This privacy notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during our management of Your Development and after it ends. We are required to notify you of this information under the General Data Protection Regulation.
Please ensure you read this notice (sometimes referred to as a “privacy notice” and any other similar notice we may provide to you from time to time when we collect or process personal information about you. This privacy notice contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
1. WHO WE ARE
PINNACLE PROPERTY MANAGEMENT LIMITED collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
In this privacy notice, references to “we” or “us” means Pinnacle Property Management.
2. DATA PROTECTION PRINCIPLES
We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR data protection policy.
3. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED BY US
In the course of demanding/collecting service charge and or ground rent payments, Receipting Notices of Transfer and/or Mortgage, Consenting to Sublet, arranging maintenance and repair whether planned, emergency or insurance work we collect the following personal information when you provide it to us:
· Name, Address of Property, Correspondence address (if different), Landline and or mobile telephone number, e-mail address, bank account details, mortgage details, vehicle Registration numbers (if appropriate), Marriage Certificate (if appropriate), Death Certificate (if appropriate), Credit/debit Card Details (when making payment)
The provision of Name, Address(es), telephone number(s), email addresses, Marriage Certificate, Death Certificate, bank account and mortgage details is required from you to enable us to perform our contract as managing agent appointed for your Development. Vehicle Registration numbers are required where we have parking control measures in place, Credit or debit card information is only taken when we process a payment from you. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
4. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain personal information from other sources as follows:
· Your Registered Address and any Mortgagor from Land Registry
5. HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the following purposes:
• For the performance of a contract you have with our client pursuant to which we are appointed as their agent on your Development. • For the purposes of our legitimate interests or those of a third party, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share the following categories of personal data:
• Name, address, telephone number(s) and email addresses
This personal information may be shared with the following categories of recipients:
• Contractors, Insurance Brokers, Insurance Companies, solicitors, Courts, IT Support
This data sharing enables us to perform our contract as managing agent.
Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’. We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
7. WHERE YOUR PERSONAL INFORMATION MAY BE HELD
Information may be held at our offices and those of our group companies, and third-party agencies, service providers, representatives and agents as described above.
We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
· We will hold your Name, Address of Property, Correspondence address (if different), Landline and or mobile telephone number, e-mail address, mortgage details for the period we are required to retain this information by applicable UK Tax Laws (Currently 6+ 1 years).
9. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
We rely on Contract as the lawful basis on which we collect and use your personal data.
10. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
· United States of America, Australia and Singapore in order to allow our software provider (Qube (part of the MRI Group)) to offer support and training
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that United States of America, Australia and Singapore provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to the EU-U.S. Privacy Shield Framework which the European Commission has deemed adequate to enable data transfers under EU Law The Privacy Shield Framework is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the Privacy Shield Framework please either click the link or contact firstname.lastname@example.org.
If you would like further information please contact us by telephone 01189 320 180, by email email@example.com or by post to Units 1,2,3 Beech Court, Wokingham Road, Hurst, Berkshire RG10 0RQ. We will not otherwise transfer your personal data outside of the [United Kingdom OR EEA] or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
11. YOUR RIGHTS
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
· fair processing of information and transparency over how we use your use personal information
· access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
· require us to correct any mistakes in your information which we hold
· require the erasure of personal information concerning you in certain situations
· receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
· object at any time to processing of personal information concerning you for direct marketing
· object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
· object in certain other situations to our continued processing of your personal information
· otherwise restrict our processing of your personal information in certain circumstances
· claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
· email, call or write to us
· let us have enough information to identify you (EG FULL NAME, ADDRESS AND PROPERTY ADDRESS),
· let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
· let us know the information to which your request relates, including any account or reference numbers, if you have them
12. KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
13. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].
14. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 16 May 2018 and last updated on 16 May 2018.
We may change this privacy notice from time to time, and when we do we will inform you.
15. DO YOU NEED EXTRA HELP?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).