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Privacy Policy…

HOW WE USE YOUR INFORMATION

This Privacy Policy is set out to inform you of how we will process your data and is applicable each time you visit and or submit your data to us through this website, or via any other means (e.g. email, fax or telephone). It applies to information we collect about:

• Visitors to our website
• People who use our services
• Job applicants and our current and former employees

Oxygen Property Management (OPM) operates as a Data Controller. It is our duty to protect the data you submit to us. We regularly train our staff on data protection compliance and maintain robust policies and procedures to ensure your personal information is processed in accordance to such laws.

We take our obligations under the Data Protection Acts very seriously. Please note OPM have a separate set of Data Protection internal policies & procedures which relate to the protection of your personal information and become applicable when:
- You rent a property through OPM (Tenants)
- You let your property through OPM (Landlord)
- You sell your property through OPM (Vendor)
- You buy a property through OPM (Buyer/Investor)
- You contact OPM with any enquiry

You may request to see a copy of our policy by getting in touch with our team (Section 11). As a policy becomes relevant to you, our team will provide you with access/a copy.

1. RELEVANT LEGISLATION
This privacy policy sets out how OPM uses and protects the personal information which you provide to us when you use and or submit your details through this website and other related websites in compliance with the following legislations:

• UK Data Protection Act 1988 (DPA)
• EU Data Protection Directive 1995 (DPD)
• EU General Data Protection Regulation 2018 (GDPR)

This sites compliance with the above legislation means that this site is likely to comply with the data protection and user privacy legislation set out by many other countries and territories. If you are unsure about whether this site is compliant with your own country of residence’s specific data protection and user legislation you should contact our team outlined in section 11.

2. LAWFUL BASIS FOR PROCESSING PERSONAL DATA
OPM will process the data you submit to us through this website under the lawful basis of “Consent” when you choose to opt-in to our Marketing updates.

OPM will process the data you submit to us through this website under the lawful basis of “Legitimate Interests” when you contact us via a submission form for any reason other than to opt-in to our Marketing updates.

By visiting this website and submitting your information through any of our online forms, you consent to this & our privacy policy as set out below.

3. THIRD PARTIES & YOUR INFORMATION
OPM will not transfer, disclose, sell, distribute or lease your personal information as submitted through this website to third parties (except as otherwise set out in this Policy) without your permission or if we are permitted or required to do so by law or the legal processes.

4. PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS, WHY WE COLLECT IT & HOW WE USE IT
This website collects and uses personal information for the following reasons:

4.1 SITE VISITOR TRACKING (COOKIES)
This website uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our website to better understand how they find and use our web pages as well as to see how they navigate through the website.

GA records data such as device, internet browser & operating system, geographical location and duration of visit, none of this information personally identifies you to us. GA records your computer’s IP address which could be used to personally identify you but this information is not granted or accessible to us. We consider Google to be a third party data processor. (See section 9).

GA utilises cookies, details of which can be found on it’s website (Click here to view)
OPM’s website then uses the analytics.js implementation of GA.

If you do not wish to be tracked, you can disable cookies on your internet browser, which will eliminate GA from tracking any part of your visit to pages within this website. For more information on this, please see our Cookie Policy.

4.2 CONTACT & ENQUIRY FORMS, REDEEM OFFER FORMS, REGISTRATION, SEND TO A FRIEND FORMS & E-MAIL LINKS
When you contact us by submitting any of the above forms or through an e-mail link, none of the data you supply will be stored by this website or passed to/ to be processed by any of the third party processors identified in section 9 unless you explicitly request for us to do so.

The data you submit through the above form will be collated into an e-mail and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by SSL meaning that the email content is encrypted before being sent across the internet. The e-mail is then decrypted by our local computers and devices.

Once this data arrives, we will deal with your enquiry accordingly. Your details will not be stored unless you explicitly agree for us to add you to our Subscription list, in which case your details will be added through our subscription process as outlined in section 4.3 below.

4.3 SUBSCRIPTION TO OUR NEWSLETTER*,* SPECIAL OFFERS* & REGISTRATION FORMS (SELECTING TO BE ADDED TO OUR MAILING LIST)
If you are under 18 years of age you MUST obtain parental consent before joining our email newsletter.Please note we will not hold on to your information for longer than is necessary and you may opt-out (unsubscribe) of any OPM Marketing Mailing List that you submit to us, subject to legal excemption.

If you choose to join any of our mailing database (e-mail newsletter, property mailout and/or special offer mailout) the personal data that you submit to us will be sent via e-mail to our Marketing representative. They will then process your data by adding your submitted details to MailChimp who provide us with mail marketing services. We consider MailChimp to be a third party data processor (see section 9). Mailchimp are fully compliant with GDPR as can be seen here.

The personal data that you submit will not be stored within this website’s own database or in any of our internal systems. The e-mail containing your details will be permanently deleted following upload to MailChimp. This process can take up around 4 working days.

Your personal data will remain within MailChimp’s database for as long as we continue to use WixShoutOut’s services for marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email offer and/or newsletter that we send you or by requesting removal via email. When requesting removal via email please send your email to us using the email account that is subscribed to the mailing list.

While your personal data remains within MailChimp's database, you will receive periodic newsletter style emails from us. The nature of these e-mails will consist of information relative to your request i.e. property market reports, news etc. We may, from time to time, contact you to check that the details we have are accurate and factual (ie. If you registered to receive property updates, we may ask you if you are still searching for a property).

5. INFORMATION IN AGGREGATE
Occasionally, OPM may use and disclose anonymised* information (*individual customers cannot be identified) for marketing and strategic development purposes (ie. identifying most common age group to purchase a property within a given postcode). This would not constitute of your personal information because you would not be identified or identifiable from it. The purpose of disclosing this information would be purely informative of a statistical/qualitative nature and may be used as content for internal reports and external literature. If you do not wish for us to use your personal data in this manner, you have the right to refuse and we will eliminate your data from this process.

6. HOW WE STORE YOUR PERSONAL INFORMATION
Once your submission form arrives in our mailbox and we successfully process your enquiry, your details will be permanently deleted from our system. OPM only store your personal data when given explicit permission to do so i.e. when you subscribe to our newsletter or when you become a client (a new privacy policy will be presented to you at the applicable time). Your information is not stored on this website. Once a form is submitted, it arrives in the means outlined within the section relevant to your submission form (Section 4).

7. USER PRIVACY/ DATA PROTECTION RIGHTS & COMPLAINTS

7.1 YOUR RIGHT TO:

ACCESS
It is your right to request copies of information we hold about you which you have submitted to us. You may do this by e-mailing us with your request as outlined in section 11. We will provide any copies within one calendar month, subject to any legal exemptions.

RECTIFICATION
If you have given consent for OPM to hold on to your details, we will contact you within 24 months of your data submission to check that your details are accurate. Should you wish to make changes to your details prior to our contact, please get in touch with our team as outlined in section 11.

ERASURE
You may at any given time request that we erase your details. You may do this by contacting our team (section 11) or, if part of a mailing list, by unsubscribing by clicking on the link provided at the bottom of our e-mail. We may refuse to erase any information which we are required to keep by law (e.g. financial information we may be required to transfer to HMRC).

OBJECT
You have a right to object to your information being processed and may do so at any time by contacting our team, details are set out at section 11 below. OPM will respect all objections unless there is a lawful requirement to retain the data (e.g. for legal, accounting or tax purposes).

If you do not agree to your personal information being used in accordance with this privacy policy you should not submit your personal information to us through this or other related websites, in writing or other forms of contact.

If your personal information was provided to us by other means, you should tell us by contacting our team as set out in section 11.

PORTABILITY
You have a right to access any information which is held about you in a machine readable and structured format (e.g. digital records which are held in common formats) transferred to another data controller (e.g. another service provider). Upon receiving a data transfer request from you in writing OPM will transferred any such data which may be held, subject to any legal exemptions.

COMPLAINTS
If you feel there is a problem with the way we have handled your data or suspect it has been breached through our means, you may wish to raise a complaint by getting in touch with our team as set out in section 11. We strive to respond to complaints within 72hrs (working week days). A formal investigation will take place and a resolution letter will be sent to you within 3 weeks of your request.

If you still feel the matter is not resolved to your satisfaction, you may wish to contact the Information Commissioner’s Office (ICO) to raise a formal complaint, via their website live chat option and /or online concern forms through this link  or via telephone: 0303 123 1113.

8. ABOUT THIS WEBSITE’S SERVER
This website is hosted by Keepnet on the company owned infrastructure Tier 3+ Data Centre in England. All servers are physically secured by biometric buildings and data hall access, locked by physical steel cage racks with 24hr, 365 day security personnel. Further details of which can be found here.

All traffic (transferral of files) between this website and your browser is protected by HTTPS using modern TLS 1.2 encryption.

Our company e-mail access is also protected by HTTP encryption services.

9. OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data submitted through this website on your behalf. All have been carefully chosen and all comply with legislation set out in section 1. Third parties which process data when you visit or submit your details on this website are as follows:

- Google ( Read Privacy Policy)

- MailChimp ( Read Privacy Policy)

- Microsoft Outlook (E-mails) (Privacy Policy)

-Keepnet (website server)

10. DATA BREACHES
It is our duty to notify you of any unlawful data breaches within our systems and any third party data processors that may impact you without undue delay. We also have a duty to notify the Information Commissioners Office within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been compromised.

11. CONTACTING US REGARDING DATA
Please refer all Data queries to us using the following contact details:

Klaudia Bacinska
(Allocated Data Protection Officer)
This email address is being protected from spambots. You need JavaScript enabled to view it.

or

OPM Team
This email address is being protected from spambots. You need JavaScript enabled to view it.

Tel: 0207 055 8000

12. RESTRICTIONS
This website is not intended for use by individuals under the age of 18. Minors under the age of 18 should not submit any personal information to us through this website.

13. RISKS
Despite external and internal efforts for safeguarding and security of any website in the wold, the internet is not a 100% secure portal for communication. Personal information submitted and/or communicated through the internet may be intercepted by other people. OPM cannot guarantee 100% security of personal information sent to us through this website, but understands its duty of maintaining safety measures in place to prevent misconduct of this nature. By visiting this website and/or submitting your details, you accept that you use this website at your own risk.

14. CHANGES TO OUR PRIVACY POLICY
Our privacy may change from time to time with legislation or industry developments. OPM cannot be held liable against any issues arising from any implemented changes not reviewed by you, therefore it is recommended that you review this page regularly. Your continued use of this website after changes have been made to this privacy policy will be taken to indicate that you have read and accepted any changes implemented. You should not use this website if you do not agree with any changes to this privacy policy and it is your responsibility to tell us if those changes mean that you are no longer happy with the way in which we use your personal information.

15. Change Log
09/04/2018
- Policy changed to reflect GDPR legislation

OPM date of incorporation is: 07/02/2008, registered in England and Wales No. 6526890 and VAT Registered: GBP 922 898191
Registered Office: Oxygen Property Management, Unit A The Oxygen, 18 Western Gateway, London, E16 1BL.

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