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GDPR DATA PRIVACY NOTICE

This is the privacy notice of the Shaviram Group.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you. This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

  1. WHO WE ARE AND IMPORTANT INFORMATION
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. DATA SECURITY
  7. YOUR LEGAL RIGHTS
  8. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
  9. QUERIES, REQUESTS OR CONCERNS

1. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, or as a client of the Shaviram Group.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy 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.

Data controller(s)

Shaviram Investments Limited is the controller and responsible for is the controller and responsible for personal data of users of this website. The contact details for Shaviram Investments Limited is Shaviram Investments Limited, Farley Court, Allsop Place, London, NW1 5LG. For all data matters contact enquiries@shaviram.com or call +44 (0)250.20 7123 4250.Companies in the Shaviram Group which process data are the data controllers for their respective activities. The contact details for each company is your usual contact.

Third-party links outside of our control

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. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We do not 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your 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.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you:

  • You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications; or
  • request marketing to be sent to you.

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:

  • Performance of Contract this 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.
  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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).
  • Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • 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 at enquiries@shaviram.com or calling +44 (0)20 7123 4250.

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, with the legal bases we rely on to do so.

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 at enquiries@shaviram.com or calling +44 (0) 207 1234 250 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.

Shaviram Clients (Including Buyers, Tenants and Other Customers)

Types Of Personal Data Collection Purpose Disclousre Retention Period

Information such as:

  • Your name;
  • Your postal and email address;
  • Your phone number(s);
  • information regarding your moving situation;
  • personal identification documentation;
  • financial information:
    • as evidence of proof of funds (buyers and tenants);
    • to transfer funds; and
    • to reimburse funds (tenants);
  • images/photographs of your property;
  • and information regarding your employment status and salary (buyers and tenants).

Your personal data will be collected from various sources including:

  • when you contact us via email, telephone or in person;
  • providers of background checks;
  • notes and records kept for the duration of your engagement with us as a Client (including details of any instructions, complaints and meetings with us regarding our relationship and your engagement as a Client);
  • CCTV while on our premises; and
  • publicly available sources.

Your personal data following purposes:

  • delivering and improving the services we provide to you;
  • internal administration management purposes;
  • fulfilling our contractual obligations;
  • fulfilling our legal obligations;
  • Achieving certain Legitimate Interests, including:
    • responding to direct requests for property information from an individual; and
    • ensuring the contractual expectations of our customers and clients are satisfied (for example, passing on new tenant information to utility companies), and
  • where you have given us your clear, unambiguous consent to do so, your personal data may be used to contact you about and provide you with:
    • communications and/or marketing material for which you have specifically subscribed; and/or
    • to contact you about, and provide you with, the communications we think are relevant to your interests and preferences.
  • Photographs and images of your property (internal and external) may be used in our marketing and promotional material including our Website only where you have given us explicit consent to do so. Often you will have given this consent as part of formalising our engagement.

Your personal data may be transferred to:

  • our third party service providers who support the operation of our business;
  • other parties involved in the transaction, for the purposes of fulfilling our contractual obligations;
  • other third parties such as our legal and other professional advisers and government departments; and
  • where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you.

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

We will only retain your personal data for as long as necessary to fulfil the purpose.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

Subscribers to our promotional material

Types Of Personal Data Collection Purpose Disclousre Retention Period

Information such as:

  • name and business information;
  • email address;
  • job title and who you work for.

Additional information may be processed where it is provided by you, for example:

  • in correspondence, in connection with any properties, or in letting us know your interests and how/when you wish to be contacted by us
  • in letting us know your interests and how/when you wish to be contacted by us

Your personal data is collected when you register and ‘opt in’ to receive:

  • marketing/promotional material;
  • information and updates about our properties; and details of events.

You can contact us at any time to amend your preferences or opt out of communications from us. You will also be sent the option to opt out of future communications in every communication you receive from us.

Where you have given us your clear, unambiguous consent to do so, your personal data will be used to:

  • contact you about, and provide you with, the communications we think are relevant to your interests and preferences;
  • understand our subscribers’ preferences and interests so we may improve our services, communication and marketing material.

Your personal data may be transferred to our third party service providers who support the operation of our business..

Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you..

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

We will only retain your personal data for as long as necessary to fulfil the purpose.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

Users of our Website

Types Of Personal Data Collection Purpose Disclousre Retention Period

Information such as:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, type of device used to access our Website and the location of where you access our Website via a mobile device;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and your name and email address/other contact details.

Your personal data is collected when you:

  • use our Website (e.g. browsing, searching);
  • provide us with personal information to enable us to contact you and let us know of your marketing preferences; and contact us via email
  • contact us using our online forms.

Your personal information is used to:

  • tailor and enhance your user experience;
  • improve the functionality of our Website;
  • ensure our Website caters to our users’ preferences;
  • contact you about, and provide you with, the communications we think are relevant to your interests and preferences; and contact you and provide you with information about our services.

Your personal data may be transferred to our third party service providers who support the operation of our business.

Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to carefully selected third parties (including but not limited to Facebook) who may process your personal data to provide you with information about properties and/or property related services.

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

you with information about services we feel may interest you..

We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.

We will only retain your personal data for as long as necessary to fulfil the purpose.

We will ensure we keep all personal data up to date and shall archive and then permanently delete any personal data which is not necessary for the purpose.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website.

The individual cookies we use are:

Cookie Name Purpose Expiry
XSRF-TOKEN Ensures visitor browsing security by preventing cross-site request forgery. This cookie is essential for the security of the site and visitors. 1 day
shaviram_group_session Works with the XSRF-TOKEN cookie, ensuring that forms on the site are not submitted by a different domain. 1 hour

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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 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. WHO WE SHARE YOUR PERSONAL DATA WITH

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.

  • Specific third parties listed in the table in paragraph 4 above.
  • 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. 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.

7. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

No fee required – with some exceptions

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 admin 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.

8. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 2nd April 2020.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

9. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact:

  • enquiries@shaviram.com or calling +44 (0)20 7123 4250.
  • Other queries: your usual Shaviram contact person

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner's Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

This document is intended to serve as general guidance only and does not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This document should not be used as a substitute for consultation with professional legal or other competent advisers.

You can download a copy of this policy via this link