This privacy policy explains what personal information companies in the Dandara Group (or “we”) will collect from you and how we will use that personal information. We are committed to being transparent with you regarding our use of your personal information and we encourage you to contact us at dpo@dandara.com if you have any questions. The Dandara Group holds registrations with the IOM Information Commissioner, the Information Commissioner’s Office in the UK and the Office of the Information Commissioner in Jersey and the details of the registrations can be found here
Contents of this privacy notice
Who controls your personal data?
What personal data will we obtain from you, and how and when will we request it?
Why do we obtain your personal data?
Who will we share your personal data with?
How do we ensure the security of your personal data?
Access to, and amending, your personal data
Amendments to this policy
Comments and questions
1. Who controls your data?
Dandara Group is the “controller”. This means that Dandara Group will obtain and process your personal data in line with GDPR/Data Protection legislation in force in the jurisdictions in which it operates.
2. What personal data will we obtain from you, and how and when will we obtain it?
We may obtain information from you when you register on our website, contact us by phone or text, or when you visit our offices or developments. The data we obtain will include some or all of the following:
your full name;
your date of birth (if there is an age qualification related to a development);
your address, postcode and country of residence; and
your contact details (email address and telephone number(s)).
You will be asked to provide the above information if you wish to enquire about or purchase a property from us. Some of our offices and developments are monitored by CCTV. If you visit a Dandara website we may monitor the type of device you use, operating system and approximate location. If you contact us, we may keep a record of that correspondence or may record calls from you and to you. If applicable, in order to meet our legal requirements if purchasing, or potentially purchasing, a property from us, we may also collect and process the following additional personal data about you:
an internationally recognised photo ID (passport, driving licence), a utility bill, proof of identity, residence and/or age, and/or a bank or credit card statement relating to your payment details that are registered with us;
information that you submit in response to a survey(s) or poll;
We may also ask for details of your mortgage arrangements or other financial arrangements to purchase your property.
We reserve the right to conduct credit checks with third party credit and financial institutions in order to confirm any information that you have provided to us.
3. Why do we obtain your personal information?
3.1 We will obtain and process your personal data in order to:
3.1.1 provide you with information regarding our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes:
3.1.2 progress any property reservation and conveyance that may result from enquiries or contact;
3.1.3 provide customer support services including property maintenance and remedial works post legal completion;
3.1.4 comply with our regulatory and legal obligations, including our ‘know your customer’ (KYC) and due diligence requirements;
3.1.5 reporting of crime or suspected crime, including money laundering or fraud.
4. What will we do with your personal data?
Disclosure to third parties
4.1 We will not disclose any personal information that you provide to us to third parties unless: (i) we have your consent; (ii) it is required or permitted by law, (iii) your agreement with us permits such disclosure; or (iv) it is in our legitimate interests to do so. This is explained more fully in clause 4.2 below.
In accordance with this Privacy Policy and data protection law, you understand and agree that we may disclose your personal information for the following purposes to the following third parties:
4.2.1 third parties, for the purposes of verifying information that you provide to us.
4.2.2 to any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
4.2.3 to any prospective seller or buyer of a company within the Dandara Group, or our business or assets (or part of them) in respect of the sale;
4.2.4 to a third party, if we are under a duty to disclose or share your personal data with them in order to comply with any legal obligation, or to protect the rights, property, reputation, security or safety of any company in the Dandara Group, our customers or others; this includes (but is not limited to) exchanging information with or providing information to third parties for the purposes of fraud protection and credit risk reduction;
4.2.5 to any law enforcement or revenue authorities (when requested by them to do so) and only to the extent necessary to adequately deal with the requests made;
4.2.6 to your bank or card scheme operator in order to verify the Card information or bank information that you provide to us and/or to recover payments made to you in error;
4.2.7 to any payment collection agency that we may decide to use in order to recover monies you owe to us; or
4.2.8 to any body or regulator to whom we have a duty to disclose such information.
4.2.9 To persons or organisations who work on our behalf to provide a product or service to you, but such persons or organisations may only use the information to provide the product or service and not for any other purpose.
4.3 We may also use your email address or your postal address to send you updates or news regarding the Company or the services we provide, but you can choose to stop receiving emails or post of this nature at any time by contacting our sales and marketing teams or the Data Protection Officer using the details in clause 6.2 below.
4.4 We do not sell or trade any of your personal information to third parties.
Transferring your personal data to other countries
4.5 In order to provide our services effectively, we may need to transfer data, including personal information, to other companies outside the Isle of Man, Channel Islands, UK or outside the European Economic Area (EEA).
4.6 If we determine that it is necessary to transfer personal data in accordance with clause 4.5, we will only make such a transfer if we are satisfied that the recipient companies offer an adequate level of protection for personal data.
4.7 You agree that we may transfer personal information we hold about you to any country (including countries outside the European Economic Area) in accordance with this Privacy Policy.
Data retention
4.9 Data collected which does not progress to the sale of a property or lease will be retained for up to three years after the last contact we have with you.
4.10 Data related to the sale of a property or lease will be retained for up to 13 years following legal completion of the matter, unless we are required to retain it for a different period pursuant to our legal obligations.
5. How do we ensure the security of your personal data?
5.1 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
5.2 The Group will strive to invest in adequate security technologies and maintain strict information security policies designed to prevent unauthorised access to personal data by anyone, including the Group’s own staff. The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All staff are responsible for ensuring that any personal data which they hold is kept securely, and that personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party. Staff having permitted access to personal data are specifically required to comply with the Group’s Information Security Policies.
6. Access to and amending and deleting your personal data
6.1 At any time, you can make a request to us to have access to the personal information that we hold about you. We may need you to provide identification in order to process your information request.
6.2 It is your responsibility to tell us when information that you have provided to us is out of date or needs to be amended, but we confirm that will update or delete your personal data accordingly.
6.3 You have the right to ask for the deletion of your personal data from our records (the ‘right to be forgotten’) unless it is necessary for us to perform our legal obligations or contractual obligations to you or another third party.
6.4 If you wish to be deleted from or ensure that details held are correct with and third party owned platform, such as a property portal you will need to contact them directly.
6.5 For requests relating to access, amendments and deletion of data please contact our Data Protection Officer at dpo@dandara.com
7. Changes to this privacy policy
If we change any of the terms of this Privacy Policy in the future, the amended policy will be available on our websites.
8. Comments and questions
If you have any comments or questions, regarding this Privacy Policy, please contact the Data Protection Officer using the details in clause 6.2 above.
Dandara Group has the following registrations:
Isle of Man Information Commissioner:
Dandara Homes Limited N000697
Dandara Limited N000740
Allied Services Limited N000695
Dandara Jersey Limited N000696
Office of the Information Commissioner in Jersey
Dandara Jersey Limited 16080
Information Commissioner’s Office in UK
Dandara Limited Z7509889
Image Property Investments (UK) Limited Z2874214Updated May 18th 2018
Policy summary
Personal Data collected for the following purposes and using the following services:
Advertising
Google AdSense and Facebook Lookalike Audience
Personal Data: Cookies; Usage Data
Facebook Audience Network
Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
Analytics
Google Analytics, Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking, HubSpot Analytics and Hotjar Form Analysis & Conversion Funnels
Personal Data: Cookies; Usage Data
LinkedIn conversion tracking (LinkedIn Insight Tag)
Personal Data: Cookies; device information; Usage Data
Contacting the User
Contact form
Personal Data: address; email address; first name; last name; phone numberMailing List or Newsletter
Personal Data: email address; first name; last name; phone numberPhone contact
Personal Data: phone numberContent commenting
Facebook Comments
Personal Data: Cookies; Usage DataData transfer outside the EU
Data transfer to countries that guarantee European standards
Personal Data: various types of DataDisplaying content from external platforms
Google Maps widget and YouTube video widget
Personal Data: Cookies; Usage Data
Google Fonts
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the serviceGeolocation
Geolocation
Personal Data: geographic position
Heat mapping and session recording
Hotjar Heat Maps & Recordings
Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service
Interaction with external social networks and platforms
Pinterest “Pin it” button and social widgets
Personal Data: Cookies; Usage DataInteraction with online survey platforms
Hotjar Poll & Survey widgets
Personal Data: Cookies; Usage Data; various types of DataManaging contacts and sending messages
Campaign Monitor
Personal Data: email addressMailchimp
Personal Data: email address; first name; gender; last name; phone number; Usage DataRemarketing and behavioral targeting
Google Ads Remarketing, Facebook Remarketing and LinkedIn Website Retargeting
Personal Data: Cookies; Usage DataFacebook Custom Audience
Personal Data: Cookies; email addressTag Management
Google Tag Manager
Personal Data: Usage DataContact information
Owner and Data Controller
Data Protection Officer (DPO), Dandara Group, Isle of Man Business Park Cooil Road Braddan Isle of Man IM2 2SAFull policy
Owner and Data Controller
Data Protection Officer (DPO), Dandara Group, Isle of Man Business Park Cooil Road Braddan Isle of Man IM2 2SATypes of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; geographic position; first name; last name; phone number; address; email address; various types of Data; gender; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Geolocation, Contacting the User, Heat mapping and session recording, Interaction with online survey platforms, Advertising, Displaying content from external platforms, Managing contacts and sending messages, Tag Management, Interaction with external social networks and platforms, Remarketing and behavioural targeting, Data transfer outside the EU and Content commenting. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:Advertising
Google AdSense (Google Inc.)
Facebook Audience Network (Facebook, Inc.)
Facebook Lookalike Audience (Facebook Ireland Ltd)
Analytics
Google Analytics (Google Inc.)
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Google Ads conversion tracking (Google Inc.)
HubSpot Analytics (HubSpot, Inc.)
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Contacting the User
Contact form (This Website)
Mailing List or Newsletter (This Website)
Phone contact (this Website)
Content commenting
Facebook Comments (Facebook Ireland Ltd)
Data transfer outside the EU
Data transfer to countries that guarantee European standards (this Website)
Displaying content from external platforms
Google Maps widget (Google Inc.)
Google Fonts (Google Inc.)
YouTube video widget (Google Inc.)
Geolocation
Geolocation (This Website)
Heat mapping and session recording
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Interaction with external social networks and platforms
Pinterest “Pin it” button and social widgets (Pinterest)
Interaction with online survey platforms
Hotjar Poll & Survey widgets (Hotjar Ltd.)
Managing contacts and sending messages
Campaign Monitor (Freshview Pty Ltd.)
Mailchimp (The Rocket Science Group, LLC.)
Remarketing and behavioral targeting
Google Ads Remarketing (Google Inc.)
Facebook Remarketing
Facebook Custom Audience (Facebook, Inc.)
LinkedIn Website Retargeting (LinkedIn Corporation)
Tag Management
Google Tag Manager (Google LLC)
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.In particular, Users have the right to do the following:Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.Data Subject
The natural person to whom the Personal Data refers.Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.Cookies
Small piece of data stored in the User's device.Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).This privacy policy relates solely to this Website, if not stated otherwise within this document.