Privacy Policy

As of January 2024

Table of contents

  1. Identity and contact details of the data controller
  2. Contact details of the data protection officer & EU Representation
  3. General information on data processing
  4. Rights of the data subject
  5. Provision of website and creation of log files
  6. Use of cookies
  7. Contact via email
  8. Sign up option
  9. Start Free Trial Subscription
  10. Processing of personal information for PropertyBox marketing
  11. Use of corporate profiles in professionally oriented networks
  12. Hosting

 

 

1. Identity and contact details of the data controller

FocalAgent Ltd, trading as PropertyBox, may act as both a data processor and a data controller of your personal data. Where we act as a data processor, this means that we only process data about you to provide our service to our customers, or on the instructions of our customers that use us to provide their services. For information on how our customer use your personal data, including how we fit into that processing, you should review their privacy notice or contact them for more information.

This privacy notice only applies to the personal data we process as a data controller. This means we are responsible for deciding how we collect, use, and store information about you. The data controller responsible is:

FocalAgent Ltd
124 City Road
London, EC1V 2NX
United Kingdom
+442035989669
Privacy@focalagent.com

www.focalagent.com

 

2. Contact details of the data protection officer & EU Representation

Data Protection Officer

The designated data protection officer is:

DataCo International UK Limited
Suite 1, 7th Floor, 50 Broadway London, United Kingdom
SW1H 0BL
Telephone: +442035146557

Email: privacy@dataguard.co.uk

 

EU Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

Ireland, France, Germany

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our Representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/13009434627

 

3. General information on data processing

(1) Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

(2) Legal basis for data processing

Where consent is appropriate for processing personal data, Article 6(1)(a) UK GDPR and EU GDPR serves as the legal basis to obtain your consent for the processing of your data.

As for the processing of personal data required for the performance of a contract of which you are a party, Article 6(1)(b) UK GDPR and EU GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Article 6(1)(c) UK GDPR and EU GDPR serves as the legal basis.

If vital interests of yourself or another natural person require the processing of personal data, Article 6(1)(d) UK GDPR and EU GDPR serves as the legal basis.

When it is necessary to process personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as a data controller, Article 6(1)(e) UK GDPR and EU GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and your fundamental rights and freedoms do not outweigh the interest of the former, Article 6(1)(f) UK GDPR and EU GDPR will serve as the legal basis for the processing of data.

(3) Data removal and storage duration

Your personal data will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by international regulations, law, or other relevant regulations to which we are subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

(4) Who we share your data with

Personal data collected from you for the purpose of Property Box services, may be shared with our service providers in order to help us deliver our services. This includes payment processors who facilitate the payment of subscriptions via the website. Personal data may also be shared with affiliated entities or brands of Property Box.

(5) Transfers of personal data

Where your personal data is transferred outside the UK or the European Union, we ensure that your data is protected. Where transfers of personal data occur from the European Union to the United Kingdom, we rely on adequacy for this transfer. We also rely on adequacy to transfer your data when it is transferred from the United Kingdom to the European Union.

Where personal data is transferred to a third country where there is no adequacy decision by the United Kingdom Government or the European Commission, Property Box relies on other safeguards enhanced through contractual agreements. This could include the use of Standard Contractual Clauses (in conjunction with the UK International Data Transfer Addendum for transfers from the UK to a third country without adequate levels of data protection).

 

4. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and the EU GDPR and have the following rights:

(1) Right to information

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

  • The purpose for which the personal data is processed.
  • The categories of personal data being processed.
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed.
  • The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
  • The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
  • The existence of the right to lodge a complaint with a supervisory authority.
  • Where personal data are not collected from you, any available information as to their source.
  • The existence of automated decision-making including profiling under Article 22(1) and Article 22(4) UK GDPR and the EU GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on you.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organisation. In this context, you can then request for the appropriate guarantees in accordance with Article 46 UK GDPR and EU GDPR in connection with the transfer.

(2) Right to rectification

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

(3) Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data;
  • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of its use instead;
  • The data controller or its representative no longer needs the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
  • If you have objected to the processing pursuant to Article 21(1) UK GDPR and EU GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the United Kingdom, European Union or of a Member State.

If the processing has been restricted according to the aforementioned conditions, you will be informed before the restriction is lifted.

(4) Right to erasure

(4.a) Obligation to erase

If you request the deletion of your personal data from us as data controller, we are required to do so immediately if one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
  • You withdraw your consent on which the processing is based pursuant to Article 6(a) and Article 9(2)(a) UK GDPR and EU GDPR and there is no other legal basis for processing the data.
  • According to Article 21(1) UK GDPR and EU GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Article 21(2) UK GDPR and EU GDPR.
  • Your personal data has been processed unlawfully.
  • The personal data must be deleted to comply with a legal obligation in the United Kingdom, European Union law or Member State law to which we as the data controller are subject.
  • Your personal data was collected in relation to information society services offered pursuant to Article 8(1) UK GDPR and EU GDPR.

(4.b) Information to third parties

If we as the data controller have made your personal data public and must delete the data pursuant to Article 17(1) UK GDPR and EU GDPR, we shall take appropriate measures, including technical means, to inform other data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

(4.c) Exceptions

The right to deletion does not exist if the processing is necessary:

  • to exercise the right to freedom of speech and information;
  • to fulfil a legal obligation required by the law of the United Kingdom, European Union or Member States to which we as the data controller are subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative;
  • for reasons of public interest in the field of public health pursuant to Article 9(2)(h) and Article 9(2)(i) and Article 9(3) UK GDPR and EU GDPR;
  • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) UK GDPR and EU GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing; or
  • to enforce, exercise or defend legal claims.

(5) Right to information

If you have the right of rectification, erasure, or restriction of processing, we are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed by us about the recipients of your data.

(6) Right to data portability

You have the right to receive your personal data given to us as the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by us as the data controller who was initially given the data, if:

  • the processing is based on consent in accordance with Article 6(1)(a) UK GDPR and EU GDPR or Article 9(2)(a) UK GDPR and EU GDPR or performance of a contract in accordance with Article 6(1)(b) UK GDPR and EU GDPR; and
  • the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to us as the data controller.

(7) Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Article 6(1)(e) or 6(1)(f) UK GDPR and EU GDPR; this also applies to profiling based on these provisions.

As the data controller. we will no longer process the personal data concerning you unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.

(8) Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

(9) Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:

  • is required for the conclusion or execution of a contract between you and us as the data controller;
  • is permitted by the European Union or Member State legislation to which we as the data controller are subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests; or
  • is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Article 9(1) UK GDPR and EU GDPR, unless Article 9(2)(a) or Article 9(2)(b) UK GDPR and EU GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in the first and third items above, we as the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from us or our representative, to express your opinion on the matter, and to contest the decision.

(10) Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR or the EU GDPR.

If you are located in the United Kingdom, you shall have the right to complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO’s address:

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF
Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article 78 UK GDPR.

If you are located in Ireland, you have the right to complain to the Data Protection Commission (DPC) if you are unhappy with how we have used your data and/or believe that the processing of the personal data concerning you violates the applicable law. The DPC’s address is:

Data Protection Commission
21 Fitzwilliam Square South

Dublin 2
D02 RD28
Ireland

Helpline number: 01 7650100 / 1800437 737

DPC website: https://www.dataprotection.ie/

If you are located in France, you have the right to complain to the National Commission for Information Technology and Liberties (CNIL) if you are unhappy with how we have used your data and/or believe that the processing of the personal data concerning you violates the applicable law. The CNIL’s address is:

Commission nationale de l’informatique et des libertés
3 Place de Fontenoy

TSA 80715
75334 PARIS CEDEX 07
France
Helpline number: +33 (0)1 53 73 22 22

CNIL website: https://www.cnil.fr/en

If you are located in Germany, you have the right to complain to the Federal Commission for Data Protection and Freedom of Information if you are unhappy with how we have used your data and/or believe that the processing of the personal data concerning you violates the applicable law. The Federal Commission for Data Protection and Freedom of Information’s address is:

Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Graurheindorfer Straße 153
53117 Bonn
Germany
Helpline number: +49 228 997799 0

Email: poststelle@bfdi.bund.de

Website: http://www.bfdi.bund.de/

 

Please note that the competence for complaints in Germany is split among different data protection supervisory authorities. These competent authorities can be identified according to the list provided here: https://www.bfdi.bund.de/DE/Service/Anschriften/anschriften_node.html

 

5. Provision of website and creation of log files

(1) Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Browser type and version used;
  • The user’s operating system;
  • The IP address of the user;
  • Date and time of access;
  • Forms data capture.

This data is stored in the log files of our system. This data is not stored together with other personal data about you.

(2) Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to your computer. For this purpose, the your IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

(3) Legal basis for data processing

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Article 6(1)(f) UK GDPR and EU GDPR.

(4) Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, it will be retained for fourteen days at the latest. Storage beyond this is possible. In this case, your IP addresses are deleted or alienated so that an assignment of the calling client is not possible.

(5) Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, you may not object to the aforementioned processes.

 

6. Use of cookies

(1) Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or the internet browser on your computer system. If a user calls up a website, a cookie can be stored on their operating system. These cookies contain a string of characters that allows the browser to be uniquely identified when the website is reopened.

We use cookies to make our website more user-friendly. Some elements of our website require the calling browser to be identified even after a page break.

The following data is stored and transmitted in the cookies:

  • Frequency of page views.
  • Masked IP address

User data collected in this manner is pseudonymised by technical measures. It is therefore not possible to assign the data to a user accessing the site. The data is not stored together with other personal data of the users.

(2) Purpose of data processing

The purpose of using technical cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. These require that the browser is recognised even after a page change.

We need cookies for the following purposes:

  • Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
  • Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.
  • Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, and so on.
  • Performance cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.
  • Advertisement cookies are used to provide visitors with customised advertisements based on the pages visited previously and to analyse the effectiveness of ad campaigns.

The user data collected by technical cookies are not used to create user profiles.

(3) Legal basis for data processing

The legal basis for the processing of personal data using technical cookies is Article 6(1)(f) UK GDPR and EU GDPR, legitimate interests.

(4) Duration of storage and possibility of objection and removal

Cookies are stored on the user’s device and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.

 

7. Contact via email

(1) Description and scope of data processing

You can contact us via the email address provided on our website. In this case your personal data  transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

(2) Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

(3) Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Article 6(1)(f) UK GDPR and EU GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Article 6(1)(b) UK GDPR and EU GDPR.

(4) Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with you has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

(5) Objection and removal

You have the possibility to withdraw consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

8. Sign up option

(1) Description and scope of data processing

The Sign up option allows you to choose a paid subscription or a free 7-day trial subscription. In either case we process limited information to setup and manage the subscription.

When sending the request for a subscription, the following data will also be stored:

  • Full name
  • Email address
  • Password
  • Date and time of contact

As part of the sending process, your consent will be obtained for the processing of your data and reference will be made to this privacy notice.

The data will be used exclusively for the processing of the setting up of a paid or free subscription.

(2) Purpose of data processing

The processing of the personal data from the input mask serves us exclusively for the purpose of establishing the setup of your Paid Subscription.

(3) Legal basis for data processing

The legal basis for the processing of the data is Article 6(1)(a) UK GDPR and EU GDPR if you have given your consent.

If the purpose of the contact is to conclude an agreement, the additional legal basis for the processing is Article 6(1)(b) UK GDPR and EU GDPR.

(4) Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. This includes any Orders placed during your paid subscription.

(5) Objection and removal

You have the possibility to withdraw the consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time.

FocalAgent Ltd
124 City Road
London, EC1V 2NX
United Kingdom
+442035989669
Privacy@focalagent.com

www.focalagent.com

In this case, all personal data stored while processing your paid subscription will be deleted.

 

9. Start Free Trial Subscription

(1) Description and scope of data processing

The Start Free Trial subscription is available on our website, which can be used for electronic contact to setup the Trial Subscription. If you make use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message, the following data will also be stored:

  • Full name
  • Email address
  • Password
  • Date and time of contact

As part of the sending process, your consent will be obtained for the processing of your data and reference will be made to this privacy notice.

The data will be used exclusively for the processing of the Start Free Trial.

(2) Purpose of data processing

The processing of the personal data from the input mask serves us exclusively for the purpose of establishing the setup of your Free 7-day Subscription.

(3) Legal basis for data processing

The legal basis for the processing of the data is Article 6(1)(a) UK GDPR if youhave given your consent.

(4) Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. This includes any Orders placed during the Free 7 day trial period.

(5) Objection and removal

You have the possibility to withdraw your consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time.

FocalAgent Ltd
124 City Road
London, EC1V 2NX
United Kingdom
+442035989669
Privacy@focalagent.com

www.focalagent.com

In this case, all personal data stored while processing your Free 7-day trial subscription will be deleted.

 

10. Processing of personal information for PropertyBox marketing

(1) Scope of processing personal data

We gather the following information from publicly available sources to construct a mailing list:

  • Full Name
  • Email Address
  • Job Title
  • Company Name

(2) Purpose of data processing

We use publicly available contact information to generate marketing lists for business individuals. We use the marketing lists to contact potential customers for PropertyBox.

(3) Legal basis for data processing

We use legitimate interest as our legal basis for the processing of the data in accordance with Article 6(1)(f) UK GDPR and EU GDPR, and due to the fact that marketing for this purpose is aimed at businesses and business individuals.

(4) Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the account setup form and those sent by email, this is the case when the respective conversation with you has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of fourteen days at the latest.

(5) Objection and removal

As a business or business individual, you have the possibility to object to the processing of personal data at any time. In such a case, personal data will be deleted.

 

11. Use of corporate profiles in professionally oriented networks

(1) Scope of data processing

We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

LinkedIn:

LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland

On our site we provide information and offer users the possibility of communication.

The corporate profile is used for job applications, information, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

(2) Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate web profile is legitimate interests, under Article 6(1)(f) UK GDPR and EU GDPR.

(3) Purpose of the data processing

Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

(4) Duration of storage

We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.

(5) Objection and removal

You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under Section IV. of this privacy notice. Please send us an informal email to the email address stated in this privacy notice.

You can find further information on objection and removal options here:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

 

12. Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is: IONOS Cloud Ltd. · Discovery House 154 Southgate Street · Gloucester · GL1 2EX

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

  • Browser type and version
  • Used operating system
  • Referrer URL
  • Hostname of the accessing computer
  • Time and date of the server request
  • IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of legitimate interests under Article 6(1)(f) UK GDPR and EU GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of their website – and server log files are therefore recorded.

The server of the website is geographically located in the United Kingdom.

This privacy notice has been created with the assistance of DataGuard.