Privacy Policy

What is this Privacy Policy for?

This privacy policy is for this website [commercialpropertyinvestor.co.uk] and governs
the privacy of its users who choose to use it.

Introduction

  1. This is a notice to inform you of our policy about all information
    that we record about you. It sets out the conditions under which we may
    process any information that we collect from you, or that you provide to
    us. It covers information that could identify you (“personal information”)
    and information that could not. In the context of the law and this notice,
    “process” means collect, store, transfer, use or otherwise act on
    information.
  2. We regret that if there are one or more points below with which you
    are not happy, your only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and
    confidentiality. We understand that all visitors to our website are
    entitled to know that their personal data will not be used for any purpose
    unintended by them, and will not accidentally fall into the hands of a
    third party.
  4. We undertake to preserve the confidentiality of all information you
    provide to us, and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including
    that required by the EU General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our
    obligations to you in regards to the processing and control of your
    personal data. We do this now, by requesting that you read the information
    provided at knowyourprivacyrights.org
  7. Except as set out below, we do not share, or sell, or disclose to a
    third party, any information collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different
categories of your personal information, and to notify you of the basis for
each category.

If a basis on which we process your personal information is no longer relevant, then we shall
immediately stop processing your data.

If the basis changes then if required by law, we shall notify you of the change and of any
new basis under which we have determined that we can continue to process your
information.

1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or
otherwise agree to our terms and conditions, a contract is formed between you
and us.

In order to carry out our obligations under that contract we must process the information
you give us. Some of this information may be personal information.

We may use it in order to:

  • verify your identity for security purposes
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and
    how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have
requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class
information, for example to monitor our performance with respect to a
particular service we provide. If we use it for this purpose, you as an
individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is
terminated by either party under the terms of the contract.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us,
such as when you browse our website or ask us to provide you more information
about our business, including our products and services, you provide your
consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information,
for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by
e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do
not use your information in any way that would identify you personally. We may
aggregate it in a general way and use it to provide class information, for
example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name
and contact information to selected associates whom we consider may provide
services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it
can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at marketing@kinrossoffice.co.uk. However, if you do so, you may not be able to use our website or our services further.

3. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in
order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request
or if they have the proper authorisation.

This may include your personal information.

Specific uses of information you provide to us

4. Information provided on the understanding that it will be shared with a third party

Once your information enters the public domain, we have no control over what any
individual third party may do with it. We accept no responsibility for their
actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at
our discretion we may agree to your request to delete personal information that
you have posted. You can make a request by contacting us.

5. Complaints regarding content on our website

We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.

If you complain about any of the content on our website, we shall investigate your
complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the
content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be
obstructed: yours, or that of the person who posted the content that offends
you.

If we think your complaint is vexatious or without any basis, we shall not correspond with
you about it.

6. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our
website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of ‘WorldPay’ or
some other reputable payment service provider. That page may be branded to look
like a page on our website, but it is not controlled by us.

9. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect
the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your
name and email address so as to be able to track our communications with you to
provide a high quality service.

10. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to
give to that other person some of the information contained in your complaint.
We do this as infrequently as possible, but it is a matter for our sole
discretion as to whether we do give information, and if we do, what that
information is.

We may also compile statistics showing information obtained from this source to assess the
level of service we provide, but not in a way that could identify you or any
other person.

11. Affiliate and business partner information

This is information given to us by you in the situation where you have been allowed to act in the
capacity of an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you
commission due for such referrals. It also includes information that allows us
to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our
relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website

12. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web
browser when you visit any website. They allow information gathered on one web
page to be stored until it is needed for use on another, allowing a website to
provide you with a personalised experience and the website owner with
statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your
browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to
prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by
software operated by third parties whose services we use.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our
    website
  • to keep you signed in our site
  • to record your answers to surveys and questionnaires on our site
    while you complete them
  • to record the conversation thread during a live chat with our
    support team

13. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website
are recorded.

We record information such as your geographical location, your Internet service provider
and your IP address. We also record information about the software you are
using to browse our website, such as the type of computer or device and the
screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our
website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data
possibly could be used to identify you personally, even if you are not signed
in to our website.

14. Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you
visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so,
then if you have consented to our use of cookies, you may see advertisements
for our products and services on other websites.

Disclosure and sharing of your information

15. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in
this notice), we sometimes receive data that is indirectly made up from your
personal information from third parties whose services we use.

No such information is personally identifiable to you.

16. Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other
companies working for them may use technology that automatically collects
information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content
of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third
parties.

17. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as
it relates to clients or customers who instruct their credit card issuer to
cancel payment to us without having first provided an acceptable reason to us
and given us the opportunity to refund their money.

18. Data may be processed outside the European Union

Our websites may be hosted in countries outside of the European Union such as the United
States of America.

We may also use outsourced services in countries outside the European Union from time to
time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the
European Union.

For example, some of the software our website uses may have been developed in the United
States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European
Union:

  • the processor is within the same corporate group as our business or
    organisation and abides by the same binding corporate rules regarding data
    processing.
  • the data protection clauses in our contracts with data processors
    include transfer clauses written by or approved by a supervisory authority
    in the European Union
  • we comply with a code of conduct approved by a supervisory
    authority in the European Union
  • we are certified under an approved certification mechanism as
    provided for in the GDPR
  • both our organisation and the processor are public authorities
    between whom there is either a legally binding agreement or administrative
    arrangements approved by a supervisory authority in the European Union
    relating to protection of your information

Access to your own information

19. Access to your personal information

  • At any time you may review or update personally identifiable
    information that we hold about you, by signing in to your account on our
    website.
  • To obtain a copy of any information that is not provided on our
    website you may send us a request at marketing@kinrossoffice.co.uk
  • After receiving the request, we will tell you when we expect to
    provide you with the information, and whether we require any fee for
    providing it to you.

20. Removal of your information

If you wish us
to remove personally identifiable information from our website, you may contact
us at marketing@kinrossoffice.co.uk

This may limit
the service we can provide to you.

21. Verification of your information

When we
receive any request to access, edit or delete personal identifiable information
we shall first take reasonable steps to verify your identity before granting
you access or otherwise taking any action. This is important to safeguard your
information.

Other
matters

22. Use of site by children

  • We do not sell products or provide services for purchase by
    children, nor do we market to children.
  • If you are under 18, you may use our website only with consent from
    a parent or guardian

23. Encryption of data sent between us

We use Secure
Sockets Layer (SSL) certificates to verify our identity to your browser and to
encrypt any data you give us.

Whenever
information is transferred between us, you can check that it is done so using
SSL by looking for a closed padlock symbol or other trust mark in your
browser’s URL bar or toolbar.

24. How you can complain

  • If you are not happy with our privacy policy or if you have any complaint,
    then you should tell us by email. Our address is marketing@kinrossoffice.co.uk
  • If a dispute is not settled then we hope you will agree to attempt
    to resolve it by engaging in good faith with us in a process of mediation
    or arbitration.
  • If you are in any way dissatisfied about how we process your
    personal information, you have a right to lodge a complaint with the Information
    Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

25. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information
only for as long as required by us:

  • to provide you with the services you have requested;
  • to comply with other law, including for the period demanded by our
    tax authorities;
  • to support a claim or defence in court.

26. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy
the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

27.
Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you
are those posted here on our website on the day you use our website. We advise
you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

 

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28th October 2021

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