This privacy statement is issued by JBB Property Limited, a company registered in England (company number 11911516) whose principal place of business is at 1 Motcomb Street, London, SW1X 8JX.

We take your privacy seriously and this privacy statement explains how we use the personal information we collect from you.

We may change the way in which we process personal data from time to time in which case we will update this privacy policy to reflect the changes. 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.

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 policy of every website you visit.

What personal information do we collect?

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 we have grouped together as follows:

• Identify data such as your first name, maiden name, surname, date of birth and proof of identification.
• Contact data such as your address, email address, delivery address and telephone address.
• Financial data such as information about your financial requirements, budget and proof of funds.
• Transaction data such as payments to and from you and other details of services you have purchased from us.
• Property data such as details about your property.
• Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
• We may also record inbound and outbound phone calls. The information we hold may include your name, contact details and details of your enquiry.

Anonymised Information and Analysis

We may collect information about your interaction with our website but this will be done on an anonymised basis in order to undertake statistical analysis of the way in which visitors use our website.

Special Category Data Information

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal conviction or offences.

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 have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How do we collect personal information?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial Data and Property Data when you communicate with us in person or by letter, telephone, facsimile, email, text message and our website. This includes personal data you provide when you subscribe to our publications, request marketing information to be sent to you, give us feedback or contact us.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as social media, advertising portals and search information providers.

How we use your personal information.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• if you fill in forms on our website, complete a survey, or contact us by any other means, we use the information to provide customer care and to respond to your enquiry or contact you on the basis that we have a legitimate interest to do so and to perform under the contract we may have in place with you;
• we may use your information for administration, audit purposes, regulatory and governance activities and compliance or the basis that we have a legitimate interest to do so as well as a legal obligation;
• if we contact you or if you contact us by means of a phone call and if we record such a call, we use the information for training and monitoring purposes on the basis that we have a legitimate interest to do so; and
• (if you have consented to receiving information from us about our services) to send newsletters and other marketing communications to you on the basis that you have consented for us to do so.

Who do we share your personal information with?

We may share your personal information with the following parties:

• service suppliers who undertake processing on our behalf (for example reference checks); and
• where you propose entering into a contract for the purchase, sale or letting of a property, the other party to the contract and his/her representatives (such as solicitors).

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.

Data Security

 We have put in place 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 suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will we keep your personal information?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

As a general rule we will keep financial information and personal information relating to property transactions for a period of 7 years and all other personal information for 4 years.

Cookies

We may use technology to track the patterns of behaviour of visitors to our website. This may include using a “cookie” (i.e. a small file which is downloaded onto your computer) to enable our website to recognise your computer and see how you use the website. It saves your preferences so as to improve your browsing experience when you next visit our website. It also allows us to provide you with information which is specifically tailored to your interests.

We will only use cookies if you consent to us doing so. Please note that if you disable the cookies function, you may not be able to access all or parts of our website.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy (b) where our use of the data is unlawful but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Queries and Complaints

If you wish to exercise any of the rights set out above or if you have any queries about this privacy statement, or any complaints about the way in which we handle your personal information, please contact us at [email protected] or at the address set out above. We will investigate any complaint promptly with a view to resolving the matter without the need for you to take the matter further (for example by contacting the Information Commissioner’s Office).

This Privacy Statement was last updated June 2022.