Privacy Policy from Golden Triangle Properties
Golden Triangle Properties (Golden Triangle Group LTD) Protecting our users personal data is an important concern for our company. All of Golden Triangle Properties web activities comply with European legislation and the GBDe Recommendations (linked to: http://www.gbde.org/) issued in September 2001.
This privacy policy governs the treatment of the information Golden Triangle Properties gathers on you when you visit this Web site.
Introduction
Welcome to the Golden Triangle Group Limited privacy
notice.
We respect your privacy and are committed to protecting your
personal data. This privacy notice will inform you as to how we
look after your personal data and tell you about your privacy
rights and how the law protects you.
This privacy notice is provided in a layered format so you can
click through to the specific areas set out below. Please also use
the Glossary to understand the meaning of some of the terms used in
this privacy notice.
1. Important Information and Who We Are
2. The Data We Collect About You
3. How Is Your Personal Data Collected
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Glossary
1.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Golden
Triangle Group LTD collects and processes your personal data
through your use of this website or our services, including any
data you may provide through this website when you sign up to our
newsletter, purchase a product or service or take part in a
competition. This website is not intended for children.
It is important that you read this privacy notice together with
any other privacy notice or fair processing notice we may provide
on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are
using your data. This privacy notice supplements the other notices
and is not intended to override them.
Controller
Golden Triangle Group LTD is the controller and responsible
for your personal data (collectively referred to as "Golden
Triangle Properties", "we", "us" or "our" in this privacy
notice
We have appointed a data protection officer (DPO) 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 your legal rights, please
contact the DPO using the details set out below.
Contact details
Our full details are:
• Full name of legal entity:
Golden Triangle Group LTD
• Name or title of DPO:
Robert Brand
• Email address:
info@goldentriangleproperties.com
• Postal address:
Unit 6, Stone Street, Hadleigh, Suffolk, IP7
6DN
• Telephone number:
01473 812049
You have the right to make a complaint at any time to the
Information Commissioner's Office (ICO), the UK supervisory
authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before
you approach the ICO so please contact us in the first
instance.
Changes to the privacy notice and your duty to inform us of
changes. This version was last updated on 16 May
2018. It is important that the personal data we hold
about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins
and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our
website, we encourage you to read the privacy notice of every
website you visit.
2.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you
including through:
• Direct interactions. You may give us your Identity,
Contact and Financial Data by filling in forms or by corresponding
with us by post, phone, email, instant messenger or
otherwise:
o apply for our products or services;
o create an account on our website;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us some feedback.
• 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 data by using cookies, server logs and other
similar technologies. We may also receive Technical Data about you
if you visit other websites employing our cookies. Please see our
cookie policy for further details.
• Third parties or publicly available sources. We may
receive personal data about you from various third parties and
public sources as set out below:
o Technical Data from analytics providers such as Google
based outside the EU.
o Identity and Contact Data from publicly available sources
such as Companies House, HM Land Registry and the Electoral
Register based inside the EU.
3.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information
about an individual from which that person can be identified. It
does not include data where the identity has been removed
(anonymous data).
We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together
follows:
• Identity Data includes first name, maiden name, last
name, username or similar identifier, marital status, title, date
of birth and gender.
• Contact Data includes billing address, delivery
address, residency status, passport copies, email address and
telephone numbers.
• Marketing and Communications Data includes your
preferences in receiving marketing from us and our third parties
and your communication preferences
• Financial Data includes bank account and payment card
details.
• Transaction Data includes details about payments to
and from you and other details of products and services you have
purchased from us.
• Technical Data includes internet protocol (IP)
address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating
system and platform and other
technology on the devices you use to interact with or access this
website.
• Profile Data includes your membership identification
number, purchases or orders made by you, your interests,
preferences, feedback and survey responses.
• Usage Data includes information about how you use our
website, products and services.
We also collect, use and share Aggregated Data such as statistical
or demographic data for any purpose. Aggregated Data may be derived
from your personal data but is not considered personal data in law
as this data does not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However,
if we combine or connect Aggregated Data with your personal data so
that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance
with this privacy notice.
We may collect any Special Categories of Personal Data about you
(this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and
genetic and biometric data).
We do not collect information about criminal convictions or
offences.
If you fail to provide personal data:
Where we need to collect personal data by law, or under the terms
of a contract we have with you and you fail to provide that data
when requested, we may not be able to perform the contract we have
or are trying to enter into with you (for example, to provide you
with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this
is the case at the time.
4.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following
circumstances:
• Where we need to perform the contract we are about to
enter into or have entered into with you.
• Where it is necessary for our legitimate interests
(or those of a third party) and your interests and fundamental
rights do not override those interests.
• Where we need to comply with a legal or regulatory
obligation.
Generally we do not rely on consent as a legal basis for
processing your personal data other than in relation to sending
third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing
at any time by contacting us.
Purposes for which we will use your personal data:
We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal
bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your personal data for more than one
lawful ground depending on the specific purpose for which we are
using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal
data where more than one ground has been set out in the table
below.
Purpose/Activity |
Type of data |
Lawful basis/bases for processing including basis of
legitimate interest |
To register you as a new client or customer |
(a) Identity (b) Contact |
Performance of a contract with you |
To process and deliver your requests and orders
including: (a) Fulfilment of requests placed by you or on your behalf (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or
complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of
data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you
and measure or understand the effectiveness of the advertising we
serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business
and to inform our marketing strategy) |
To use data analytics to improve our website,
products/services, marketing, customer relationships and
experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our website
updated and relevant, to develop our business and to inform our
marketing strategy) |
To make suggestions and recommendations to you about goods or
services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our
products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain
personal data uses, particularly around marketing and
advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and
Profile Data to form a view on what we think you may want or need,
or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this
marketing).
You will receive marketing communications from us if you
have requested information from us or placed a request with us or
purchased goods or services from us or if you provided us with your
details when you entered a competition or registered for a
promotion and, in each case, you have not opted out of receiving
that marketing.
Third-party marketing
We will get your express opt-in consent before we share your
personal data with any company outside the Quintessentially group
of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you
marketing messages at any time by contacting us at any
time.
Where you opt out of receiving these marketing messages,
this will not apply to personal data provided to us as a result of
a product/service purchase, product/service experience or other
transactions.
Change of purpose
We will only use your personal data for the purposes for
which we collected it, unless we reasonably consider that we need
to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original
purpose, please contact us.
If we need to use your personal data for an unrelated
purpose, we will notify you and we will explain the legal basis
which allows us to do so.
Please note that we may process your personal data without
your knowledge or consent, in compliance with the above rules,
where this is required or permitted by law.
5.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set
out below for the purposes set out in the table in paragraph 4
above.
• Internal Third Parties as set out in the
Glossary.
• External Third Parties as set out in the
Glossary.
• Third parties to whom we may choose to sell,
transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge
with them. If a change happens to our business, then the new owners
may use your personal data in the same way as set out in this
privacy notice.
We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not
allow our third-party service providers to use your personal data
for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our
instructions.
6.
INTERNATIONAL TRANSFERS
We share your personal data within the Golden Triangle
Properties. This may involve transferring your data outside the
European Economic Area (EEA).
Many of our external third parties are based outside the
European Economic Area (EEA) so their processing of your personal
data will involve a transfer of data outside the
EEA.
Whenever we transfer your personal data out of the EEA, we
ensure a similar degree of protection is afforded to it by ensuring
at least one of the following safeguards is
implemented:
• We will only transfer your personal data to
countries that have been deemed to provide an adequate level of
protection for personal data by the European
Commission.
• Where we use certain service providers, we may
use specific contracts approved by the European Commission which
give personal data the same protection it has in
Europe.
• Where we use providers based in the US, we may
transfer data to them if they are part of the Privacy Shield which
requires them to provide similar protection to personal data shared
between the Europe and the US. For further details, see European
Commission: EU-US Privacy Shield.
Please contact us if you want further information on the
specific mechanism used by us when transferring your personal data
out of the EEA.
7.
DATA SECURITY
We have put in place appropriate security measures to
prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to
know. They will only process your personal data on our instructions
and they are subject to a duty of
confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do
so.
8.
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as
necessary to fulfill the purposes we collected it for, including
for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal
data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process
your personal data and whether we can achieve those purposes
through other means, and the applicable legal
requirements.
By law we have to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for
seven years after they cease being customers for tax
purposes.
In some circumstances you can ask us to delete your data:
see Request erasure below for further information.
In some circumstances we may anonymise your personal data
(so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information
indefinitely without further notice to you.
9.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data
protection laws in relation to your personal data. To find out more
about these rights, please refer to paragraph 10
below:
• Request access to your personal
data.
• Request correction of your personal
data.
• Request erasure of your personal
data.
• Object to processing of your personal
data.
• Request restriction of processing your personal
data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above,
please contact us.
No fee usually required:
You will not have to pay a fee to access your personal data
(or to exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request
in these circumstances.
What we may need from you:
We may need to request specific information from you to help
us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to
any person who has no right to receive it. We may also contact you
to ask you for further information in relation to your request to
speed up our response.
Time limit to respond:
We try to respond to all legitimate requests within one
month. Occasionally it may take us longer than a month if your
request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you
updated.
10.
GLOSSARY
Lawful Basis:
Legitimate Interest means the interest of our business in
conducting and managing our business to enable us to give you the
best service/product and the best and most secure experience. We
make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by
the impact on you (unless we have your consent or are otherwise
required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by
contacting us.
Performance of Contract means processing your data where it
is necessary for the performance of a contract to which you are a
party or to take steps at your request before entering into such a
contract.
Comply with a legal or regulatory obligation means
processing your personal data where it is necessary for compliance
with a legal or regulatory obligation that we are subject
to.
Third Parties
Internal Third Parties
• services pursuant to the contract we are about
to enter into or have entered into with you.
• IT and system administration services and
undertake leadership reporting.
External Third Parties
• Franchise partners acting as joint controllers
or processors who may provide services pursuant to the contract we
are about to enter into or have entered into with
you.
• Service providers acting as processors based
who provide IT and system administration services.
• Professional advisers acting as processors or
joint controllers including lawyers, bankers, auditors and insurers
who provide consultancy, banking, legal, insurance and accounting
services.
• HM Revenue & Customs, regulators and other
authorities acting as processors or joint controllers based in the
United Kingdom who require reporting of processing activities in
certain circumstances.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a
"data subject access request"). This enables you to receive a copy
of the personal data we hold about you and to check that we are
lawfully processing it.
Request correction of the personal data that we hold about
you. This enables you to have any incomplete or inaccurate data we
hold about you corrected, though we may need to verify the accuracy
of the new data you provide to us.
Request erasure of your personal data. This enables you to
ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to
ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your
request.
Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts
on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your
personal data in the following scenarios:
(a) if you want us to establish the data's
accuracy;
(b) where our use of the data is unlawful but you do not
want us to erase it;
(c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal
claims; or
(d) you have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use
it.
Request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us
to use or where we used the information to perform a contract with
you.
Withdraw consent at any time where we are relying on consent
to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to
provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your
consent.