Welcome to Justin Robinson Property and our website at www.justinrobinsonproperty.com (our “website”). At Justin Robinson Property we are committed to protecting and respecting your privacy. 

This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website or our customers or potential customers, or other business partners or in any other cases where we specifically state that this policy will apply. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data. 

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?

“Processing” means and covers virtually any handling of data.

WHAT LAW APPLIES?

We will only use your Personal Data in accordance with the UK`s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHO IS RESPONSIBLE FOR DATA PROCESSING?

The responsible party within the meaning of the above is Parfinch Sourcing Ltd, C/O Property Accounts, 59 Castle Street, Reading, RG1 7SN ​(“Justin Robinson Property”, “we”, “us”, or “our”). If you want to contact us or if you have any questions, you can reach us by email using hello@justinrobinsonproperty.com or call +44 7838 216562.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

  1. a) Personal Data that you give us:

This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), or when you use our services, or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with us; and information about your requirements, background and interests. 

We also process the Personal Data involved in your use of our services in order to be able to provide our property sourcing and portfolio growth services. The Personal Data obtained from or provided by you depends on how you are using our services and your particular requirements and may include your contact details, contract details, payment information and data relating to your preferences. The purpose of using your data in that context includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations and in individual cases, your consent.

When you go ahead and download our publications and resources, your IP address is requested and logged for documentation purposes. This is a mere technical process and required to make our Publications and Resources available for download to your device or depending on your browser available for viewing. The basis for this storage is the provision of a contract and our legitimate interest. If you register during the download process for our mailing list, we may send you the occasional email for marketing purposes. The only data required for our mailing list is your name and email address. The processing bases are your consent and our legitimate interest. 

We use your data (name and email address) provided by you when you subscribe to our newsletter within the legally permissible scope for marketing purposes. You can unsubscribe at any time via the link provided for this purpose in each email we send or by sending us an informal message. After unsubscribing, your email address will be deleted immediately. 

  1. b) Personal Data that our website and other systems collect about you: 

If you visit our website it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website. 

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the DPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy.

DATA PROCESSING THROUGH THIRD-PARTY SERVICES 

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”) on our website. This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. 

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any: a) Hosting: Namecheap, Inc; b) Content Management System: WordPress.ORG; c) Fonts: Google Font API; and d) Spam Protection: reCAPTCHA from Google. 

HOW WILL WE USE YOUR PERSONAL DATA?

We may collect, store and use your Personal Data for the following purposes:

  • to operate, manage, develop and promote our business and, in particular, our relationship with you and related transactions including, for example: 
    • marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you); 
    • accounting and billing / payment purposes;
    • to operate, administer and improve our website and other aspects of the way in which we conduct our operations;
    • to offer you our property sourcing and portfolio growth or auxiliary services;
    • to provide you with services or information that you may have requested; and
    • to keep you informed and updated on relevant or services you may be interested in.
  • to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; 
  • to comply with our legal and regulatory obligations and bring and defend legal claims and assert legal rights; and
  • if the purpose is directly connected with an assigned purpose previously made known to you.

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances we may also be required by law to disclose or otherwise process your Personal Data. 

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

  1. a) Internal

If necessary, we transfer your Personal Data within Justin Robinson Property. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries. 

  1. b) External bodies

Personal Data is transferred to our service providers in the following instances:

  • in the context of fulfilling our contract with you,
  • to use marketing services and to advertise our services online,
  • to communicate with you,
  • to provide our website, and 
  • to state authorities and institutions as far as this is required or necessary.
  1. c) International transfers 

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

SOCIAL MEDIA

We are present on social media on the basis of our legitimate interest (currently Facebook, Instagram and LinkedIn). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

MARKETING 

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance where:

  • it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it; 
  • we believe that your Personal Data that we hold is inaccurate; or 
  • in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website. 

YOUR RIGHTS AND PRIVILEGES 

  • Privacy rights 

You can exercise the following rights under the DPA and the GDPR:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;
  • Updating your information and withdrawing your consent 

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

  • Access Request 

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

  • Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is The Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO

  • What we do not do
  • We do not request Personal Data from minors and children;
  • We do not process special category data without obtaining prior specific consent;
  • We do not use Automated decision-making including profiling; and
  • We do not sell your Personal Data.

HOW DO WE MAKE CHANGES TO THIS POLICY?

We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.

EFFECTIVE DATE

Sunday, 07th of July, 2024