SEEDERS CAPITAL FOR PROPERTY AND TRADE SERVICES LTD, a company registered in England and Wales under company number 11868281 whose registered office is at Regus - London St Paul's, St. Martin's Le Grand, London, EC1A 4EN (‘Square Seven’, ‘Us’, ‘Our’ or ‘We’ (which shall also refer to Affiliates)) have created this privacy statement (‘Statement’) in order to reflect the transparency requirements expected of Us by law and Our own ethics. In this Statement, references to ‘You’, ‘Your’, ‘Developer Member’ or ‘Buyer Member’ are references to developer and prospective buyer user of the Platform www.square-seven.com.
Your privacy is extremely important to Square Seven and We are only too happy to comply with the law and provide You with clear and transparent information about how We use Your PD. We only process it for the purposes outlined and We process as little of it as possible. Our aim is not to be intrusive and We undertake not to ask You irrelevant or unnecessary questions. We will try Our best to keep Your PD accurate and up-to-date but do try to help Us with this too please! We also have robust measures and procedures in place to minimise the risk of unauthorised access and to keep it secure. Also, We only share it with third parties where We have a right to do so and where We are satisfied that the third party shall treat it with the same or higher levels of respect.
This document outlines how We process Your Personal Data when You use Our Platform or otherwise communicate with Us including by email or telephone. We are committed to respecting Your privacy and protecting Your PD. For the purpose of the Data Protection Legislation, We are the Data Controller (ICO registration number: ZA643399).
We might make changes to this Statement but if We do, We will, where appropriate, notify You by email, or, when You next log in, the amended version (and specific terms) will be displayed on-screen and You may be required to read and accept them to continue.
HOW DO WE PROCESS YOUR PERSONAL DATA?
PERSONAL DATA YOU PROVIDE TO US VOLUNTARILY: In order for Us to provide You with
Our Services, We need to process some of Your PD. We understand that Your PD belongs
to You and You provide it to Us on trust that We will use it lawfully i.e. appropriately,
proportionately, only in respect of the stated purpose and We will only hold on to it
for as short a time as possible. Most important of all, We must have a valid lawful
basis for processing Your PD. Rather than have lots of paragraphs of text where all
these transparency requirements are scattered throughout this Statement, We hope You
find having most of it all in Our tables easier to navigate:
Personal Data (‘PD’) Source Purpose Lawful Basis for general processing Retention Developer Member Data: We will collect Your name, email address, password and other details We collect from You will be Your company details We will obtain this information either from You or via Our lead generation activities which are undertaken in line with Data Protection Legislation. Developer Member Data: to provide You with an online self-service property marketplace for and a Communication Centre for use with Buyer Members. We process Your Personal Data for this purpose under the legal basis of Contract or Legitimate Interest according to Article 6 (1) GDPR Developer Members: We will keep Your personal data for as long as You are subscribed on the Platform and then for 7 years according to HMRC Guidelines. Buyer Member Data: We will collect Your name, phone number and email, password. We will obtain this information either from You or via Our lead generation activities which are undertaken in line with Data Protection Legislation. Buyer Member Data: to provide You with a platform for browsing properties. We process Your Personal Data for this purpose under the legal basis of Contract or Legitimate Interest according to Article 6 (1) GDPR Buyer Members: We will keep Your PD for as long as You are subscribed on the Platform. If You upgrade to Our premium/platinum service, We will keep Your PD for 7 years according to HMRC guidelines.
If You are using Our free service, We will only keep it while You remain subscribed and for 7 days after you terminate your account.
This includes PD which Platform Members may divulge in the Communication Centre.
PD which may be disclosed in the Communication Centre will be generated by the Platform Members. To allow communication between Platform Members. We process Your Personal Data for this purpose under the legal basis of Contract according to Article 6 (1)(b) GDPR Within 7 days of the termination of your account, any PD in the Communications Centre will be deleted. Your name, email, telephone number and query details As above To respond to requests for feedback, information and support from existing or prospective Platform Members. Legitimate Interests Article 6 (1)(f) GDPR As above Prospective Platform Members; name and email address We will obtain this information either from You or via Our lead generation activity, which are undertaken in line with Data Protection Legislation. For marketing purposes We Process Your Personal Data for this purpose under the legal basis of consent according to Article 6 (1)(a) GDPR As long as You are signed up to Our email marketing list. You are Welcome to unsubscribe at any time. Technical Data (as defined) Platform Members To monitor the effectiveness of the Platform and Our Marketing Communications/ Non-Marketing Communications Legitimate Interests Article 6 (1)(f) GDPR and consent where appropriate Article 6 (1)(a) GDPR As above Financial Details Data Subject (Platform Member after the Free Trial where appropriate) To record sales/ purchases made in the business Legal/ Statutory Obligation Article 6 (1)(c) GDPR 7 years from the end of the relevant tax year
- We are growing and We do want to be of value to You during Our relationship so if We ever require further PD from You or if We would like to use Your PD for a different purpose, then We will always provide You with additional information about this at the point that You are invited to make use of these additional services.
- OUR RETENTION RIGHTS: How long We keep Your PD depends on the context in which You provide it and the purpose for which We use it. See the last column in the table above. Do note that We need to retain sufficient information about You in compliance with certain legal or statutory requirements, for example, in the event of a legal or insurance claim in the future so that We can identify You.
- Where We state that We rely on consent to process Your PD for a particular purpose, You have the right to withdraw Your consent at any time. This will not affect the lawfulness of processing carried out by Us which was based on consent before its withdrawal.
- PERSONAL DATA YOU PROVIDE TO US VOLUNTARILY: In order for Us to provide You with Our Services, We need to process some of Your PD. We understand that Your PD belongs to You and You provide it to Us on trust that We will use it lawfully i.e. appropriately, proportionately, only in respect of the stated purpose and We will only hold on to it for as short a time as possible. Most important of all, We must have a valid lawful basis for processing Your PD. Rather than have lots of paragraphs of text where all these transparency requirements are scattered throughout this Statement, We hope You find having most of it all in Our tables easier to navigate:
HOW DO WE USE YOUR PERSONAL DATA TO COMMUNICATE WITH YOU?
NON-MARKETING COMMUNICATIONS: You acknowledge that, Your PD may be used by Us
(or a Service Provider on Our behalf) to contact You when necessary in connection
with Your use of the Platform and to access Our Services as follows:
Non-Marketing Communication? Method of receipt Lawful Basis for general processing Contractual and service messages will be available on the Platform answering requests for information.
(Quarterly performance stats for Developer Members)
Available on the Platform, or by email.
MARKETING COMMUNICATIONS: From time to time and with Your lawful (express or implied)
permission, We (or a Service Provider on Our behalf) send You Marketing Communications
(and monitor whether You have opened the communication and clicked on any included
links which will enable Us to understand Your level of engagement/ interest in the
communication We are sending to You). We want to keep You interested!
Marketing Communication? Method of receipt Lawful Basis for general processing How can You opt out? Email newsletter with information or offers regarding upcoming promotions, services or surveys. If You are a Platform Member, We process Your Personal Data for this purpose under the legal basis of Legitimate Interest according to Article 6 (1)(f) GDPR If You are a prospective Platform Member We process Your Personal Data for this purpose under the legal basis of Consent according to Article 6 (1)(a) GDPR Platform Member: You will be able to log in to Your account at any time to amend Your preference. You amend Your preference by clicking on the link at the bottom of any email communication. OR You can unsubscribe on the email at any time.
- MARKETING COMMUNICATIONS FROM US: If You agree to receiving any of the above Marketing Communications but later change Your mind, You can opt out at any point, by amending Your account preferences on the Platform, Alternatively, You can use the ‘unsubscribe’ link at the end of any electronic communication received by You or simply respond to Our prompt in all of Our communications to You. If You opt out of Our communications, We will retain Your PD on our suppression list so that We comply with Your wishes not to be contacted again.
- LEGITIMATE INTERESTS TO PROCESS YOUR PERSONAL DATA: We may process PD about You where We rely on “legitimate interests” as Our lawful basis. Where this is the case, We will have carried out an assessment to determine that We have valid and lawful rights to do so. Despite this, if it bothers You, You have the right to object to any of the processing We undertake by completing Our Data Subject Rights Request Form.
- PROFILING: We may from time to time use publicly available demographic information to determine who We target for specific events or marketing campaigns so as to avoid contacting individuals unnecessarily. You have the right not to be subject to a decision based solely on automatic processing (Article 22). We undertake profiling when You have visited Our Platform or Facebook Page. Where this is a result of cookie activity You will be asked for Your prior consent for this. You can further manage this via Your cookie preferences via Our Cookie Preference Management Tool.
- RESEARCH & STATISTICS: We may use communications information to compile anonymous statistical reports showing information like the number and type of query and how each has been resolved. Occasionally We will use information provided to develop case studies for learning and development purposes. We will be very careful to ensure that any information that could re-identify a person is removed or changed to preserve anonymity.
• Facebook (Facebook Inc., USA, Data protection declaration: (http://www.facebook.com/policy.php)
• Twitter (Twitter Inc., USA; Data protection declaration: (http://twitter.com/privacy/)
• Pinterest (Pinterest Inc., USA; Data protection declaration: (https://policy.pinterest.com/en-gb/privacy-policy)
• Instagram (Instagram Inc., USA Data protection declaration; (https://help.instagram.com/402411646841720)
• LinkedIn (LinkedIn Ireland Unlimited Company; https://www.linkedin.com/legal/privacy-policy)
• WhatsApp (WhatsApp Inc, USA. Data Protection declaration (https://www.whatsapp.com/legal?eea=0#privacy-policy)
- NON-MARKETING COMMUNICATIONS: You acknowledge that, Your PD may be used by Us (or a Service Provider on Our behalf) to contact You when necessary in connection with Your use of the Platform and to access Our Services as follows:
WHO HAS ACCESS TO YOUR DATA & WHERE IS IT STORED?
We may engage or collaborate with a Third Party for a variety of different reasons. This may be in relation to the performance of Our business and daily operational functions on Our behalf to enable Us to fulfil Our Services only (including making improvements to Our Services). Where it is necessary to share Your PD, We will limit the PD that We share to the minimum required to provide the Service and the Data Processor (or Data Controller) will only be able to use it for the specific purposes for which it was shared. If We stop using the service of a Data Processor, We ensure Your PD is deleted or securely returned to Us.
From time to time, We may transfer Your PD to a related company, agent or contractor (also known as a Joint Data Controller) e.g. where We collaborate on a joint project together.
The last column relating to where the PD goes and what safeguards are in place in the recipient territory where it is stored sets out 1 of 3 options in respect of the Third Party as follows:
STATUS WHERE? MORE INFO AROUND SAFEGAURDS STATUS 1 United Kingdom Should We need to transfer Your PD outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Statement. STATUS 2 Within the EEA Should We need to transfer Your PD outside of the EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Statement. STATUS 3 Outside EEA: US We will not transfer Your PD to any Third Parties based in other countries outside the EEA unless there is a European Commission adequacy decision, the EU-US Privacy Shield Certification or the EU Commission approved Standard Contractual Clauses
If You would like more information about any of the transfer safeguards We implement please contact Us using the details as set out at Clause 5 of this Statement.
Transfer of Personal Data in the Event of the Sale of SEEDERS CAPITAL FOR PROPERTY
AND TRADE SERVICES LTD or its Assets
In the event that SEEDERS CAPITAL FOR PROPERTY AND TRADE SERVICES LTD is sold or transfers some of its assets to another party, Your PD could be one of the transferred assets. If Your PD is transferred, its use will remain subject to this Statement. Your PD will be passed on to a successor in the event of a liquidation or administration.
- THIRD PARTIES:
WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION?
You have a number of rights that You can exercise free of charge and on request
in certain circumstances, however, if Your requests are obviously unfounded or
excessive, We reserve the right to charge a reasonable fee or to refuse to act.
You have the right:
• to be informed about the collection and use of Your PD. This is what this Statement fulfils;
• to access Your PD and supplementary information (‘DSAR’);
• to have inaccurate PD corrected, or completed (if it is incomplete);
• to have Your PD erased;
• to restrict Our processing of Your PD;
• to receive a copy of any PD You have provided to Us, in a machine-readable format, or have this information ported to a third party;
• to object AY ANY TIME to processing of Your PD for direct marketing purposes;
• to object in certain other situations to the continued processing of Your PD.
For more information on these rights and when You can exercise them, see the Information Commissioner’s Guide
- If You wish to exercise any of these rights, please complete Our Data Subject Rights Request Form. We will respond to You within one month from when We receive Your request, unless the complexity and number of requests We receive means that We need more time. If We do need more time (up to two further months), We will tell You why within the first month.
- You have a number of rights that You can exercise free of charge and on request in certain circumstances, however, if Your requests are obviously unfounded or excessive, We reserve the right to charge a reasonable fee or to refuse to act. You have the right:
HOW CAN YOU SUBMIT A QUERY OR A COMPLAINT?
We try to meet the highest standards when processing Your PD. For this reason, We take any complaints We receive about this very seriously. We encourage You to bring it to Our attention. We are happy to provide any additional information or explanation needed in respect of Our processing activities upon request. For all matters relating to privacy and data protection, please contact our Data Protection Manager (DPM) by email to firstname.lastname@example.org or by telephone to +44 (0)2039 851 356 ext 1356.
While We hope to be able to resolve any concerns You have about the way that We are processing Your PD, You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (or with the supervisory authority of the European Member State where You work, normally live or where the alleged infringement of data protection laws occurred) if You believe that Your PD has been processed in a way that does not comply with the Data Protection Legislation or have any wider concerns about Our compliance. You can do so by calling the ICO helpline on 0303 123 1113 or via their Website here.
CHANGES TO THIS STATEMENT
We keep Our Statement under regular review. This Statement was last updated on 07.02.2020
DEFINITIONS & INTERPRETATIONS
Buyer Member: refers to a consumer or business registered on the Square Seven Platform who is given the opportunity to browse the Properties within the Property Portfolio and avail of the Square Seven Buyer Member Services.
Data Controller or DC or JDC or IDC: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of PD (Article 4(7));
Data Processor or DP: means a natural or legal person, public authority, agency or other body which processes PD on behalf of the Data Controller (Article 4(8));
Data Protection Manager (DPM): email@example.com
Data Subject Access Request or ‘DSAR’: refers to right of access as further described in Clause 4.
Developer Member: refers to a property developer business entity registered on the Platform who is given the opportunity to publish and advertise their Property Portfolios on the Platform and to benefit from the Square Seven Buyer Member Services.
EEA: refers to the European Economic Area which consists of all EU member states, plus Norway, Iceland, Liechtenstein.
Electronic Mail: includes but is not limited to email, text, video, voicemail, picture and answerphone messages (including push notifications).
Marketing Communication(s): refers to any communication whether by an Electronic Mail method or otherwise that We send to You (either directly or via a Service Provider) which may include but are not necessarily limited to relevant newsletters and magazines, information about opportunities, products, services and events and relevant information.
Non-Marketing Communication(s): refers to any communication which is functional/administrative only as distinct from Marketing Communications.
Personal Data or PD: has the meaning set out in the Data Protection Legislation.
Platform Members: Refers to a Developer Member and/or a Buyer Member as applicable
Platform Service Terms: referring to Developer Member Service Terms and/or the Buyer Member Service Terms as applicable
Service Provider(s): refers to a Third Party with whom We work with from time to time as a necessary part of providing Our Services and with whom We may need to share Your PD.
Technical Data: refers to that at Clause 1.5 which is capable of being considered PD.
Third Party: refers to a Data Processor or Data Controller with whom We may need to share Your PD. This includes Service Providers.
Contains public sector information from https://ico.org.uk licensed under the Open Government Licence v3.0.