Newton Property Management respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after and deal with your personal data and tell you about your privacy rights and how the law protects you.
Purpose of this Privacy Notice
This privacy notice aims to give you information on how Newton collects and processes your personal data through your use of this website, including any data you may provide through this website when using our Pay Online feature.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
Newton Property Management Ltd (SC224378) is the controller of your personal data and is responsible for this website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
If you wish to contact us, our full details are:
Full name of legal entity: Newton Property Management Ltd (SC224378)
Name of Data Privacy Manager: Derek MacDonald
Email address: firstname.lastname@example.org
Postal address: 87 Port Dundas Road, Glasgow, G4 0HF
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority 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 Notice and Your Duty to Inform us of Changes
We may update this privacy notice from time to time. Please review this privacy notice periodically for changes. This privacy notice was last updated on 12th June 2018.
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.
Third Party Links
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, plug-ins and applications and we 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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Purposes for Which We Will Use Your Personal Data
We have set out below, in the following table, a description of all the ways we plan to use your personal data, and which the lawful basis on which we rely on to do so.
Please note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful Basis for Processing|
|To process instructions and deliver a service (including providing customers with the products and services they require, managing payments, fees and charges and to collect and recover money owed to us)||Identity, Contact, Financial, Transaction, Marketing and Communication||Performance of a contract with you and necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Usage
Marketing and Communications and Technical
|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 business sale) and necessary to comply with a legal obligation|
|To use data analytics to improve our website, products and services, marketing, customer relationships and experiences||Marketing and Communications, Technical and 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)|
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Marketing and Promotional Offers from Us
We may use your Identity Data, Contact Data, Usage Data and Marketing and Communications Data to promote our products, services and offers which may be relevant for you or which may be of interest to you (we call this marketing).
You will receive marketing communications from us if you have provided us with your details and you have opted-in to receiving that marketing.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of products or services we provide to you or other transactions.
Third Party Marketing
We will get your express opt-in consent before we share your personal data with any third parties for marketing purposes.
Change of Purpose
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The personal data we collect will be stored within the European Economic Area (“EEA”). However, in some instances, we may need to transfer data outwith the EEA for processing. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Exercising your rights
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 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.