PRIVACY POLICY

Data Protection and General Data Protection Regulation

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This Website collects some Personal Data from its Users. We are required to gather certain
personal data about clients and guests for the purposes of satisfying operational and legal
obligations. This personal data will be subject to the appropriate legal safeguards as
specified in the Data Protection Act 1998. 
We fully endorse and adhere to the eight principles of the Data Protection Act. These
principles specify the legal conditions that must be satisfied in relation to obtaining, handling,
processing, transportation and storage of personal data. The principles require (amongst
other things) that the personal data shall be obtained for a specified and lawful purpose and
shall not be processed in any manner incompatible with that purpose.

The purpose for which we hold your personal data is to carry out this Agreement, and we do
not pass information on to third parties save for this purpose. We may use cookies on our
website for the purpose of monitoring website usage, and we will ask for your consent, but
do ask that you inform us if you do not consent to the use of these cookies.

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Owner and Data Controller
Jesswood Properties Ltd, 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX

Owner contact 
email: sasha@jesswoodproperties.com

Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third
parties, there are: Cookies, Usage Data, email address, first name, last name, phone
number, country, ZIP/Postal code, date of birth, city, address and company name. Complete
details on each type of Personal Data collected are provided in the dedicated sections of this
privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected
automatically when using this Website. Unless specified otherwise, all Data requested by
this Website is mandatory and failure to provide this Data may make it impossible for this
Website to provide its services. 

In cases where this Website specifically states that some Data is not mandatory, Users are
free not to communicate this Data without consequences to the availability or the functioning
of the Service. Users who are uncertain about which Personal Data is mandatory are
welcome to contact the Owner. 

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-
party services used by this Website serves the purpose of providing the Service required by
the User, in addition to any other purposes described in the present document and in the
Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained,
published or shared through this Website and confirm that they have the third party’s
consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure,
modification, or unauthorized destruction of the Data. The Data processing is carried out
using computers and/or IT enabled tools, following organizational procedures and modes
strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data
may be accessible to certain types of persons in charge, involved with the operation of this
Website (administration, sales, marketing, legal, system administration) or external parties
(such as third-party technical service providers, mail carriers, hosting providers, IT
companies, communications agencies) appointed, if necessary, as Data Processors by the
Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. 
Note: Under some legislations the Owner may be allowed to process Personal Data until the
User objects to such processing (“opt-out”), without having to rely on consent or any other of
the following legal bases. This, however, does not apply, whenever the processing of
Personal Data is subject to European data protection law; provision of Data is necessary for
the performance of an agreement with the User and/or for any pre-contractual obligations
thereof; processing is necessary for compliance with a legal obligation to which the Owner is
subject; processing is related to a task that is carried out in the public interest or in the
exercise of official authority vested in the Owner; processing is necessary for the purposes
of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
Place

The Data is processed at the Owner’s operating offices and in any other places where the
parties involved in the processing are located. Depending on the User’s location, data
transfers may involve transferring the User’s Data to a country other than their own. To find
out more about the place of processing of such transferred Data, Users can check the
section containing details about the processing of Personal Data. 
Users are also entitled to learn about the legal basis of Data transfers to a country outside
the European Union or to any international organization governed by public international law
or set up by two or more countries, such as the UN, and about the security measures taken
by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections
of this document or inquire with the Owner using the information provided in the contact
section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they
have been collected for. Therefore: Personal Data collected for purposes related to the
performance of a contract between the Owner and the User shall be retained until such
contract has been fully performed. Personal Data collected for the purposes of the Owner’s
legitimate interests shall be retained as long as needed to fulfill such purposes.
Users may find specific information regarding the legitimate interests pursued by the Owner
within the relevant sections of this document or by contacting the Owner. The Owner may be
allowed to retain Personal Data for a longer period whenever the User has given consent to
such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be

obliged to retain Personal Data for a longer period whenever required to do so for the
performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to
access, the right to erasure, the right to rectification and the right to data portability cannot
be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well
as for the following purposes: User database management, Displaying content from external
platforms, Interaction with external social networks and platforms, Contacting the User,
Handling payments and Platform services and hosting.

Users can find further detailed information about such purposes of processing and about the
specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contacting the User, Displaying content from external platforms, Handling payments,
Interaction with external social networks and platforms, Platform services and hosting, User
database management.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner. In
particular, Users have the right to do the following:

•  Withdraw their consent at any time – Users have the right to withdraw consent where they have previously given their consent to the   processing of their Personal Data.

•  Object to processing of their Data – Users have the right to object to the processing of their Data if the processing is carried out on a   legal basis other than consent.

Further details are provided in the dedicated section below.

• Access their Data – Users have the right to learn if Data is being processed by the

       Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

• Verify and seek rectification – Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

• Restrict the processing of their Data – Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed – Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

• Receive their Data and have it transferred to another controller – Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.

• Lodge a complaint – Users have the right to bring a claim before their competent data protection authority.

 

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority
vested in the Owner or for the purposes of the legitimate interests pursued by the Owner,
Users may object to such processing by providing a ground related to their particular
situation to justify the objection. Users must know that, however, should their Personal Data
be processed for direct marketing purposes, they can object to that processing at any time
without providing any justification. To learn whether the owner is processing Personal Data
for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact
details provided in this document. These requests can be exercised free of charge and will
be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the
stages leading to possible legal action arising from improper use of this Website or the
related Services. The User declares to be aware that the Owner may be required to reveal
personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Website may provide the
User with additional and contextual information concerning particular Services or the
collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may
collect files that record interaction with this Website (System logs) use other Personal Data
(such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested
from the Owner at any time. Please see the contact information at the beginning of this
document.

How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the
third-party services it uses honor the “Do Not Track” requests, please read their privacy
policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving
notice to its Users on this page and possibly within this Website and/or – as far as
technically and legally feasible – sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often, referring to the
date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s
consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references

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Latest update: 5th December, 2020