Updated 1st July 2020 Summary:
ML Property Venture is committed to respecting your privacy and protecting your personal information. Thank you for choosing to work with us.
- We will be transparent about the information we are collecting and what we will do with it.
- We will also use the information to help us understand you better and so that we can give you relevant offers.
- If you tell us, you don’t want to receive marketing messages we will stop sending them. We will, of course, continue to send essential information relating to a service you have subscribed for and/or purchased to keep you informed about what we have to offer.
- We have measures in place to protect your information and keep it secure. We will respect your data protection rights and aim to give you control over your own information.
- “Client” means a customer of ML Property Venture Limited.
- “Client Data” means Personal Data a Client provides to use the Service.
- “Personal Data” means any information relating to an identified or identifiable natural person or considered personally identifiable information by law. means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
- “Public Area” means those portions of the Service that can be accessed both by Users and Visitors, without needing to log in.
- “Restricted Area” means those portions of the Service that can be accessed only by logging in. “User” means a person or entity that uses the Service.
- “User Data” means Personal Data that a User provides to use the Service.
- “Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
- “Account” means an account required to access and/or use certain areas and features of Our Site
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
- “We/Us/Our” – means ML Property Venture Limited, a limited company registered in England under company number 11811131, whose registered address is 19 Wood View, Grays, RM16 2WJ.
Information About Us
Our Site is owned operated by ML Property Venture Limited, a limited company registered in England under company number 11811131, whose registered address is 19 Wood View, Grays, RM16 2WJ. Our Data Protection Officer and EU representative can be contacted by email at firstname.lastname@example.org.
2. What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you;
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, but if you would like Us to delete it sooner, please contact Us);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling. If you have any cause for complaint about Our use of your personal data, please contact Us and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
3. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
- business/company name
- contact information such as email addresses and telephone numbers;
- demographic information such as address, post code and investment preferences;
- financial information such as credit / debit card numbers, billing address, mailing address, name on credit / debit card, business or home phone number, email information;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to; If you choose to correspond with Us through email, We may retain the content of your email messages together with your email address and Our responses. We provide the same protections for these electronic communications that We employ in the maintenance of information received by mail and telephone. We collect information to provide and improve our Service to you. We sometimes collect Personal Data including:
- “Registration Information”: When you register to use our Service, you will be asked to complete a registration form. This form requires providing information such as name, address, phone number, email address and other Personal Data. This form also requires providing information about your business and/or investment preferences.
- “Publishing Information”: We also collect information you submit through our Site or to us for publication on the Site through the publishing tools there. By submitting Publishing Information, you consent to its publication to the extent such information is not Personal Data.
- “Usage Data”: We may also collect information that your browser sends whenever you visit our Service. This may include information such as your computer’s Internet Protocol address (i.e. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and the like. Usage Data may also include data about your purchasing patterns, your contact details, and your profile information.
- When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
- “Payment Information“: We may collect billing information, credit card numbers and expiration dates, tracking information from checks or money orders, or other payment information particularly if you establish a credit account with us or our providers or if you purchase a product or service from us, other Users of the Service, or other vendors available through the Site.
- “Statistical Information“: In addition, we gather statistical information about our Site and Users, such as IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions, unique visitors and so forth.
- “Marketing Information“: From time to time, we gather information about our Users and prospective users during trade shows, events and other functions for follow up marketing purposes.
- “Disclosed Personal Information“: From time to time, our Users may disclose Personal Data deliberately or inadvertently including without limitation to personal identifiers such as name, email addresses, telephone number, facsimile number and IP address of individuals in the course of using the Site.
You can determine if and how a cookie will be accepted by configuring your browser, which is installed in the computer you are using to access the Site. If you desire, you can change those configurations in your browser to accept all cookies, to be notified when a cookie is sent, or to reject all cookies. If you reject all cookies you may be required to re-enter your information on our Site more often and certain features of our Site may be unavailable.
Examples of Cookies we may use: Session Cookies. We may use Session Cookies to operate our Service. Preference Cookies. We may use Preference Cookies to remember your preferences and various settings. Security Cookies. We may use Security Cookies for security purposes.
3.3 Collected Information. By “Collected Information” we mean information collected by cookies, information collected by Clients that is provided to us or collected by us as Client Data, Registration Information, Publishing Information, Usage Data, Payment Information, Account Activities Information, Statistical Information, Marketing Information, Disclosed Personal Information and any information we may collect from you, from our affiliates, or from other parties or through any other means.
4. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our products and services for you;
- Replying to emails from you;
Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by contacting email@example.com.
Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third parties whose content appears on Our Site may use third party Cookies.
Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
By law we have to keep basic information about our customers (including contact, identity, financial and transaction Data) for seven years after they cease being customers for tax purposes; and
In some circumstances we may anonymise 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.
We may use the information that We collect to notify you about important changes to Our Site, new products and services, and special offers that We think you will find valuable. You may notify Us at any time if you do not wish to receive these offers by contacting firstname.lastname@example.org.
5. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 4, and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR. These steps include:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
6. Do We Share Your Data?
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
7. How Can You Control Your Data?
When you submit personal data via Our Site, you may be given options to restrict Our use of your 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.
8. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com.
By using Our Site 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 Site for Google Analytics and Facebook Pixel(s). These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
10. A Special Note About Children
Children are not eligible to use Our products or services unsupervised and We ask that children (under the age of 18) do not submit any personal information to us. If you are a minor, you can use this service only in conjunction with permission and guidance from your parents or guardians.
11. Contacting Us
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you. 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.