At Propuno.com we take your privacy seriously and are committed to complying with all data protection and/or privacy laws that are applicable to us. This policy and notice has been drafted in accordance with the requirements of the General Data Protection Regulations (“GDPR”).
Propuno.com (herein also referred to as “Platform”) is owned and operated by Propuno Ltd.
This privacy notice explains how we look after your personal data in all situations where we collect your data and sets out your privacy rights and also explains how the law and our approach to privacy and personal data protects you.
This privacy notice supplements any other privacy notices that we may provide to you at the point that we collect data from you and should be read in conjunction with those notices.
During the course of providing you with access to the platform or services (as defined in our Terms and Conditions), we will be collecting, using, disclosing, storing and/or processing data, including your personal data.
Our Status and Details
For the purpose of the GDPR we are the data controller and any enquiry regarding the collection or processing of your data should be addressed to Matthew Campbell using the contact details below:
Name or title: Matthew Campbell
Email address: [email protected]
Postal address: The Whitehouse, 4 Church Square, Hartlepool, TS24 7EQ.
By using the website you consent to this policy.
Information We Collect From You
We collect information about you or your devices directly from you only with your permission to use, process and retain by means of implied or express consent from the following sources:
- Propuno’s brand websites
- User’s devices (computer and/or mobile phone)
We will collect, process and store personal data only if it is directly provided to us by you. You may do this in your capacity as the user of this website, by enquiring in relation to our goods or services, becoming a customer or supplier, or potential supplier.
Personal information covers any information which relates to you as an identifiable person. During the course of your use of the Platform and the provision of the Services, we may collect personal data from you, which includes but is not limited to:
- Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier.
- Contact Data may include invoicing; purchase order; home or work address, email address and telephone numbers, personal or job title and position.
- Financial Data may include bank account and payment card details.
- Special Category Data for example health or medical data, details about your race, religion, sex and political opinions.
- Transaction Data may include payments made for products and services you have purchased from us, or in relation to payments that we have made to you.
- Technical Data may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access this Website.
- Profile and Usage Data may include enquiries submitted by you, purchases information, feedback and survey responses, and how you use our website, products and services.
- Marketing Data may include details of any preference that you have advised us of in relation to marketing communications from us.
We may also collect non-personal data such as aggregated data which is data that may be obtained from your personal data, but which does not directly or indirectly identify you. This may include usage data detailing how you use our website and the features and areas that you have interacted with.
During the course of your use of the Platform and the provision of the Services, we may receive personal data from you in the following situations:
- When you create an account with us;
- When you submit an enquiry for a property listed on Propuno.com, any of the Services or purchase any products available on the Platform;
- When you use any of the features or functions available on the Platform or Services;
- When you record any user-generated content which is uploaded on the Platform;
- When you use the chat function on the Platform;
- When you subscribe to our publications or marketing collaterals;
- When you enter a competition, promotion or survey;
- Items and data searched for on the Platform;
- When you participate in any activity or campaign on the Platform;
- When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
- When any other user of the Platform posts a message on a property you have uploaded to the Platform or when you post a messages on a property uploaded to the Platform from another user;
- When a third party lodges a complaint against you or the content you have posted on the Platform;
- When you interact with us offline, including when you interact with our outsourced customer service agents.
- Through direct interactions with us in person, by post, phone, email or otherwise. You may give us your Identity, Contact and Financial Information.
- Through Automated technologies or interactions with our website, by using the web enquiry form. You may give us Identity, Contact and Financial Information.
- Through third parties or publicly available sources (third parties may be used in processing Identity, Contact and Financial categories of personal data).
You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation to verify the personal data provided by you as part of our customer verification processes.
You may access and update your personal information submitted to us at any time.
Use And Disclosure Of Personal Data
We may hold and process personal data that you provide to us in accordance with the GDPR.
The personal data we collect from you or via third parties may be used by us, or shared with or transferred to third parties for certain purposes, which include but are not limited to the following:
- To facilitate your use of the Services or access to the Platform;
- To respond to your enquiries, feedback, or disputes, directly or through our outsourced service agents, partner agencies and/or property developer partners;
- To process orders you submit through the Platform (Payments that you make through the Platform for products, whether sold by us or a third party seller, will be processed by our agents);
- To deliver the products you have purchased through the Platform, whether sold by us or a third party seller. We may pass your personal information on to a third party in order to make delivery of the service to you (for example to our courier or suppliers), whether the product is sold through the Platform by us or a third-party seller;
- To update you on the delivery of the services or products, whether sold through the Platform by us or a third party seller, and for customer support purposes;
- To compare information, and verify with third parties in order to ensure that the information is accurate;
- To ascertain your identity for fraud detection purposes;
- To administer your account (if any) with us;
- To verify and carry out financial transactions in relation to payments you make online;
- To audit the downloading of data from the Platform;
- To improve the layout or content of the pages of the Platform and customise them for users;
- To identify visitors on the Platform;
- To carry out research on our users’ demographics and behaviour;
- To provide you with information we think you may find useful or which you have requested from us, including information about our or third party sellers’ products and services, provided you have indicated that you have not objected to being contacted for these purposes;
- To display your name, username or profile on the Platform;
- To promote the Services and use information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on our Platform and will be accessible on the internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote the Platform and user properties;
- To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform;
- To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
- To send you marketing or promotional materials about our products and services from time to time (unless you choose to opt-out from receiving these materials); and
- We may also conduct automated decision-making processes in accordance with any of these purposes.
- To enable us to provide our services to you, to communicate with you and to meet our contractual commitments to you. This may include Identity, Contact, Financial and Transactional data.
- To notify you about any changes to our business, such as improvements to our website or service/product changes, that may affect our service or relationship with you. This may include Identity and Contact data.
- If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you. This may include Identity and Contact data.
- Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you. This may include Identity, Contact and Marketing data.
- Where you have consented to receive our e-newsletters to provide that to you. This may include Identity and Contact data.
- Where we need to comply with a legal obligation. This may include Identity, Contact and Transactional data.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This may include all types of data.
Security of Your Personal Data
To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
- Restricting access to personal data to individuals who require access;
- Maintaining technology products to prevent unauthorised computer access; and
- Using SSL (secure sockets layer) encryption technology when processing your financial details.
If you believe that your privacy has been breached, please contact us immediately.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your Propuno password to anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal data and other data submitted to Propuno. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log out of your account and close the browser when you are finished with using a shared computer.
How We Use Information We Collect
We use or disclose your information, based on implied or express consent and in compliance with all applicable regulations in relevant jurisdictions, for following purposes:
- For our business purposes, we use and retain data to analyse and improve our business, including services and platforms;
- For cybersecurity purposes, we use or analyse data to detect illegal activities to prevent frauds or crimes;
- To send you our certain business information of Propuno, including news, notice, promotion, update of platform policy, and marketing communications;
- To customize the content and advertising you see on our websites and apps, across the internet, and elsewhere;
Disclosure of Information We Collect From You
It is obligatory that we may share data in compliance with the laws or the formal request of the state authority. Also, There are a range of circumstances where we may disclose your data to third parties. These include:
- Regulatory bodies. We may disclose your data to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise credit risk. This may include Identity, Contact and Transactional data.
- Our Suppliers and partners. We may disclose your data to third parties that are involved in the fulfilment of our services to you. This may include Identity, Contact and Transactional data.
- Third-party marketing. We may provide your data to selected third parties who may contact you about their goods or services that you may be interested in. This may include Identity, contact and marketing data.
Data storage and the transfer of your data
As part of the services offered to you, for example through our website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g. our website server host, payment processing provider, or work for us when temporarily outside of the EEA.
A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.
If you use our service while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with these services.
The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site; any such transmission is at your own risk.
We have put in place security measures to prevent your data from accidental, loss or disclosure. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential. You should choose a password that is not easy for someone to guess.
In the event of a data breach we will notify the ICO and you in the event that the breach results in any likelihood of loss or damage to you.
The length of time that we retain and store data depends on the purpose for which it was collected. We will only store data for as long as is required to fulfil that purpose, or for the purpose of satisfying legal requirements.
It is a legal requirement that we keep certain data about our customers and suppliers for at least six years. The type of data includes Contact, Identity, Financial and Transaction data.
Where you have requested that we provide you with marketing materials we will retain your data until such time as consent is withdrawn by you.
We may also gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you.
The operation of our website requires the use of Essential Cookies, this enables the user to complete online forms and log in to secure areas where appropriate.
To continue to improve our website we use Analytical Cookies to track how visitors are using our website. This allows us to improve any areas to improve the user experience.
So that we can recognise a returning website visitor we use marketing cookies, this allows us to make our website personalised and relevant for returning customers.
The GDPR gives you a range of rights in relation to the personal data that we collect from. You have the right to:
- Access your personal data. This right is commonly known as the ‘data subject access request’ and enables you to receive a copy of the personal data we hold about you. You will not need to pay a fee to access your personal data unless we can justifiably demonstrate that the request is repetitive or excessive. We will respond to all legitimate data access requests within one month, but we may need to obtain further information from you in order to confirm your identity and the legitimacy of the request.
- Request update of the personal data. This enables you to have any incomplete or inaccurate data corrected.
- Erasure of your personal data. This enables you to ask us to delete personal data where there is no justifiable reason for us continuing to retain and process it. We may not always be able to delete the data such as if there is an ongoing contractual relationship between us or if we are legally required to retain the data.
- Object to processing of your personal data where we are relying on consent or our legitimate interests (or those of a third party) as the justification for processing the data.
- Restrict the processing of your personal data. This enables you to ask us to change the processing of your personal data. For example, you may wish to vary the basis on which we contact you.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, machine-readable format.
- Withdraw consent. Where we are relying on consent to process your personal data you may withdraw that consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise these rights at any time by writing to us at the address detailed above, or by email to [email protected].
Third Party Links
You might find links to third party websites on our website. If you click a link to a third-party website and visit that site, you may be allowing that site to collect and share certain data about you. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
If you wish to raise a complaint regarding our use of your personal data then you can contact the Information Commissioner’s Office (ICO), who are the UK supervisory authority for data protection issues. (www.ico.org.uk).
If you do wish to raise a complaint then we would welcome the opportunity to discuss your concerns before you contact the ICO to see if we can resolve the issue for you.
Changes to this policy
We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.
Questions, Suggestions, Complaints and Feedback