SCOPE

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

RESPONSIBILITIES

The GDPR Owner / Acting Controller is responsible for ensuring that this notice is made available to data subjects prior to Jonathan Rolls collecting/processing their personal data.

All Employees/Staff of Jonathan Rolls who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

PRIVACY NOTICE

WHO ARE WE?

Jonathan Rolls is Property management Business located in Brighton, East Sussex.

Our GDPR Owner / Acting Controller and data protection representatives can be contacted directly here:

• datacontroller@jonathanrolls.com
• 01273 684997

The personal data we may collect and process from you is:

• Name
• Address
• Telephone number
• Email Address
• (Copy) Bank Statement
• (Copy) Passport
• (Copy) Driving License
• Tenant References

The personal data we collect will be used for the following purposes:

• To verify identification of a data subject
• To supply and provide a property management services to our clients and tenants.

Our legal basis for processing for the personal data:

• The Property Management process requires this information before it can act on your behalf.

Any legitimate interests pursued by us, or third parties we use, are as follows:

• Third parties that may receive data are:
• Contractors, Suppliers, with specific permissions only

The special categories of personal data concerned are:

• Racial
• Ethnic origin
• Political opinions
• Religious beliefs
• Philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Health data
• Data concerning a natural person’s sex life
• Sexual orientation

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Jonathan Rolls to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting our GDPR Owner at datacontroller@jonathanrolls.com and requesting a consent withdrawal form GDPR DOC 4.6a.

DISCLOSURE

Jonathan Rolls will not pass on your personal data to third parties without first obtaining your consent. The third parties we use are vetted for security and are known suppliers with good reputation and may only receive your personal data for the following purpose(s) as part of the processing activities:

• To assist in meeting your Property Management and Tenant needs

Any other work you request from us

RETENTION PERIOD

Jonathan Rolls will process personal data for up to 6 years and will store the personal data for a further 7 years.

YOUR RIGHTS AS A DATA SUBJECT

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Jonathan Rolls refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by Jonathan Rolls (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Jonathan Rolls’s data protection representatives GDPR Owner / Acting Controller.

The details for each of these contacts are:

PRIVACY STATEMENT

This privacy statement describes how we collect data, what we do to protect you and your rights as a Data Subject.

ONLINE PRIVACY STATEMENT

PERSONAL DATA

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

HOW WE USE YOUR INFORMATION

This privacy notice tells you how we, Jonathan Rolls, will collect and use your personal data for the purpose of providing Property Management services.

WHY DOES JONATHAN ROLLS NEED TO COLLECT AND STORE PERSONAL DATA?

In order for us to provide you with legal services we need to collect personal data for correspondence purposes and detailed legal service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes, Jonathan Rolls would contact you for additional consent.

WILL JONATHAN ROLLS SHARE MY PERSONAL DATA WITH ANYONE ELSE?

We may pass your personal data on to third-party service providers contracted to Jonathan Rolls in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Jonathan Rolls’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

HOW WILL JONATHAN ROLLS USE THE PERSONAL DATA IT COLLECTS ABOUT ME?

Jonathan Rolls will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Jonathan Rolls is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

UNDER WHAT CIRCUMSTANCES WILL JONATHAN ROLLS CONTACT ME?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

CAN I FIND OUT THE PERSONAL DATA THAT THE ORGANISATION HOLDS ABOUT ME?

Jonathan Rolls at your request can confirm what information we hold about you and how it is processed. If Jonathan Rolls does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Jonathan Rolls or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

WHAT FORMS OF ID WILL I NEED TO PROVIDE IN ORDER TO ACCESS THIS?

Jonathan Rolls accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months), etc.

CONTACT DETAILS OF THE GDPR OWNER / ACTING CONTROLLER:

COOKIE POLICY

INFORMATION WE COLLECT

Information you give us. This is information about you that you give us through our website at www.jonathanrolls.com (our site) or by using our applications, corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our service, our website, or when you contact us by any other means. The information may include your name, and contact details, as well as personal information.

We rely on your consent to process such personal data and this will have been obtained when you provide any personal data to us. Please note, that you have a right to withdraw your consent for processing at any time by emailing info@jonathanrolls.com or writing to us at 74 Preston Drove, Brighton, BN1 6LB. We will stop processing if we have no other legal basis or requirement to do so. Where the personal data collected includes sensitive/special category data, we will obtain a separate, explicit consent from you for this, which may be withdrawn in the same way.

We have a legitimate interest to process your data in order to communicate with and provide our services to you, understand and analyse the performance of the company and to generally manage and improve our operations, as long as this interest is not outweighed by your rights, as detailed below.

HOW DO WE USE YOUR DATA?

All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

We use your data to provide the best possible services to you. This includes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying Our services to you; Personalising and tailoring Our services for you;
• Responding to communications from you;
• Supplying you with emails e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time);
• Market research;
• Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;

In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary to protect the vital interests of you or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child

HOW AND WHERE DO WE STORE YOUR DATA?

We only keep your data for as long as We need to in order to use it as described above, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Please refer to our Privacy Policy for Our Data Retention Policies.

Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our website.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.