Last update: 04.05.2020
This Policy only applies to information we process when you use our Website. It does not apply to the practices of companies that we don't own or control, or employees that we don't manage. Please do not provide us with any Personal Data if you do not want that information to be used by us in this manner.
We may update this Policy from time to time and will notify you of changes to this Policy affecting your rights by posting on our Website. The changes will take effect as soon as they are posted on the Policy page.
Whitewill may collect, store and use information in accordance with the Data Protection Act 2018 (the “DPA“) and any other relevant legislation and regulations.
For the purposes of the DPA, we are the data controller of any Personal Data information we process about you.
2. What Personal Data is collected and its purpose
With regard to each of your visits to the Website, Whitewill will automatically collect the following Personal Data:
Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit to the Website, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; download errors, length of visits to Websiteand methods used to browse away from the page.
We collect this information to improve our Website, fulfil our administrative purposes, protect our business interests, for market research, analysis, testing and monitoring.
Whitewill will collect your telephone number if your wish to download catalogue of new developments in London. We collect this Personal Data in order to establish contact and communicate with you, also for our own internal record-keeping requirements.
If you object to the use of your Personal Data to fulfil any of the purposes set out above, please contact us. Whilst your decision to provide your Personal Data to Whitewill is generally voluntary, if you do not provide certain information Whitewill may not be able to accomplish some of the purposes outlined in this Policy. For example, we may not be able to contact you without knowing your telephone number.
We may collect other types of Personal Data in exceptional circumstances only. If we do need to process additional types of personal data about you, we will make sure that you are informed about the processing of your personal data and that there is a valid legal basis for doing so (e.g. your consent).
3. What is the legal basic of the use of the Personal Data?
Legitimate Interests: As required by us to pursue our own legitimate interests, in particular:
- to communicate with you;
- to help us monitor, improve, administer and protect our Website;
- to measure or understand the effectiveness of advertising we serve to you and others.
Consent: Subject to the following, Whitewill will contact you and send you catalogue of new developments in London. This will only be sent where you have given your consent to Whitewill.
4. How do we keep your Personal Data secure?
We understand the importance of keeping your Personal Data secure. Whitewill has implemented a number of technical, organizational and administrative measures to ensure the confidentiality, integrity, availability and privacy of your Personal Data and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction which are generally accepted by the industry to protect the Personal Data in its possession. For example, our IT systems are protected by firewalls; regular software updates and anti-virus protections. If we become aware of a data breach we will notify the Information Commissioner's Office in a timely manner. We may also notify you if we believe the breach is serious.
5. How long do we keep your Personal Data for?
Under data protection laws, we cannot retain your personal information in a form that identifies you for longer than is necessary to fulfil the purposes for which we collected it. This may include for the purposes of satisfying any legal, accounting or reporting requirements.
We store your telephone number for 1 (one) year.
In order to determine how long we store your Personal Data for, we take into consideration why we need to continue to store your Personal Data, whether we can achieve the same result without having access to your data, and what the potential risk is if there is a data breach that affects your data.
As for technical information and information about your visit to the Website we anonymise this data which means that it is no longer associated with you. We do this for statistical or research purposes so we can improve the Website we offer to you. We can use anonymous data indefinitely without further notice to you.
6. Who will your Personal Data be shared with?
We may share your Personal Data with:
You or those acting on your behalf;
Companies or other entities within our group under common control for the purposes described in this Policy and always in accordance with the terms of this Policy;
To any third party to who we believe we are required, by law, to disclose the information; and
To any third party to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.
This sharing will be for the purposes set out above or to comply with specific legal obligations to which we are subject.
Whitewill uses appropriate safeguards to protect Personal Data which is transferred to countries outside of the European Economic Area which are considered to provide a lower level of protection for personal information.
7. International Data Transfers
We store your information primarily within the European Economic Area. However, some features and requirements, may involve transferring your information to third-parties outside the European Economic Area. We have described all those third parties above in the Section “Who will your personal data be shared with?”. Where such third parties are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, the transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism such as the Privacy Shield Framework.
8. Your rights in relation to your Personal Data
Here we have summarised the principal rights that you have under data protection law. Some of the rights are complex, might contain restrictions depending on the legal basis for processing the data and not all of the details have been included in our summaries. For example, you will not be able to request that we delete all of your information if you have purchased a property from us because it will be necessary for the contract you have entered into. We will always let you know the legal basis for this. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by contacting our customer support.
(b) the right to rectification;
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
(c) the right to erasure;
You have the right to the erasure of your personal data. We have described our policy for retaining and deleting personal data above in Section 5.
(d) the right to object to processing;
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
(e) the right to data portability;
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
(f) the right to complain to a supervisory authority;
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
(g) the right to withdraw consent.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by contacting our customer support.
9. Your right to lodge a complaint with the information commissioner's office
You have the right to complain to the Information Commissioner's Office (ICO) if you believe we have not handled your request in an appropriate manner. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
For information on contacting the ICO please see their website at www.ico.org.uk.
10. Updates of the Policy
This Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of Whitewill. When we do, we will post a notification on the main page of our Website, revise the updated date at the top of this page. We encourage you to check this page with a regular frequency for any changes to stay informed on how we help to protect the Personal Data we collect. Each Visitor must acknowledge and agree that it is his personal responsibility to review this Policy periodically and become aware of modifications.
By using our Website, you automatically signify your acceptance of this Policy. If you do not agree to this Policy, we would require you not to use our Website.
11. How can you contact us?
If you have any questions about this Policy, would like to update information we have about you or would like to exercise any of the rights mentioned, you can either:
Email us: email@example.com
Write to us: Moscow, Presnenskaya naberezhnaya, 6/2, Empire Tower, office 4315