Find a Property Limited is committed to maintaining the accuracy, confidentiality and security of personal information it holds in accordance with the relevant laws. This Privacy Notice describes the personal information that we collect, how we use and to whom we disclose this information. For the purposes of this Privacy Notice: Data Protection Law (‘DP Law’) means the relevant legislation in Gibraltar: Data Protection Act 2004 (as amended)
What is personal information?
For the purposes of this Privacy Notice, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.
Personal information does not include anonymous or non-identifiable information (i.e. information that cannot be associated with or tracked back to a specific individual).
Types of Personal Data we collect, process, hold and share include:
• Date of birth
• Residential Address
• Contact details
• Proof of identity
• Employment information
• Background check data
• Source of funds (where relevant)
• Source of wealth (where relevant)
• Bank details
• Occupation / outside interests
• Special categories of data including criminal information
• Cookies and usage data (website)
Why do we collect and use this information?
• Providing our contracted services
• Maintaining and using relevant electronic filing systems
• Conducting anti-money laundering/countering the financing of terrorism risk reviews
• Keeping records up to date
• Complying with any requirement of Law, Regulation or reporting to a Regulatory or Tax authority
• As an employer
• Monitoring and analysing website traffic (see Cookies section below)
We do not use automated decision making (including profiling) in any circumstances.
In the future, if we intend to process personal data for a purpose other than that which it was collected, we will update this Privacy Notice, providing information on that purpose and any other relevant information.
The lawful basis on which we process this information
Find a Property Limited processes personal data, including any special category data, to comply with its legal and contractual obligations.
Collecting this information
Most of the information we hold will have been collected directly from the individual concerned upon our request. In some cases, we collect data from third parties, for example, referees and background checking services.
browser settings. Please note however that you may be unable to use some features of the website if cookies are disabled.
Storing this information
We hold personal data both in hard copy files and on IT systems. The information will be stored until the expiration of a period of six years after the termination of our relationship. We take the security of personal data seriously. We have internal policies and controls in place to ensure that personal data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
What is a cookie? A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognise your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself. Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences), and to personalise your content (eg. advertising, language). Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.
Types of cookies and how we use them
Essential cookies: Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.
Performance cookies: Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use performance cookies on our site. Functionality cookies Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and timezone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.
Targeting/advertising cookies: Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service.We use targeting/advertising cookies on our site.
Our third-party privacy promise: We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.
Who we share this information with?
Access to personal information is limited only to staff who need it in order to fulfil their duties. Personal data may be shared with contractors as necessary to fulfil our legal and contractual obligations. In limited and necessary circumstances, your information may be transferred outside of the European Economic Area, or countries not appearing on the EC Adequacy List, to comply with our legal or contractual requirements.
In such cases we have implemented safeguards to ensure the security of your data, including written contracts with the relevant parties.
Your Rights Under the General Data Protection Regulation (GDPR) and the DP Law
You have certain rights with regards to your personal data. You have the right to request from us access to and rectification of your personal data. In certain circumstances, you have the right to request erasure of your personal data, the right to restrict processing, the right to object to processing, and the right to receive your data in a machine-readable format. If you would like to make a request under any of the above-mentioned rights, please contact the relevant Find a Property Limited Responsible Officer listed below, preferably by email or regular post.
You have the right to file a complaint with the relevant data protection regulatory body (see below) if you believe that we have not complied with the requirements of GDPR or the DP Law with regard to your personal data.
Identity and contact details of controller and Responsible Officer
Find a Property Limited is a controller and processor of data for the purposes of GDPR and the DP Law. If you have any concerns as to how your data is processed, you can contact: Keith Nairn
Email address: email@example.com
Correspondence address 83 Governor’s Street, Gibraltar, GX11 1AA
Local Regulatory Authority Gibraltar Regulatory Authority firstname.lastname@example.org
This policy is effective as of 1st January 2022