Kelproperties (IOM) Limited is committed to protecting and respecting your privacy.

Our Privacy Notice explains the data we collect about you when you interact with us. It gives you detailed information about what we do with your data and how we keep it safe.

We hope that our Privacy Notice will give you clear guidance on how we use your data and what your rights are, but if you have any further questions, please do contact us. You will find our contact details at the end of the Privacy Notice which you can use if you have any questions, including how to update or access your Information or to make a complaint. Please see the page Contact Us.

PRIVACY NOTICE

Kelproperties (IOM) Limited

1. Introduction
2. Who is Kelproperties
3. How we process your Information legally
4. Why we collect your Information and the Information we collect
5. Who we share your Information with
6. How long we keep your Information
7. Where we hold your Information
8. How we keep your Information safe
9. Use of Cookies
10. Links to other websites
11. What are my rights over my Information?
12. How to stop us direct marketing to you
13. Contacting the Regulator
14. Changes to the Privacy Notice
15. Contacting us

INTRODUCTION
Kelproperties (IOM) Limited (from here on called Kelproperties) is committed to protecting and respecting your privacy.

Our Privacy Notice explains the data we collect about you when you interact with us. It gives you detailed information about what we do with your data and how we keep it safe.

We hope that this Privacy Notice will give you clear guidance on how we use your data and what your rights are, but if you have any further questions, please do contact us. You will find our contact details at the end of this Privacy Notice which you can use if you have any questions, including how to update or access your Information or to make a complaint. Please see the section Contacting us.

We use abbreviations in this Privacy Notice:

Contact Information means your name, business name, address, telephone numbers and email addresses.

Information means Personal Data as defined by the GDPR

WHO IS KELPROPERTIES?

A data controller (“Controller”) is the company that decides why and how your Information is processed i.e. how it is collected and used.

When you deal with us, the Controller of your data is Kelproperties. There may be exceptions to this and if there are, we will bring those to your attention.

Where this Privacy Notice refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to Kelproperties as the Controller.

HOW WE PROCESS YOUR INFORMATION LEGALLY

The law allows us to collect and process your Information in certain circumstances:

1. With your CONSENT

In specific situations, we will seek your consent to collect and process your Information. When we seek your consent, we will make clear to you how we would like to use your Information so that you can make an informed decision about whether to allow us to collect and use your Information.

2. Where we have a CONTRACTUAL OBLIGATION

We may need your Information to comply with our contractual obligations to you. We may also require your Information where we take steps towards entering into a contract with you.

3. Where we have a LEGAL OBLIGATION

If the law requires us to, we may collect and process your Information.

4. Where it is in your VITAL INTERESTS

We will use your Information where we consider the processing of your Information will prevent or reduce any potential harm to you. For example, if we need to communicate a product safety announcement to you.

5. Where it is in ours, or someone else’s, LEGITIMATE INTEREST

In certain circumstances we may collect and use your Information where it is reasonable for us to do so in the interests of our business operations and where we consider that doing so will not materially impact your rights, freedom or interests. This means we may use your Information in a reasonable way (that you might expect) but only where we consider this will not cause you any excessive or unnecessary risk.

WHO WE SHARE YOUR INFORMATION WITH

1. We understand that your privacy is important and that you trust us to look after your Information. We will never sell your Information.

2. We may share your Information with carefully chosen third parties that we trust to carry out services on our behalf.

3. When Information is shared with a third party, we will apply a policy to help keep your Information safe:

  • We will provide only the Information they need to perform the services for us.
  • They may only use your Information for the exact purposes we specify in our contract with them.
  • We will work closely with them to ensure that your privacy is respected and protected at all times.
  • If we stop using their services, any of your Information held by them will either be deleted by them or rendered anonymous.

4. We will not share your Information without good reason. Below are some of the categories of third parties who we may share your Information with:

i. Group Companies
We may share your Information with other companies within the group of companies.

ii. Our Suppliers and Service Providers
We may share your Information with our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.

iii. Other third parties
We may also share your Information if we’re under a duty to disclose or share it in order to comply with our legal obligations, to detect or report a crime, to comply with our tax obligations, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our staff and customers. In these circumstances, your Information may be shared with the Police, Isle of Man Government, Isle of Man Treasury or other registered bodies.

HOW LONG WE KEEP YOUR INFORMATION

1. Whenever we collect or process your Information, we’ll only keep it for as long as is necessary for the purpose for which it was collected and to defend any potential claims.
2. At the end of that retention period, your Information will either be deleted completely or anonymised. We may use your data in an anonymised way (so you cannot be identified) for statistical analysis and business planning.
3. When we consider how long to hold your Information, we will consider several factors:
a. whether any legal provisions require a maximum or minimum retention period;
b. whether the business requires the Information and documents for business operations;
c. whether we need to retain your Contact Information to allow us to contact you in the event of any product safety issue;
d. whether the Information and documents we hold may support any legal claim or defence. Where this is the case, we will usually hold documentation for 7 years after our contract with you terminates. This is because the law allows for 6 years to bring a claim in contract law and we allow an additional 12 months for the claim to be served and reviewed.

WHERE WE HOLD YOUR INFORMATION

1. Sometimes we may share your Information with third parties and suppliers outside the European Economic Area (EEA), such as the USA. The EEA includes all EU Member countries and Iceland, Liechtenstein and Norway. We may transfer Information that we collect from you to third-party data processors in countries that are outside the EEA. The table describing our Suppliers and Service Providers above will provide more detailed information about when this may occur.

2. If we do this, we have policies in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.

3. Any transfer of your Information will follow applicable laws and we will treat your Information under the principles of this Privacy Notice.

HOW WE KEEP YOUR INFORMATION SAFE

1. We use technical and organisational security measures to protect the Information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.

2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Information, we cannot guarantee the security of your Information whilst in transit to our website and any transmission is at your own risk.

3. Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to use the same password as on other accounts and not to share your password with anyone.

USE OF ‘COOKIES’

1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By browsing the site, you are agreeing to our use of cookies.

2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Cookies allow our websites to recognise you when you visit.

3. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services;
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
  • COOKIE_MESSAGE – Cookie Message – This cookie tells us whether you have accepted our cookie policy.
  • S-FID – Adobe Analytics – This cookie is used by Adobe Analytics to help measure the amount of traffic on our website.

4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

LINKS TO OTHER WEBSITES

1. Our website may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites and apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness.

Your disclosure of Information to third party websites is at your own risk.

2. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

WHAT ARE MY RIGHTS OVER MY INFORMATION?

1. You have several rights afforded to you under data protection laws. You have the right to:

  • request access to the Information we hold about you, free of charge in most cases;
  • ask for the correction of your Information when it is incorrect, out of date or incomplete;
  • be ‘forgotten’ and that we delete your Information where we no longer need to process it;
  • request that we stop using your Information in a particular way;
  • request that we stop using your Information for direct marketing;
  • withdraw consent that you have previously provided and we must stop using your Information for that purpose;
  • object to any processing that we undertake on the grounds of legitimate interest; and
  • request that we transfer your Information to another ‘controller’ (e.g. an alternative service provider).

2. You have the right to request a copy of the Information we hold. Where any Information we hold is inaccurate, you can request that it is changed. To ask for your Information, please contact us. To ask for your Information to be amended, please contact us.

3. You may ask that we delete your Information and we must do so where we no longer have a reason for holding your Information. Whenever you have given us your consent to use your Information, you have the right to change your mind at any time and withdraw that consent.

We must then delete your Information if we have no other reason for holding your Information.

4. You have the right to request that we temporarily stop using your Information in a certain way.

This right applies where:

  • you think the Information we hold is inaccurate;
  • you think we are processing your Information illegally;
  • we no longer the require your Information but you may require it for legal reasons; or
  • you have objected to us processing your Information (see below) and you await a response from us.

5. Where we are processing your Information on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your Information.

6. You have the right to stop the use of your Information for direct marketing activity through all channels, or selected channels. We must always comply with your request. See section: How to stop us direct marketing to you.

7. If we choose not to action any request from you, we will explain to you the reasons for our refusal.

8. We may ask you to provide evidence of your identity before we process any request. This is to ensure your Information security.

HOW TO STOP US FROM DIRECT MARKETING TO YOU

1. You can stop receiving marketing emails from us at any time by clicking the ‘unsubscribe’ link at the bottom of our emails.

2. You may withdraw consent for marketing by contacting us

3. We will stop all direct marketing to you if you object to marketing by contacting us.

4. Please note that you may continue to receive communications for a short period after changing your preferences whilst we process your request.

CONTACTING THE REGULATOR

We encourage you to get in touch with us directly in the event of any query or complaint here and we will do all we can to resolve any issue you may have. However, if you feel that your Information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your Information, you have the right to lodge a complaint with the Isle of Man Information Commissioner.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice may change. If it does, we will post an updated version on our website. If the changes are material, we may contact you by email to let you know. If you do not agree with the changes, you must notify us immediately by writing to us and stop using our services.

Changes will take effect 7 days after the updated Privacy Notice is uploaded. We recommend that you review this notice from time to time on our website.

CONTACT US

If you have any questions, suggestions or complaints about the processing of your Information or wish to contact us to amend/update your marketing preferences, please contact us using the details below:

kelproperties.com/contact

Company registration number: 008363V

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