Privacy Statement Summary:
Who will use my data? Costa Team Ltd
We will store and process your data in order to allow us to provide our estate agent and associated property management services to you whether you contact us an owner [vendor], buyer, agent, investor, or in any other capacity. We will respect your rights under all data protection regulations and take precautions to keep your data safe. We will process your data as required to provide our services to you including recommending options, completing ID checks, preparing contracts, managing property sales and other processes as required. With your explicit consent may also use your data to process financial transactions including payments and where strictly necessary we may process more sensitive information about you.
What will happen if I contact you?
If you contact us, we will use your information to send you the information you have requested including updates and other information that we think you will be interested in. If you choose to use our services, we may collect more information from you and where necessary share your information with carefully selected third parties required to provide the services you have requested. Where we share your data this will be as you would reasonably expect and always with your consent
What data will be stored?
We will store your personal details, and where necessary family, financial, and other information, in order to provide our services to you. We will store your details plus relevant information relating to enquiries, contracts, financial, and other information as required. This may include sensitive personal information but only with your explicit consent.
What data will be shared?
We will not share your data with any third parties other than as described here. We are obliged to share your information with any regulator or legal body that requests it.
Your data will be stored only for as long as strictly necessary to provide our services to you and meet our legal obligations after which time your data will be deleted. We will of course respect your rights under data protection laws to rectify your data, delete your data and stop processing should you request this.
Who can access my data?
We will never sell, share or otherwise distribute your data to any other third party other than as required to provide our services to you. We ensure access is restricted to only those persons authorised by us to access your data.
How is my data kept secure?
We will store your data on secure EU based servers which will be processed in the UK. We use industry standard security protocols/technology to secure data.
We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services you may be interested in. We will never sell, share or use your personal information other than as described here.
This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Costa Team Ltd. The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:
· Be processed fairly and lawfully
· Be obtained only for specific, lawful purposes
· Be adequate, relevant and not excessive
· Be accurate and kept up to date
· Not be held for any longer than is necessary
· Processed in accordance with the rights of the data subjects
· Be protected in appropriate ways
· Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection
We take these responsibilities seriously, this document describes our approach to data protection. This policy helps to protect us from data security risks, including:
· Breaches of confidentiality. For instance, information being given out inappropriately.
· Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
· Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
· Loss, damage, or other consequences of such a breach or security failure
Who We Are And How To Contact Us
Costa Team Ltd is a trading name of Costa Team Ltd that is registered in UK and is registered with the Information Commissioner’s Office.
The data controller is: Hugh Steele-Perkins:
Post: Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX
Costa Team Ltd is an estate agent specialising in Spanish properties. We provide a range of property related services. Processing of your data is required in order to offer you these services and for us to meet our contractual and/or legal commitments to you.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
· Names of Individuals
· Postal addresses
· Email Addresses
· Telephone numbers
· Financial information
· Family/Personal information
· Criminal convictions or pending legal action against you
· Sensitive personal information
· Any other information relating to individuals as required to provide our services to you
What this policy applies to
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:
· The Information you provide when you contact us
· As a vendor or buyer when you contact us about our property services. producing contracts, ID checks, financial transactions and other related services
· Information we collect about how you use the website
· Information we collect through our marketing channels such as Facebook, Google Adwords, and other online channels.
· Information relating to other products and services including personal, financial and other possibly sensitive information required to provide these services to you
· Information that is given and stored as part of our ongoing relationship
· Information we collect from third parties and other agencies
· Information we collect from social media and other public domain sources
· This website uses Google Ads’ free conversion tracking features on certain pages. If you contact us online, the destination page will have code on it that will help us understand the path you took to arrive on that page.
· This website uses FACEBOOK ad display/tracking features on certain pages. If you contact us online, the destination page will have code on it that will help us optimise our advertising campaigns. You can manage your Ad Preference settings in your Facebook account.
We do not normally collect or process sensitive data about you, however where it is necessary to process sensitive information we will abide by GDPR Article 9 requirements and take appropriate precautions to protect your data.
How your information will be used
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:
Purpose/Activity Type of data Lawful basis for processing
To register you as a client of ours (a) Identity, (b) Contact, (c) Financial, (d) Personal including sensitive, (e) other information as required (a) To provide our services to you, (b) Performance of a contract with you, (c) In our legitimate interest
To process and deliver the services you request including managing payments, fees and charges, and to 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 owed to us
To administer and protect our business and our site (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 content and advertisements to you and measure and understand the effectiveness of our advertising (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 services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical, (b) Usage Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about 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 services and grow our business
We may collect and process information about you strictly as required to provide our services to you. The data we collect will depend on the nature of the services offered and whether you are a tenant, landlord, investor or other relevant party. The information processed could include but not limited to:
· Your name, date of birth, address, contact details (including email address and mobile phone number)
· Your request details including personal information you send to us
· Financial/employment/criminal convictions/address history, data acquired, collected, and processed as part of any application, credit check, identity check, or payment (including previous addresses, employment details and bank account details)
· Other information as necessary to complete our checks, complete any contracts, and to manage our ongoing relationship
We may take personal information from the following sources:
· Information that you provide to us when registering with our website or contact us by any other means (including your email address)
· Information that you provide when completing your application, contract or other documentation
· Information relating to any services you use or requests you make
· Information from a range of sources as required including online advertising platforms [Facebook, Google Adwords etc…] social media and other companies / agencies
Personal data we receive will be used for the purposes it was provided, including but not limited to:
· To respond to queries from you regarding our services
· To carry out our obligations arising from any contracts entered into between you and us including provision of services, and to respond to queries from you regarding those contracts
· To manage and administer the relationships between you and us
· To notify you about changes to our services and to otherwise communicate with you
· To obtain feedback from you regarding us and our services.
How to change your preferences
We operate in line with EU GDPR (May 2018) data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at anytime.
Scope of Agreement
We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
Opting out at a later date
Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at anytime. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.
How we store and process your data
Your data will be collected stored and processed in the EU only, we do not transfer your data outside the EU. Your data will be stored for up to 7 years to ensure we have records of service, payments, and other interactions we have with you. For details on retention periods please ask for a copy of our Data Retention and Erasure policy.
In order to provide our services to you, we use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU, if this is the case we will ensure precautions are in place to protect your data.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
You will only receive marketing communications from us if you have:
· Requested information from us or used our services
· Used our services previously vendor/seller, investor, or other third party
· If you provided us with your details and confirmed at the point of entry of your details for us to send you marketing communications
· You have not opted out of receiving marketing
· If you are a limited company and we believe our services will be of interest to you
We will get your explicit consent before we share your personal data with any third party for marketing purposes.
We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR (2018) in the way we use and share your personal data. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
· 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.
You can see more about these rights at: https://ico.org.uk/
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.
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 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.
We may have to share your personal data with the parties set out below for the purposes described in this document:
· Contractors, agents, and other third-parties necessary to meet our obligations to you, as required to run our business, and in order to meet our legal obligations
· Utility companies, local councils, and other third parties in order to fulfil our commitments to you and to meet our contractual obligations
· Service providers who provide IT and system administration services
· Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services
· HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
· Third parties to whom we sell, transfer, or merge parts of our business or our assets
Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
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.
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Contacting us, exercising your information rights and Complaints
Information Commissioner’s Office