choices (e.g. marketing related emails or otherwise)

When you purchase our products or services, request information from us, or otherwise communicate with us, we may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you, marketing-related correspondence by email and and/or text message (SMS) related to our products.When we process your Personal Information for marketing purposes, we do so on the basis that it is in our legitimate interests to do so.

We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.

To opt out of receiving marketing-related correspondence from Dartmouth, please click”Unsubscribe” from any marketing or promotional email or text message(SMS) you receive from us, or contact us at patrickaschan@dartmouthcapital.co.uk.

9.    Accessing your PersonalInformation and other rights you have

Under certain circumstances and to the extent provided forby applicable law, you have the following rights in relation to your Personal Information:

  1. Access – you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
  2. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
  3. Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time.  In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 13.
  4. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
  5. Erasure (‘right to be forgotten’) – you have the right to have your Personal Information ‘erased’ in certain specified situations.
  6. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.
  7. Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
  8. Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.

Enforcing your rights

If you wish to enforce any of your rights under applicable data protection laws, then please contact us at patrickaschan@dartmouthcapital.co.uk.We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.

Complaints

If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk)which is the data protection regulator in the UK which is where DartmouthCapital Advisors Limited is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.

10. Third-Party Links and Products on Our Services

Our websites, applications and products may contain links to other third party websites that are not operated by Dartmouth, and our websites may contain applications that you can download from third parties. These linked sites and applications are not underDartmouth’ control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites or applications, any PersonalInformation collected by the third party’s website or application will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

11. Cookies

What are cookies?

Dartmouth may use cookies on our website. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user’s internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed). Cookies collect and store information about a user’s preferences, product usage and content viewed which allows for Dartmouth to provide users an enhanced and customized experience when engaging with our website.

The vast majority of web browsers accept cookies. However you do have the ability to decline cookies by modifying the settings on your browser. If you do this please be aware that restricting or deleting cookies may impact on the functionality of the website.

Dartmouth only uses”strictly necessary” cookies. These are cookies that are required for the operation of our website. For more information on cookies, please visit www.allaboutcookies.org which provides general information and how you can manage cookies on your computer.

12. Changes to this Privacy Notice

It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting notice of the changes on the Dartmouth website or through any relevant Services.

13.  Contact Us / Further Information

If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Information, please contact us:

                                I.        By mail:

Data Protection Manager

Dartmouth Capital Advisors Limited

Riverbank House

2 Swan Lane

London

EC4R3TT

 

                               II.        By email:

patrickaschan@dartmouthcapital.co.uk

                              III.        By telephone:

02076290239

Monday to Friday 09:30 – 17:30 

Date last updated: 01 September 2018

Cookies

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