JIA LONDON LIMITED
WEBSITE PRIVACY POLICY 2019
Who we are
We are JIA London Limited (company number 11985623) and our address is Oakcroft House 1 Hampden Hill Close Ware Herts SG12 7JU (referred to as "we" or "us" or "our"). We are the providers of the website www.jialondon.com (referred to as the "Site").
We provide this Site for our members so that they can advertise or purchase properties online. "Our members" include: private indviduals, estate agents, commercial agents, letting agents, landlords, new homes developers and UK and overseas property owners.
A reference to "you" or "your" is a reference to a user of the Site or any of our services.
INTRODUCTION
We are committed to protecting your privacy. This privacy policy (referred to as the "Policy") explains how and for
CONTACTING US
If you would like to stop receiving marketing and communications from us please contact us at tim@jialondon.com or please write to us at Oakcroft House 1 Hampden Hill Close Ware Herts SG12 7JU.
If you have any questions about this Policy or our use of your personal information or would like to submit a subject access request or exercise your other data subject rights, please contact our Data Protection Officer via email at tim@jialondon.com or please write to us at Oakcroft House 1 Hampden Hill Close Ware Herts SG12 7JU.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
PROPERTIES ADVERTISED ON THE SITE
What we collect and where it comes from
· In the course of providing our services, we collect property data such as images of properties, property asking prices, sales history and sold prices, property addresses, property locations and property descriptions.
· The property data is provided to us by our members or other third parties on behalf of those members.
Why we collect it
· We will use this information for a number of reasons including:
o to provide the JIA London Site;
o to enable our members to advertise their properties to the largest online audience available;
o to enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in;
o to allow users to see current property trends such as the prices of houses for sale in their local area; and
o for our own commercial purposes such as to identify trends in the property market, automated survey and valuation tools, and to build property databases.
Our lawful basis for processing this personal data
· We have a legitimate interest to process this information. These legitimate interests are:
o providing a service to our members by helping them to market properties;
o providing a service to our members by advertising properties to potential purchasers or tenants;
o providing a service to potential purchasers and tenants so that they know what properties are currently on the market and the price of those properties; and
o to provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.
How long we will keep it for
· We will stop advertising a property when we are instructed to do so by our members.
· However, the property information will remain available on the Site as historical property information to allow users to benefit from services such as identifying previous for sale or sold prices (please see the historical property data section below for further information).
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INFORMATION YOU GIVE TO US
What we collect and where it comes from
· We will collect the information that you give to us when using our Site or services:
Enquiries to our members:
o if you choose to access a particular search feature or to fill in a form on the Site you may be asked to provide information about yourself, such as your name and contact details. We may also collect other information about you at the same time, such as details of the sort of property you are interested in, the cost and location of the property, and your current residential address;
o if you choose to contact us or a member using the member telephone number on Site, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.
Registered Users and Property Alerts:
o information that you provide to us when you register as a JIA London user and/or request property email updates such as Property Alerts about when a property is placed on the market in your chosen postcode and meeting your search parameters;
General Site Use:
o information that you provide when participating in discussion boards or other social media functions on our Site and enter into competitions, promotions or surveys available on the Site;
Communications:
o information that you provide to us by corresponding with us by phone, e-mail or otherwise; and
Investors
o information that you provide to us when browsing our plc investor pages.
Why we collect it
· We will use this information:
Enquiries to our members:
o to make sure that you receive the benefit of the JIA London service. This may include transferring your property enquiry to our member advertising that property so that they can respond to your enquiry. Some of our members may use lead handling agencies who handle and process your enquiry on their behalf;
o for training and monitoring purposes where calls are recorded;
o to profile your lead activity on our Site or telephone calls to our Members to enhance the service you receive from our Members. If you want to know more about this, see "Lead Profiling" below.
Registered Users and Property Alerts:
o to provide you with the benefit of services for registered users only;
o to provide Property Alerts to you of new properties marketed on our Site that meet your search criteria;
General Site Use:
o to provide the Site to you;
o to enhance the services that you select on our Site;
o to process any queries that you have about JIA London or its members;
o to customise and enrich your experience on our Site;
o to contact you for your views on our services and to notify you occasionally about important changes to our Terms of Use or this Policy or developments to this Site or our services;
o to deliver relevant advertising to you whilst you are on the Site;
Communications:
o to process and resolve any queries that you may have; and
Investor Relations:
o to allow you to subscribe for relevant JIA London regulatory alerts;
o to process and respond to any queries that you might have.
Our lawful basis for processing this personal data
· We have a legitimate interest to process this information. These legitimate interests are:
o Enquiries to our members:
to provide a service to our members and/or to provide a service to you;
o Registered User and Property Alerts:
to provide you with our services;
o General Site Use:
to gain information about the use of our Site and any improvements that can be made as well as providing advertising space to our members and third parties;
o Communications:
to ensure that your queries are addressed; and
o Investor Relations:
to allow you to access JIA London regulatory alerts and to ensure that your queries are addressed.
How long we will keep it for
· We will store the information summarised above for the following periods:
Enquiries to our members
o all enquiry data will be kept for two years from the date on which you last used our Site or our services. After that it will be erased or anonymised so that the data no longer identifies you.
o Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted.
o profiling data will be kept for a shorter time period, as described in "Lead Profiling" below.
Registered Users and Property Alerts:
o information that you provide to us when you register as a JIA London user will be kept for as long as you have an account setup on JIA London. The personal data relating to your account will be deleted when you delete your account.
General Site Use:
o information that you provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years.
o information that is provided when you interact with us through social media functions will only be retained on the social media platforms which you use to contact us - we will not copy or store it separately. This data will be retained for as long as you keep it on your social media accounts.
Communications:
o information that you provide to us by corresponding with us by phone, e-mail or otherwise will be retained for the later of 18 months from the date of communication or until your query is resolved.
Investors
o Information that you provide to us when browsing our plc investor pages will be kept for as long as you maintain a user account on our plc investor pages. Any data which we hold will be deleted when you delete your account.
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INFORMATION WE COLLECT ABOUT YOU
What we collect and where it comes from
· This is different to "information you give us" because it relates to technical data that we collect. We may:
o collect technical information that has the potential to identify you, such as the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
o collect information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page; and
o we may combine technical information with other information that we have about you to help us with our processing of your information as set out in this Policy.
Why we collect it
· We will use the information summarised above:
o to provide the Site to you;
o to conduct reviews that assist us in the improvement and optimisation of our Site;
o to ensure that content from our Site is presented in the most effective manner for you and for your device;
o to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
o as part of our efforts to keep our Site safe and secure; and
o to customise and enrich your experience on our Site.
Our lawful basis for processing this personal data
· We have a legitimate interest to process this information. These legitimate interests are:
o to help ensure the on-going security of the Site;
o enhancing the service that you receive on the Site; and
o providing information necessary to enable us to provide a competitive, cost effective services.
How long we will keep it for
We will store this personal data for two years in order to allow us to review and monitor normal traffic patterns and trends on Site. After two years this data will be kept in an anonymous form.
USE OF YOUR DATA FOR MARKETING AND COMMUNICATIONS
Sometimes we may use your personal information to provide marketing messages to you. You can opt out of marketing and other communications at any time by contacting tim@jialondon.com You can always make use of the Site without having to agree to marketing. The types of things that we may do include:
· providing direct marketing advertisements and communications to you via email, text, post or telephone;
· making suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them;
· communicating with you on third party social media platforms; and
· monitoring the effectiveness of our direct marketing communications and your responses to it.
REMOVING PROPERTY DATA FROM THE SITE
If you have any concerns about the property data on the Site, please contact us at tim@jialondon.com and we will endeavour to resolve the issue promptly.
WHO HAS ACCESS TO YOUR PERSONAL DATA?
We retain access to all personal information that we have collected from you or about you. Once your information has been passed to one of our members in the course of providing our services (most typically when you communicate with an estate agent through our Site) then that JIA London member will have a copy of the information that you have provided within your enquiry and your contact details which they will use to get in touch with you. In relation to property data, it is provided to us by our members (or third parties that act on their behalf). Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of your information by any of our members.
When our service is available via the websites of our partners, those partners may have access to your information. We may also have links to other websites from our Site. We are not responsible for the content, security, privacy policies and practices of any other websites, even if you access them using links from this Site or if you can access this Site or use our services from them. We recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
If our business is sold or merged, or if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.
If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your information to them in order to deliver the service. The categories of third parties (who are acting as a data processors) include: telephone call recording and our support ticketing systems. We may also use third parties to provide services on our behalf which may include processing (but not using themselves) your information e.g. to complete partial addresses or to augment the information we hold about you. In either case, we will not pass your information to anyone who is not also subject to adequate privacy commitments in our contract with them.
We will not otherwise disclose, sell or distribute your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.
WHERE DO WE STORE YOUR PERSONAL DATA?
We follow strict security procedures to ensure that your personal information is not damaged, destroyed or disclosed to a third party without your permission and to prevent unauthorised access to it. The computers that store the information are kept in a secure facility with restricted physical access and we use secure firewalls and other measures to restrict electronic access. If we are working with third parties, we will require them to have in place similar measures to protect your information.
Only employees who need access to your information to perform a specific job are granted access to personally identifiable information. We may require you to co-operate with our security checks before we disclose information to you.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
YOUR RIGHTS
You have the right to ask us not to process your personal data at any time.
You have the right to use our Site without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We always use the most recently submitted form to be your current consent status. If you are a registered user, but not signed in when you submit a form, we will not be able to use your saved settings so will deem your consent choice to be as per the form you submit at the time. You can exercise your right to prevent such processing by selecting the specific options in the fields or forms when you become a registered user.
You have a right to request access to or rectification of your personal data which we hold about you. You also have a right to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us, the right to object to our processing of your personal data and a right to request that we transmit your personal data to another data controller.
Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.
To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this policy.
You have the right to complain to the Information Commissioner's Office if you feel unhappy with the way we process your data. Please visit www.ico.org.uk for more information.
COOKIES AND TRACKING
Like many websites, we use "cookies" to enable us to personalise your visits to our Site, simplify the signing-in procedure, keep track of your preferences and to track the usage of our Site.
CHANGES TO THIS POLICY
Any changes we may make to this Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Policy.
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