PRIVACY POLICY

This privacy notice outlines details of how we collect and process your personal data as both a data controller and processer.

CONTACT DETAILS

Ativa Property Ltd
5 South Charlotte Street, Edinburgh, EH2 4AN
[email protected]

THE DATA WE PROCESS AND WHY

When you communicate with us via any means we will process your data for the purpose of communicating with you and for maintaining our records. We understand that the lawful basis for this is legitimate interest which enables us to respond to you and reasonably manage our business.
For users of our website, digital platforms and other online services, such as our social media accounts we process your data to operate our website/digital platforms and communicate online providing relevant content to the user. We understand that the lawful basis for this is legitimate interest which enables us to operate our website and build our business.
Data collected from your use of our website, digital platforms and online services may include technical information such as; your IP address, how you behave on the website, the devices you use etc. We generate this data from Google Analytics and process it to review and improve our business, website content and ensure our promotional activity is as targeted and relevant as possible. We hold this data on the legitimate interest legal basis as it enables us to manage our website, provide more relevant business services and promote effectively to help build the business.
We may use the above data categories to develop more relevant website content for our users and promote to our target audiences via methods such as online advertising. The lawful basis for this is legitimate interest as it enables us to develop and grow our business ensuring more relevant promotion to our target markets.

EMAIL MARKETING

From time to time, we may process your data to communicate with you via email marketing communications. The lawful basis may be either legitimate interest or consent where you have opted-in to receive information.

As per the Privacy and Electronic Communication Regulations, 2003 (PECR) we may send you communications; if you are a previous client, were in touch with us about our services in the past, or you previously agreed to receive our marketing emails and have not opted-out. We may also send emails to limited companies without your consent on the basis that you may unsubscribe at any time.
We promise we will not share your email data collected for the purposes of our own email marketing with any other third party for the purposes of them marketing to you unless you give us permission to do so.
To unsubscribe from our regular marketing newsletter please hit the unsubscribe button at the bottom of the email, or email [email protected]. Opting out of the marketing newsletter does not apply to personal data provided as a result of other communications, thus allowing other conversations and business to continue.
To amend your preferences on our email marketing communications you receive from us please email [email protected]
Our email marketing system has a tracking facility which provides information such as ‘how many people opened the email’, ‘which links they were most interested in’ etc. This provides us with useful information on the success of our content and how interested our audience is, allowing us to provide improved content in future.

INTERNATIONAL TRANSFER OF YOUR DATA

As some of our third-party service providers are based outside the European Economic Area (EEA) your data may require to be transferred outside of this area in order for us to fulfil some of our services. In this instance, we ensure these providers are providing adequate levels of security or that they are approved by the European Commission. For US-based providers we ensure they are part of the EU-US Privacy Shield which provides similar safeguards to those within the EEA.

WEBSITE

Our website may include third party links. We ensure these links provide relevant, quality information to the reader. However, by clicking on these links a third party may collect or share your data. We do not control or take responsibility for any third-party actions such as these and recommend you refer to their own privacy notice for information on how they will process your data.
Our website uses the Facebook Pixel to collect data on visitor’s behaviour and helps us to improve any Facebook advertising we may implement. We also track visitors use of our website through Google Analytics to better understand how we can improve our customer’s experience. These analytics do not save personal information. For more information on Google’s privacy policy visit: google.com/privacy.html
Cookies – We currently only have one ‘user session’ cookie on our website. This simply logs users going into the site. You can set your browser to refuse or alert you to cookies featured on a website, however by doing so the website may not operate correctly.

USE OF SOCIAL MEDIA PLATFORMS

We communicate and engage with various audiences over a number of social media platforms, often providing information, links to content on our and third-party websites. We recommend you read the privacy policies of each of these platforms and your use and interaction with us over the platforms is at your own discretion and risk. We will never ask you for sensitive information over a social media platform and you have the right not to engage.
We use shortened links on our social media platforms to allow us to track the success of each of the posts/content and this does not link to nor do we collect any personal data as a result. We aim to provide high-value links to third-party information and news sites for our audiences. However, we recommend you use caution and your own judgement, read the third-party privacy notice and cookie policy before engaging as we take no responsibility for the actions of any third-party website we link to and how they may handle, track or collect your data.

SECURITY AND RETENTION OF YOUR DATA

Our data security is under regular review, password access to our systems are regularly renewed, to ensure our processes prevent the accidental loss, misuse or disclosure of your data without our authorisation. We ensure our employees, partners and contractors who may require access to your data handle it under our instructions, confidentially and ensure the upmost security at all times.
If we suspect a breach of our security measures, where your personal data may have been compromised, we will inform the ICO within 72 hrs as per the GPDR guidelines.
We will only hold onto your data for as long as it requires for us to reasonably fulfil the purpose it was collected for.

SHARING YOUR DATA

We may share your data with our trusted third parties, contractors and service providers to fulfil our business services and client requirements. We require, through a User Agreement between us and these third parties and service providers, that they declare they are fully GDPR compliant ensuring your data is protected, only used for specified purposes and in accordance with our instructions.

Our IT and system administration service providers have access to our systems in order to complete routine maintenance and repair works, building of our systems, as per our instructions. These service providers have also declared via a User Agreement between us and them that they are GDPR compliant and operate to the highest levels of data security in executing these services.

REQUESTING ACCESS AND CHANGING PREFERENCES

You have the right to request access to the data we hold, change the preferences, withdraw your consent for use at any time. In this instance please email [email protected] and we will respond within 28 days.

If you have a complaint about the way in which we use your data, you have the right to contact the ICO directly. However, we would ask you allow us the opportunity to try and resolve any issues first.