Falles Properties

External Privacy Notice

Our commitment to your personal data use

Falles Holdings Limited (Falles Properties) is committed to protecting the privacy and security of your personal information and to ensuring your personal data:

is only used lawfully, fairly and in a transparent way
is only collected for valid purposes which we have clearly explained to you and is not used in any way that is incompatible with those purposes
is only collected if it is relevant to the purposes we have told you about and is limited to those purposes
is accurate and kept up to date
is only kept as long as is necessary for the purposes we have told you about
is kept securely

Personal data includes any information about an individual from which a person can be identified. It does not include data where identifying information has been removed (anonymous data).

Data protection laws often talk about ‘processing’ data. ‘Processing’ in relation to data includes collecting, recording, organization, structuring, storage, use, retrieval and transmission.

Our Privacy Statements

Falles Properties has the following privacy notices:

Privacy Notice for Tenants, Clients and Third Parties (this notice)
Privacy Notice for Website Users (click here)
Privacy Notice for Employees and other Workers (click here)

If you want to contact us about this privacy notice or any data protection issues please contact us at info@fallesproperties.com or at the following address:

Data Protection Officer
Falles Properties
1st Floor, Douet House
Longueville Road
St Saviour
Jersey JE2 7SA
Channel Islands

What data do we collect about you?

We will collect Personal data of the following types from you:

Personal contact details such as name, title, addresses, telephone numbers and email addresses
Copies of identification documentation and details of your gender, date and place of birth and your marital status and dependants
Next of kin and emergency contact information
Bank account and transactional details, records and tax status information and relevant tax numbers.

Data protection laws recognise that certain types of “special categories” of more sensitive personal information requires particular attention and further protection. We may sometimes collect, store and use the following types of sensitive personal information:

Information about your family and personal life which may be relevant to our relationship with you
Information about your health

How do we collect your personal information?

We collect information from you through your dealings with us, for example when you respond to questions from us or complete questionnaires or tenancy agreements for us. We will also collect information in the course of our relationship with you through our dealings (phone calls, correspondence or meetings).

We may sometimes undertake credit reference checks or public searches in relation to you (for example on websites in telephone directors or other public registers) to check information about you or verify information you supply.

How do we use your personal data?

The data protection laws set out certain grounds on which we are allowed to process your personal data. We are obliged to advise you of the grounds on which we are processing your personal information.

We will use your personal data:

if you have asked us to consider entering into a contract with you, to allow us to decide whether to do that
if we have entered into a contract with you, to allow us to perform that contract
where we need to comply with a legal obligation
where use of your personal data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
occasionally, where we need to protect your vital interests (or another person’s vital interests) or where it is needed in the public interest

To be transparent with you we have set out in the schedule a detailed list of how we use your personal data and our basis for doing so. This also explains when we rely on legitimate interests for using your personal data and what those legitimate interests are.

How do we use your sensitive personal data?

When we collect sensitive personal data we are obliged to give it higher levels of protection and to have additional justification for collecting, storing and using it.

We may process sensitive personal data:

in limited circumstances, with your explicit written consent or to protect your vital interests or some other person’s vital interests
where it is necessary for us to carry out our legal obligations
where it is necessary for the purposes of any legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights.

Will we always need your consent to process your personal information?

We do not need your consent if we process your personal information in accordance with other lawful grounds set out in the data protection laws such as where we are complying with our legal obligations.

In limited circumstances, we may ask you for your written consent to allow us to process certain particularly sensitive data. If we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can choose whether you wish to consent. You are not obliged to consent. It is not a condition of any contract with us that you agree to any request for consent from us.

Will we use your data for any other purposes?

Occasionally we may need to use your personal information for a different reason than the reason for which we originally collected. We will only do this if that reason is compatible with the reason for which it was originally collected. If we want to use your personal information for an unrelated reason we will notify you and explain the legal basis which allow us to do so.

Will you be subject to automated decision-making?

The data protection laws require us to advise you if you will be subject to any automated decision-making. Automated decision-making occurs when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means. If this changes we will notify you in writing and advise you of your rights in relation to automated decision-making and when we may use it.

Who will we share your personal information with?

We may need to share your information with third parties. We may need to transfer your personal information outside the EU. When your personal information is sent outside the EU you can expect an equivalent degree of protection in respect of your personal information.

When we transfer information to third parties we require those third parties to respect the security of your data and to treat it in accordance with data protection laws. We only permit third parties who process your personal information on our behalf to use it for specified purposes on our instructions and not for their own purposes.

The third parties we may share your information with are:

Third party service providers who help us work with you and operate our business, such as certain IT contractors who provide us with IT support
Tax authorities, customs agencies, regulators and other government agencies
Credit card companies and direct debit operators
Fraud prevention agencies and credit reference agencies
Any professional service providers, contractors or other entities working with you or for you or that introduce you to us or that you ask us to deal with or share your data with
In certain circumstances our professional advisers or insurers
Companies that we introduce you to or that you ask us to share your data with

How long will we retain your data for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods for your personal information are decided by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

How secure is your personal data?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Will your personal data be used for marketing?

We may use your personal information to let you know about those of our products and services we think may be of interest to you. Before doing so we may use your personal information to better understand what services or products you are likely to need or have use for.

If you ask us to stop using your personal information to market to you, we will do so and you can change this choice at any time.

Website

We use “cookies” on our website, these are small pieces of data that allow us to track which computers visit our website and how.

What are your rights in relation to your personal information?

In certain circumstances data protection laws give you rights to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
Request the transfer of your personal information that you have provided to us to another party

Where we have asked for your consent to use your personal information you may withdraw that consent at any time by contacting us using the details below. If we are relying on your consent to process your personal information we will stop using it. This may mean that we can no longer provide some services to you. We will explain this to you at the time of receiving any such request.

If you want to exercise these rights please contact us in writing using the contact details above. We will not usually require you to pay any fee. We may require a reasonable fee or refuse to comply with the request if the request is clearly unfounded or excessive.

When responding to a request in relation to personal information we will usually request identity information to verify that you are the person we hold information about. If you are making a request on behalf of a third party, we will usually require evidence of your authority to make a request on that person’s behalf.

What are your obligations in relation to your personal information?

It is important that the personal information we hold about you is accurate and current. Please advise us if your personal information changes during your relationship with us.

Will we change this privacy notice?

We reserve the right to update this privacy notice at any time. We will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Schedule

How we use your personal information:
- To operate and maintain our relationship with clients
Our basis for doing so:
- Your consent
- Contract fulfilment
- Our legal obligations
- Our legitimate interest in developing and growing our business
- Our legitimate interest in obtaining your consent where needed for contact
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Delivering our services to our clients
Our basis for doing so:
- Contract fulfilment
- Our legal obligations
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Complying with applicable laws and regulations, such as AML laws and risk management
Our basis for doing so:
- Our legal obligations
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Marketing our products and capabilities and advising clients of services
Our basis for doing so:
- Your consent
- Our legitimate interest in developing and growing our business
- Our legitimate interest in obtaining your consent where needed for contact
How we use your personal information:
- To learn how our clients engage with us and how we can improve this
Our basis for doing so:
- Our legitimate interest in developing and growing our business
- Our legitimate interest in obtaining your consent where needed for contact
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Working with service providers who help us operate our business
Our basis for doing so:
- Contract fulfilment
- Our legal obligations
- Our legitimate interest in developing and growing our business
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Developing and testing new products and services and improving service delivery for clients
Our basis for doing so:
- Contract fulfilment
- Our legal obligations
- Our legitimate interest in developing and growing our business
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
- Our legitimate interest in identifying the customer base for our service lines
How we use your personal information:
- Responding to complaints
Our basis for doing so:
- Our legal obligations
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Efficiently and lawfully operating our business in accordance with good corporate governance
Our basis for doing so:
- Our legal obligations
- Our legitimate interest in maintaining proper practice and efficiencies in meeting our legal and commercial obligations
How we use your personal information:
- Exercising our contractual rights including collecting debts due
Our basis for doing so:
- Contract fulfilment
- Our legitimate interest in developing and growing our business