BACKGROUND:
Angels Media Ltd is the publisher of this site. At Angels Media Ltd we are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us.
Angels Media Ltd is the controller and understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our websites, (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Sites and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Sites;
“Cookie” means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites to find out more about cookies go to http://www.allaboutcookies.org/ . Details of the Cookies used by Our Sites are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
2. Information About Us
Our Sites are owned and operated by Angels Media Ltd, a Limited Company registered in England under company number 08629863 whose registered address is Ground Floor, 1/7 Station Road, Crawley, West Sussex, RH10 1HT, and whose main trading address is Angels House, 5 Albemarle Road, Beckenham, Kent, BR3 5HZ.
Our VAT number is 180540524 and our Data Protection Officer is Patsy Gown, at the trading address above.
Our ICO number is Z9849129.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Sites which may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
You have rights in respect of your personal data. We will need to confirm your identity before we can consider your request so, if you wish to exercise any of these rights, we will need Certified Copies of your passport, driving licence, and a utility bill.
The right to be informed – you have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
Right of access – you have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
Right to rectification – you have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to restrict processing – you have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DP at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Right to data portability – you have the right to move, copy or transfer your personal data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/
Right to object – you have the right to object to our processing of your personal data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.
(i) Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
(ii) Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
(iii) Scientific/historical research and statistics - your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.
If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information Commissioner’s Office - https://ico.org.uk/concerns/
6. What Data Do We Collect?
Depending upon your use of Our Sites, we may collect some or all of the following personal and non-personal data (please also see Part 15 on our use of Cookies and similar technologies and our Cookie Policy):
• Name;
• Postcode;
• Email address;
• Telephone number if applicable;
• Business name if applicable;
• Job title if applicable;
• Information about your preferences and interests;
• IP address;
• Web browser type and version;
• Operating system;
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate commercial interests to use it. Your personal data may be used for the following purposes:
• Providing and managing your Account.
We wanted to let you know that we have added "Noindex" meta tags to all personal profile pages therefore they will not appear in search results of most of the search engines if searched by keywords. However this could change in future if Search Engines make changes at their end.
If the full url for a Personal Profile Page is entered in a Google search then it will show in the Google search results.
• Providing and managing your access to Our Sites;
• Personalising and tailoring your experience on Our Site;
• Supplying our products or services to you and/or those of our partners to you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by using the unsubscribe link in our emails or contacting us using the details in Part 16.
• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Sites and your user experience.
• Retargeting
See Wikipedia for an explanation of retargeting.
This website uses retargeting services (sometimes referred to as remarketing) to advertise on 3rd party websites (including Google and Facebook) to previous visitors to our site. Any data collected will be used in accordance with our own privacy policy and the 3rd parties’ privacy policies.
You can set preferences for how Google advertises to you using the Google Ad Personalization page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on both our and our partners products and services which are relevant to the Property Industry. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
8. The legal basis for which we process your Personal Data
Whenever we process your personal information we have to have something called a “legal basis” for what we do. The different legal bases we rely on are:
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Consent: You have told us you are happy for us to process your personal information for a specific purpose;
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Legitimate interests: The processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
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Performance of a contract: We must process your personal information in order to be able to provide you with one of our products or services;
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Prevention of fraud: Where we are required to process your data in order to protect us and our clients from fraud or money laundering;
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Vital interests: The processing of your personal information is necessary to protect you or someone else’s life;
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Public information: Where we process personal information which you have already made public;
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Legal claims: The processing of your personal information is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; and
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Legal obligation: We are required to process your personal information by law.
9. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
We will keep your personal data in connection with the services/products you have bought for 3 years after the last purchase. We need to retain this data for our own accounting purposes and for legal and tax purposes.
In terms of personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.
10. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
Where we transfer your data to a third party based in the US, this is only with Third Parties that are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 16 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
• Secure Servers/database
• Websites on SSL (https).
• Server/database software upgrades
• Encrypted passwords
• All backups are performed in three stages:
• A) A dump is created locally where the container lives on our server.
• B) All data, including files such as dumps, code, images and other assets are encrypted locally
• C) Encrypted files are sent to cloud based servers within the EU which are an infrastructure made of multiple servers.
11. Do You Share My Personal Data?
We contract with the other third parties for the following reasons In some cases those third parties may require access to some or all of your personal data that we hold.
• Email Service Provider - for the purpose of sending Our emails
• CRM - for the purpose of our Customer Relationship Management System.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 10.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
12. How Can I Control My Personal Data?
12.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Sites, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Can I Withhold Information?
You may access certain areas of Our Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 15.
14. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally,we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
15. How Do You Use Cookies?
Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Sites, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Sites for if we use these, what do we use them for? For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.
All Cookies used by and on Our Sites are used in accordance with current Cookie Law. See our Cookie Policy for more information.
16. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of The Directorate):
Email address: team@angelsmedia.co.uk.
Postal Address: Angels House, 5 Albemarle Road, Beckenham, Kent, BR3 5HZ
Please mark your correspondence with the subject “Privacy Policy Enquiry”.
17. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date