Privacy Policy
INFORMATION AND WHO WE ARE
We are committed to protecting and respecting your privacy.
This policy (together with our Terms of Use and Cookie Policy) sets out how we (9E Media Ltd) will process any personal data we collect. By visiting our Website/App you are accepting and consenting to the practices described in this policy, so please read it carefully.
TYPES OF DATA WE COLLECT AND PROCESS
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone numbers.
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 (or promotions you participate in).
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, device ID and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website, products and services (including Uniform Resource Locators (URL) clickstream to, through and from our website/app (including date and time); properties 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).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you either or:
apply for our products or services;
create an account on our Website/App;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will 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 [LINK] 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
Technical Data is collected from the following parties:
analytics providers such as Google based outside the UK
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services the UK.
Identity and Contact Data is collected from data brokers or aggregators.
Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based, land registry inside the UK.
HOW WE USE YOUR INFORMATION
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
We use your personal data in the following ways:
|
Purpose/Use |
Type of
data |
Legal
basis [and retention period] |
|
To register you as a new user |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To carry out our obligations arising from
any contracts entered into between you and us and to provide you with the
information, products and services that you request from us. For example, we
need your contact information to correspond with you regarding any enquiry relating
to a promotion on the Website/App. |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries |
(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 manage our relationship with you |
|
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/App (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/App content and online 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,
customer relationships and experiences and to measure the effectiveness of
our communications and marketing |
(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 send you relevant marketing communications and make personalised
suggestions and recommendations to you about goods or services that may be of
interest to you based on your Profile Data |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to carry out direct marketing,
develop our products/services and grow our business) |
|
To carry out market research through your voluntary participation in
surveys |
|
Necessary for our legitimate interests (to study how customers use our
products/services and to help us improve and develop our products and
services). |
Direct Marketing
During the registration process on our Website/App when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Nine Elms Real Estate via e-mail, SMS, telephone or post.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by logging into the Website/App and checking or unchecking relevant boxes to adjust your marketing preferences.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.
HOW WE DISCLOSE YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006).
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
Local providers of goods and services, for the purpose of permitting them to provide you with information about upcoming events, promotions, products and services we feel may interest you. For example, retailers with on-site locations may be given anonymous information about local residents' purchase histories in order to provide the most advantageous offers and promotions at the most effective time.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If 9E Media Ltd or its affiliates or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of 9E Media Ltd, our customers or others.
SECURE STORAGE OF YOUR PERSONAL DATA
he data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us and use secure remote access when outside the EEA.
By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
All information you provide to us is stored on our secure servers. You are responsible for keeping your password and username confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website/App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or loss of your data.
RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period after they cease being customers.
In some circumstances you can ask us to delete your data.
THIRD PARTY LINKS
Our Website/App may, from time to time, contain links to and from the websites/apps of our partner networks, advertisers and affiliates. If you follow a link to any of these websites/apps, please note that these websites/apps have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites/apps.
YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see above for details of how to object to receiving direct marketing communications).
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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
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
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us.
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: marketing@9elms.app
COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review.
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, for example a new address or email address.