This Privacy Policy governs the way ADANTE REALTY and its affiliates, subsidiaries, group companies, partners, and agents (“We”, “Us”, “Our” or “ADANTE REALTY”) collect, use, maintain and disclose information collected solely from:
- Users of Our
website: https://www.AdanteRealty.com/;
- Email, text, and other
electronic messages between you and Us;
- Mobile and desktop
applications that you may download from Our Websites;
- Your interactions with
Our advertising and applications on third-party websites and services, if
those applications or advertisements include links to this privacy policy;
and information and data collected by our call centers.
PERSONAL
INFORMATION:
We may collect and process the
following types of Personal Information that can be used to identify you:
Personal Identification Information such as your name, email address, phone
number, nationality, and other contact details; Property Preferences, including
information about the properties or units you are interested in the projects of
ADANTE REALTY; Transactional Information, such as payment details if you engage
in any financial transactions with us; Marketing & Communications Data,
including your preferences for receiving marketing from us and your
communication preferences; and Technical Information, such as your IP address,
browser type, and other technology on the devices you use to access our
website. This information may be collected in various ways, including when you
visit our websites, use live chat, subscribe to our newsletter, complete a
form, or engage with other services, features, or resources available on our
websites. Personal Information may also be collected automatically as you navigate
through our websites. While you can choose not to supply Personal Information,
this may prevent you from engaging in certain activities on our websites. You
can visit our websites anonymously, and you can update your Personal
Information by emailing us at info@adanterealty.com
NON-PERSONAL
IDENTIFICATION INFORMATION:
We may collect your non-personal
identification information whenever you interact with Our Websites.
Non-personal identification information means information that is about you but
does not identify you individually, and/or relates to information about your
internet connection, the equipment you use to access the Websites and usage
details, and other similar information.
WEB
BROWSER COOKIES:
Our Websites may use
“cookies” to enhance your user experience. Your web browser places
cookies on your hard drive for record-keeping purposes and sometimes to track
information about you. You may choose to set your web browser to refuse cookies
or to alert you when cookies are being sent. If you do so, note that some parts
of the Websites may not function properly. This is a standard operating
procedure that is used across the internet.
HOW
TO MANAGE AND REMOVE COOKIES?
If you are using Our Websites
via a browser you can restrict, block or remove cookies through your web
browser settings. The Help menu on the menu bar of most browsers also tells you
how to prevent your browser from accepting new cookies, how to delete old
cookies, how to have the browser notify you when you receive a new cookie, and
how to disable cookies altogether. You can also visit
http://www.aboutcookies.org for more information on how to manage and remove
cookies across a number of different internet browsers.
HOW
WE USE COLLECTED INFORMATION:
ADANTE REALTY may collect and
use your Personal Information for various purposes, including providing you
with information about the projects of ADANTE REALTY and available units,
responding to your inquiries or requests, processing your property purchase or
investment transactions, sending marketing materials, promotions, and updates
about our projects (if you opt-in), improving our services, website, and
customer experience, and complying with legal obligations. Additionally, we may
use your information to improve customer service by responding more efficiently
to requests and support needs, personalize your user experience by understanding
how users as a group interact with our services, improve our websites using
feedback you provide, run promotions, contests, surveys, or other features, and
send you information you agreed to receive on topics of interest. We may also
use your information for marketing purposes through third-party vendors
appointed by us and for any other purpose disclosed when you provide your
information. By accepting this Privacy Policy, you grant us permission to
record, store, process, transfer, and share your personal information,
including sharing it with third parties for marketing purposes. You have the
right to withdraw your consent at any time by notifying us in writing at info@adanterealty.com. We may use your email address
to respond to inquiries, and if you join our mailing list, you will receive
emails about ADANTE REALTY news, updates, and related projects. You can
unsubscribe from future emails at any time by contacting us through our
websites.
ACCESSING
AND CORRECTING YOUR PERSONAL INFORMATION:
You can review and change your
Personal Information by logging into the Websites. You may also request to
update any Personal Information We hold about you by contacting us at info@adanterealty.com
HOW
WE PROTECT YOUR PERSONAL INFORMATION :
We adopt appropriate data
collection, storage, and processing practices and security measures to protect
against accidental loss, unauthorized access, alteration, disclosure, or
destruction of your Personal Information and data stored on Our Websites. Any
payment transactions will be encrypted using current technology. Unfortunately,
the transmission of information via the internet is not completely secure.
Although we do our best to protect your Personal Information, we cannot
guarantee the security of your Personal Information transmitted to Our
Websites. Any transmission of Personal Information is at your own risk. We are
not responsible for the circumvention of any privacy settings or security
measures contained on the Websites.
SHARING
PERSONAL INFORMATION :
We do not sell, trade, or rent
your Personal Information to others. We may share generic aggregated
demographic information not linked to any personal identification information
regarding users with Our subsidiaries, group companies, Our business partners,
trusted affiliates, and advertisers (eg: Facebook) for the purposes outlined
above.
We may share Personal
Information with other organisations in the following circumstances:
- To provide measurement
services and target ads
- If any applicable law
or a public authority says We must share Personal Information;
- If We need to share
Personal Information to establish, exercise or defend Our legal rights
(this includes providing Personal Information to others for the purposes
of preventing fraud and reducing credit risk);
- To an organisation We
sell or transfer (or enter into negotiations to sell or transfer) any of
Our businesses or any of Our rights or obligations under any agreement
that We may have with you. If the transfer or sale goes ahead, the
organisation receiving your Personal Information can use your Personal
Information in the same way as Us; or
- To any vendor or the
third-party service provider appointed by us to provide enhanced services;
- For storage of sale
contract and for the usage of third-party software used for electronic
signature of the relevant documentation;
- To any other successors
in title to Our business.
CHANGES
TO THIS PRIVACY POLICY:
ADANTE REALTY shall update this
privacy policy at its sole discretion from time to time. You are advised to
check this page for any changes in the privacy policy and to stay informed
about how your Personal Information is protected by us, and you acknowledge and
agree that it is your responsibility to review this privacy policy periodically
and become aware of any modifications.
Your acceptance of these terms: By using the Websites, you signify your
acceptance of this privacy policy as may be modified from time to time. Your
continued use of the Websites after we make changes is deemed to be acceptance
of those changes, as they are binding on you. You are advised not to access the
Websites if you do not agree with Our privacy policy and practices.
GLOSSARY
Legitimate Interest is our
lawful interest in conducting and managing our business to enable us to give
you the best service/product.
Performance of Contract means processing your data where it is necessary for
the performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Third Parties means
- Companies
within the ADANTE REALTY Group other than the ones to whom you are providing
your personal data.
- Organisations we need
to share your personal information with to provide you with the product or
service you have chosen.
- Revenue & Customs,
regulators, and other authorities.
- Fraud prevention and
law enforcement agencies.
- Companies that we
introduce to you.
- Agents and advisers who
we use to help run your relationship with us, collect what you owe, and
explore new ways of doing business.
- Companies we have a
joint venture or agreement to co-operate with.
- Organisations that
introduce you to us.
- Companies you ask us to
share your data with.
We may also share your personal
information if the composition of ADANTE REALTY Group changes in the future:
- We may choose to sell,
transfer, or merge parts of our business, or our assets. Or we seek to
acquire other businesses or merge with them.
- During any such
process, we may share your data with other parties. We will only do this
if they agree to keep your data safe and private.
- If the change to our
Group happens, then other parties may use your data in the same way as set
out in this notice.
1.
IMPORTANT INFORMATION
Purpose of this privacy notice
This privacy notice aims to give you information on how ADANTE REALTY Group collects and processes your personal data, including any data you may provide through this website. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Third-party links
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or application you visit.
If you fail to provide personal data
Where we need to collect
personal data by law, or under the terms of a contract we have with you and you
fail to provide that data when requested, we may not be able to perform the
contract. We will notify you if this is the case.
Updating your personal data with us
It is important that the
personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.
2.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal
information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed
(anonymous data). We may collect, use, store, and transfer different kinds of
personal data about you which include:
- Identity Data, which includes
first name, maiden name, last name or similar identifier, marital status,
title, date of birth, gender, country of residence, and nationality.
- Documentary Data, which includes
copies of your passport, driver’s licence, ID card, proof of address, etc.
- Contact Data, which includes
billing address, delivery address, email address, and telephone numbers.
- Financial Data, which includes
bank account and payment card details.
- Contractual Data, which includes
details about the products or services we provide to you.
- Transaction Data, which includes
details about payments to and from you and other details of products and
services you have purchased from or through us.
- Open Data, which includes
details about you that are in public records, and information about you
that is openly available on the internet.
- Social Relationships
Data, which
includes your family, friends, and other relationships.
- Location Data, which includes
data we get about where you are.
- Technical Data, which includes
internet protocol (IP) address, your login data (where applicable),
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 you use to access our websites.
- Communications Data, which includes
what we learn from you from letters, emails (and other forms of electronic
communication), and conversations between us.
- Profile Data, which includes
your username and password (if any), purchases or services requested by
you, your interests, preferences, and feedback.
- Usage Data, which includes
information about how you use our website, products, and services.
- Marketing and
Communications Data, which
includes your preferences in receiving marketing from us and your
communication preferences.
- Special Category Data, which includes
details about your race or ethnicity and information about criminal
convictions and offences. We will only collect and use these types of data
if the law requires or allows us to do so.
We also collect, use, and share
Anonymous Data such as statistical or demographic data for any purpose. Anonymous
Data may be derived from your personal data but is not considered personal data
in law as this data does not directly or indirectly reveal your identity.
3.
HOW IS YOUR PERSONAL DATA COLLECTED
We may collect personal
information about you (or your business) from these sources: Data you give us:
- When you apply for our
services or purchase our products;
- When you talk to us on
the phone;
- When you use our
website;
- In letters, emails, and
other forms of electronic communication;
- In customer surveys or promotions;
- If your business is
looking to enter into or has entered into a business arrangement with us;
- When you make payments
to us in relation to the services or products we are providing to you.
- Companies that
introduce you to us;
- Fraud prevention and
law enforcement agencies;
- Retailers;
- Social networks;
- Public information
sources such as Companies House;
- Agents working on our
behalf;
4.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal
data:
- Where we need to
perform a contract we are about to enter into or have entered into with
you.
- 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.
- Where we need to comply
with a legal or regulatory obligation including any obligation arising out
of applicable anti-money laundering regulations.
- Where we want to use
your personal data for purposes similar to the one for which the personal
data is provided.
Where we send direct marketing
communications to you, or if we process any Special Category Data we will rely
on your consent. For all other purposes, we generally do not rely on consent.
You have the right to withdraw your consent at any time by contacting the ADANTE
REALTY.
Purposes for which we will use your
personal data
We usually collect your data for
the following purposes:
- To register you (or
your business) as a new customer or supplier
- To deliver our
services/products including:
- To process your
instructions and requests
- To Manage payments and fees/charges
- To Collect and recover
money owed to us
- To manage our
relationship with you which will include:
- Notifying you about
changes to our terms and conditions or privacy policy
- Studying how our
customers use products and services from us and other organisations
- Developing and carrying
out marketing activities
- To develop and manage
our brands, products, and services and to manage how we work with other
companies that provide services to us and our customers
- To manage risk for us
and our customers, to obey laws and regulations that apply to us, and to
respond to complaints and seek to resolve them
- To run our business in
an efficient and proper way. This includes managing our financial
position, business capability, planning, communications, technical, and
corporate governance
- To exercise our rights
set out in agreements or contracts
- To deliver relevant
website content and advertisements to you and measure or understand the
effectiveness of the advertising we serve to you
- To use data analytics
to improve our website, products/services, marketing, customer
relationships, and experiences
- To make suggestions and
recommendations to you about goods or services that may be of interest to
you.
Note that we may process your
personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact the ADANTE REALTY if you need
details about the specific legal ground we are relying on to process your
personal data. We make sure we consider and balance any potential impact on you
and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law).
Marketing
We strive to provide you with
choices regarding certain personal data uses, particularly around marketing and
advertising. We have established the following personal data control
mechanisms:
Promotional offers from us We may use your Identity, Contact, Technical, Usage,
and Profile Data to form a view of what we think you may want or need, or what
may be of interest to you. This is how we decide which products, services, and
offers may be relevant for you. You will receive marketing communications from
us (or from another company within the ADANTE REALTY Group or third-party
vendor appointed by us) if you have requested information from us, if you have
provided your express consent for receiving that marketing, or, in certain cases
if it is in our legitimate interest.
Third-party marketing We will not share your personal data with any company
outside the ADANTE
REALTY Group for
marketing purposes.
For Opting out You can ask us to stop sending you marketing messages by
contacting the ADANTE REALTY at any time. Where you opt out of receiving these
marketing messages, you will still receive important information such as
changes to your existing services or products purchased from us.
Cookies
You can set your browser to
refuse all or some browser cookies or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more information
about the cookies we use, please see our cookie policy.
Telephone Calls
We may monitor and/or record
your telephone calls to us, or ours to you, or a third-party vendor appointed
to do so, to ensure consistent servicing levels (including staff training) and
account operation, to assist (where appropriate) in dealing with complaints or
disputes, and to assist us in ensuring we comply with our legal obligations.
Change of purpose
We will only use your personal
data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with
the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please
contact the ADANTE REALTY.
Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or
permitted by law.
5.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your
personal data with the parties set out below:
- Companies
within the ADANTE REALTY Group.
- External Third Parties
as set out in the Glossary.
- Third parties to whom
we may choose to transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6.
INTERNATIONAL TRANSFERS
We share your personal data
within the ADANTE
REALTY Group. Whenever
we transfer your personal data, we ensure a similar degree of protection is
afforded to it by ensuring that we use specific contracts or have robust. Companies
within the ADANTE
REALTY Group are
expected to comply with the group’s Data Protection Policy with is applicable
to all employees within the group. Please contact the ADANTE REALTY if you want
further information on the specific mechanism used by us when transferring your
personal data Internationally.
7.
DATA SECURITY
We have implemented appropriate
security measures to prevent your personal data from being accidentally lost,
used, or accessed in an unauthorised way, altered, or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors,
and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty
of confidentiality. We have put in place procedures to deal with any personal
data breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.
The safety and security of your information also depend on you. Where we have
given you (or where you have chosen) a password for access to certain parts of
our Website, you are responsible for keeping this password confidential. We ask
you not to share your password with anyone. Unfortunately, the transmission of
information via the internet is not completely secure. Although we do our best
to protect your personal information, we cannot guarantee the security of your
personal information transmitted to our Website. Any transmission of personal
information is at your own risk. We are not responsible for the circumvention
of any privacy settings or security measures contained on the Website.
8.
DATA RETENTION
We will only retain your
personal data 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. To determine the appropriate retention period for
personal data, we consider 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. Details of retention periods for different aspects of your
personal data are available in our retention policy which you can request from
us by contacting the ADANTE REALTY. In some circumstances, we may anonymize
your personal data (so that it can no longer be associated with you) for
research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
9.
YOUR LEGAL RIGHTS
Under certain circumstances, you
have rights under data protection laws in relation to your personal data. These
include:
- Requesting access to your personal
data.
- Requesting correction of the personal
data that we hold about you
- Requesting erasure of your personal
data.
- Objecting to
processing of
your personal data.
- Requesting restriction of processing of
your personal data.
- Requesting the transfer of your personal
data to you or to a third party
- Withdrawing consent at
any time where
we are relying on consent to process your personal data.
If you wish to exercise any of
the rights set out above, please contact us on EMAIL. Note, however, that while
we will generally comply with your requests, in certain scenarios we may be
able to comply with your request for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unreasonable, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all
legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
DATA
PROTECTION POLICY
SECTION
A – WHAT THIS POLICY IS FOR
Policy statement
ADANTE REALTY PROPERTIES LLC and its group
companies (Collectively “ADANTE
REALTY Group”) as
a data controller is committed to protecting and maintaining the
confidentiality, integrity security of personal data and respecting the rights
of our data subjects. We value the personal information entrusted to us and we
respect that trust, by complying with all applicable laws, regulations, and
adopting best industry practices.
Our management is fully committed to ensuring the continued and effective
implementation of this policy and expects all ADANTE REALTY Group’s employees and third
parties to share in this commitment. Any breach of this policy will be taken
seriously and may result in disciplinary action or business sanction.
Purpose and Scope
This policy establishes an
effective, accountable, and transparent framework for ensuring compliance with
the requirements of the applicable laws and regulations regarding the
protection of personal data. This policy applies to all our employees and all
third parties responsible for the processing of personal data on behalf of ADANTE REALTY Group.
Application of Policy
All employees processing
personal information on behalf of ADANTE REALTY Group are required to comply with this
policy. Any employee who thinks that he has accidentally breached any terms and
conditions of this policy should immediately contact to Data Protection Officer
to prevent and limit the impact of the breach. Various third parties (companies
or individuals) who are appointed by us as data processors are required to
comply with this policy under the contract with us. Any breach of the policy
will be taken seriously and could lead to taking contract enforcement action
against the company or individual or terminating the contract. Our Data
Protection Officer is responsible for advising us and our employees about their
legal obligations, monitoring compliance with applicable laws and regulations,
dealing with data security breaches, and with the development of this policy.
SECTION
B – OUR DATA PROTECTION RESPONSIBILITIES
Data
Collection
In the course of our work, we
will ensure that personal data is collected directly from the data subjects’
unless one of the following conditions apply:
- the nature of the
business purpose necessitates collection of the personal data from other
persons or bodies; or
- the collection must be
carried out under emergency circumstances in order to protect the vital
interests of the data subject or to prevent serious loss or injury to
another person.
If personal data is collected
from a source other than the data subject, the data subject will be informed of
the collection unless one of the following applies:
- the data subject has
received the required information by other means;
- a national law
expressly provides for the collection, processing, or transfer of personal
data.
Data Subject Consent
Each ADANTE REALTY Group entity will obtain
personal data only by lawful and fair means and, where appropriate with the
knowledge and consent of the data subject concerned. Where a need exists to
request and receive the consent of data subject prior to the collection,
processing, or disclosure of their personal data, ADANTE REALTY Group is committed to seeking
such consent. The Data Protection Officer, in cooperation with other relevant
business representatives, shall be responsible for establishing a system for
obtaining and documenting data subject consent for the collection, processing,
and/or transfer of their personal data.
Privacy Notices
We will inform data subjects in
writing whose personal data is collected about our identity/contact details and
those of the Data Protection Officer, the type of data collected, the reasons
for the processing, and the legal bases, including explaining any automated
decision-making or profiling, explaining our legitimate interests, and explaining,
where relevant, the consequences of not providing data needed for a contract or
statutory requirement, whom we will share the data with, how long the data will
be stored and the data subjects’ rights. This information will be communicated
through Privacy Notice and will be given at the time when the personal data is
collected.
Data Processing
We will only process personal
data for the specific purposes explained in our Privacy Notice or for other
purposes specifically permitted by law. We will not process personal data
unless at least one of the following legal conditions is met:
- the processing is
necessary for a contract with the data subject;
- the processing is
necessary for us to comply with a legal obligation;
- the processing is
necessary to protect someone’s life (“vital interests”);
- the processing is
necessary for us to perform a task in the public interest, and the task
has a clear basis in law; and
- the processing is
necessary for our legitimate interests unless overridden by the interests,
rights, and freedoms of the data subject.
We will only process Special
Categories of Data where the data subject expressly consents to such processing
or where one of the following conditions apply:
- the processing is
necessary for carrying out our obligations under employment and social
security and social protection law;
- the processing is
necessary for safeguarding the vital interests (in emergency, life or
death situations) of an individual and the data subject is incapable of
giving consent;
- the processing is
carried out in the course of our legitimate activities and only relates to
our members or persons we are in regular contact with in connection with
our purposes; and
- the processing is necessary for pursuing legal claims.
Data Subject’s Rights
We will process personal data in
line with the data subject’s rights including their right to:
- request access to any
of their personal data held by us (Subject Access Request);
- ask to have inaccurate
personal data changed;
- restrict processing, in
certain circumstances;
- object to processing,
in certain circumstances, including preventing the use of their data for
direct marketing;
- data portability, which
means to receive their data, or some of their data, in a format that can
be easily used by another person (including the data subject themselves)
or organisation;
- not be subject to
automated decisions, in certain circumstances; and
- withdraw consent when
we are relying on consent to process their data.
We will act on all valid
requests as soon as possible, and at the latest within one calendar month,
unless we have reason to, and can lawfully extend the time limit. This can be
extended by up to two months in certain circumstances.
All data subject’s rights are provided free of charge provided any Subject Access
Requests which are manifestly unfounded or excessive shall be provided on a
chargeable basis in accordance with applicable laws and regulations.
Any information provided to data subjects will be concise and transparent,
using clear and plain language.
Direct marketing
We will comply with the
applicable laws and regulations including any laws which may amend or replace
the laws and regulations around direct marketing. This includes, but is not
limited to when we make contact with data subjects by post, email, text
message, social media messaging, telephone (both live and recorded calls), and
fax.
Any direct marketing material that we send will identify us as the sender and
if a data subject exercises their right to object to direct marketing, we will
stop the direct marketing as soon as possible unless it is in our legitimate
interests.
Third-Party Data Processors
We will only share personal data
with third parties when we have a legal basis to do so and if we have informed
the data subject about the possibility of the data being shared unless legal
exemptions apply to informing data subjects about the sharing. Only authorised
and properly instructed staff are allowed to share personal data. Before
appointing a contractor/agent/supplier/service provider who will process
personal data on our behalf, we will carry out necessary due diligence. The
checks are to make sure the data processor will use appropriate technical and
organisational measures to ensure the processing will comply with applicable
laws and regulations, including keeping the data secure and upholding the
rights of data subjects.
We will only appoint third-party data processors on the basis of a written
contract that will require the data processor to comply with all relevant legal
requirements. We will continue to monitor the data processing, and compliance
with the contract, throughout the duration of the contract.
We will keep records of personal data shared with a third party, which will
include recording any exemptions which have been applied, and why they have
been applied
Data Retention
We will not keep personal data
longer than is necessary for the purposes that it was collected including for
the purposes of satisfying any legal, accounting, or reporting requirements.
Information about how long we will keep personal data can be found in our Data
Retention Policy which may be obtained by contacting the Data Protection
Officer.
Security of Personal Data
We will use appropriate measures
to keep personal data secure at all points of the processing. Keeping data
secure includes protecting it from unauthorised or unlawful processing, or from
accidental loss, destruction, or damage. We limit access to personal data to
those employees, agents, contractors, and other third parties who have a business
need to know.
We will implement security measures that provide a level of security that is
appropriate to the risks involved in the processing.
- technical systems
security;
- measures to restrict or
minimise access to data;
- measures to ensure our
systems and data remain available or can be easily restored in the case of
an incident;
- physical security of
information and of our premises;
- organisational
measures, including policies, procedures, training, and audits; and
- regular testing and
evaluating of the effectiveness of security measures.
Training and Guidance
Our employees/staff that have
access to personal data will have responsibilities under this policy outlined
to them as part of their employee induction training program. In addition, each
ADANTE REALTY Group entity accessing personal data will provide regular data
protection training and procedural guidance to its employees/staff.
SECTION
C – MANAGING CHANGE AND RISKS
Data Protection Impact
Assessments
When we plan to carry out any
data processing which is likely to result in a high risk we will carry out a
Data Protection Impact Assessment (DPIA). Any decision not to conduct a DPIA
will be recorded. We may also conduct a DPIA in other cases when we consider it
appropriate to do so.
Dealing with Data Protection
Breaches
Any individual who suspects that
a personal data breach has occurred due to theft or unauthorized disclosure of
personal data must immediately notify the ADANTE REALTY providing a description
of the incident. Notification of the incident can be made via e-mail to the ADANTE
REALTY. The ADANTE REALTY will investigate all reported incidents to confirm
whether or not a personal data breach has occurred. If a personal data breach
is confirmed, the ADANTE REALTY will follow the relevant authorised procedure
based on the criticality and quantity of the personal data involved. For severe
personal data breaches, ADANTE REALTY Group’s executive team will initiate and
chair an emergency response team to coordinate and manage the personal data
breach response.
Recommendations, Advice, and
Support
For any recommendations, advice,
and support in relation to this policy, please contact the ADANTE REALTY via
email at info@adanterealty.com
Schedule
1 – Definitions and useful terms
The following terms are used
throughout this policy and have meanings as set out below:
- Data Controller means any person,
company, authority, or other body who (or which) determines the means for
processing personal data and the purposes for which it is processed. The
data controller is responsible for the personal data which is processed
and the way in which it is processed. We are the data controller of the
data which we process.
- Data
Processors include any individuals or organisations, which process
personal data on our behalf and on our instructions. This definition will
include our entities within ADANTE REALTY Group, employees who may be data
subjects.
- Data Protection Officer is an expert on
data privacy who works independently to ensure that data control and
processor are adhering to the applicable laws and regulations including
policies and procedures in relation to data protection.
- Data Subjects include all
living identifiable individuals who we hold or otherwise process personal
data about.
- Personal Data means any
information relating to a natural person (living person) who is either
identified or identifiable. A natural person must be an individual and
cannot be a company or a public body. Representatives of companies or
public bodies would, however, be natural persons. Personal data is limited
to information about living individuals and does not cover deceased
people. Personal data can be factual (for example, a name, address, or
date of birth) or it can be an opinion about that person, their actions,
and behaviour.
- Privacy Notice means the
information given to data subjects that explains how we process their data
and for what purposes.
- Special Categories of
Personal Data include
information about a person’s:
- Racial or ethnic origin;
- Political opinions;
- Religious or similar
beliefs;
- Trade union
membership;
- Health (including
physical and mental health, and the provision of health care services);
- Genetic data;
- Biometric data;
- Sexual life and sexual
orientation.
Contacting us:
If you have any questions about
this Privacy Policy and/ or Our privacy practices of the Websites, or your
dealings with Our Websites, please contact us at:
ADANTE REALITY PROPERTIES LLC P.O,
Box
231433, Office No:5, Central Plaza, Dip1, Dubai, UAE