Updated September 2018
Penny Strawson Property Consulting Ltd (hereinafter called PSPC Ltd) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
Personal Information We May Collect
We collect two types of information in connection with the Sites: Personal Information and Other Information. “Personal Information” is information that identifies you or relates to you as an individual. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual. Other Information is addressed below, under the heading “OTHER INFORMATION”.
We may collect Personal Information through the Sites such as:
- Email address
- Telephone numbers
- Postal or other physical address
How We May Use Personal Information
We may use Personal Information:
- to respond to your inquiries and fulfill your requests, such as to send you newsletters or publications that you request, or to invite you to events.
- to send you updates and mailings relating to our offering that we think may be of interest to you, in accordance with applicable law.
- to keep a record of your contact information and correspondence, if you contact us through the Sites, and to use such information and correspondence to respond to you.
- to send you administrative information, including information regarding the Sites and changes to our terms, conditions and policies.
- to facilitate social sharing functionality.
- to provide relevant information that match your stated preferences on our Sites.
- for our internal business purposes, such as improving or modifying the Sites and operating and expanding our business activities.
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed:
- to our third-party service providers which provide services such as website hosting, data analysis, IT services and infrastructure, customer service, email delivery, auditing and other similar services.
- to a third party (whether affiliated or unaffiliated with us) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).
- by you, on message boards, blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Sites and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Sites.
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and Other Information provided by you
- Aggregated information
- Zip code
How We May Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser: Most Internet browsers transmit certain information to websites that you visit, such as your computer’s type (Windows or Macintosh) and its Media Access Control (MAC) address and screen resolution, and the type and version of your computer’s Operating System and browser. We use this information to ensure that the Sites functions properly.
- Using applications: We may use applications, including mobile applications or widgets, to collect information from you.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Sites pages and HTML-formatted email messages to, among other things, track the actions of Sites users and email recipients, measure the success of marketing campaigns and compile statistics about Sites usage and response rates.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Sites usage levels, helping diagnose server problems and administering the Sites.
- From you: We collect information when voluntarily provided by you, such as your company, title, interests and preferred means of communication. Unless combined with Personal Information, such information does not personally identify you or any other user of the Sites.
- By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Sites. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.
How We May Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, except where we are required to treat Other Information as Personal Information under applicable law. In those situations, we may use and disclose Other Information for the purposes for which we use and disclose Personal Information, as well as for the uses listed in the “How We May Collect Other Information” section above.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your company and title). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.
We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data storage system or method of data transmission over the Internet can be guaranteed to be 100% secure.
Please do not send sensitive or confidential information to us by email or by any other means in connection with the Sites. If you have reason to believe that your communications with us have been compromised in any way, please immediately notify us of the problem by contacting us by emailing [email protected]
Choices and Access
Your choices regarding our use of your Personal Information for marketing purposes:
If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message. We aim to comply with such request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you administrative messages.
How you can access, change or suppress your Personal Information
You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Sites, or object to the use of such Personally Identifiable Information by us. You may exercise these rights contacting us at [email protected] and will aim to comply with such request(s) as soon as is reasonably practicable. Additionally, you may also oppose the processing or transferring of Personal Information to the extent the laws of your country require, if you have a legitimate reason to do so. In your request, please make clear what information you would like to have changed, and whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We aim to comply with requests as soon as reasonably practicable.
Please note that we may need to retain certain information for record-keeping purposes, and there may also be residual information that will remain within our databases and other records. Such information will not be removed. We may, from time to time, re-contact former users of the Sites. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared your Personal Information.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Use of Site by Minors
The Sites is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Sites.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Sites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Sites or otherwise to us.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request the address below.
You can also contact us by writing to this address:
Attention: Privacy Officer
Post Office Box MO6612 ,
Rodney Bay, Saint Lucia, West Indies
If you reside in the EU, United Kingdom, Lichtenstein, Norway or Iceland, you can also contact our Data Protection Officer by emailing [email protected]
In your request, please make clear what information you would like to have changed, and whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We aim to comply with requests as soon as reasonably practicable.
Please note that we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records. Such information will not be removed. We may, from time to time, re-contact former users of the Sites. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared your Personal Information.