On imperialresorthurghada.com website we take your privacy very seriously and we take great steps to ensure that all measures are taken to protect your information and closely monitor how it is used. We have compiled a privacy notice to explain how we look after your personal data when you visit our website and we also explain the steps we take to adhere to the law which protects your privacy rights
Whether your interaction with us is by phone, email or via signing up and submitting to request further information on our website, the information which follows with explain how we collect and process your personal data.
WHO WE ARE
Imperial Living is the controller and responsible for your personal data. Therefore we have appointed a Data Protection Manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
* Legal name: Go Investment
* Name of DPM: Secretary
* Email address: firstname.lastname@example.org
* Postal address: 114a Bellegrove Road, Welling, London, United Kingdom, DA16 3QR
* Telephone number: +44 207 859 4280
* Company number: 07283457
If at any time you feel your data is at risk you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 30/10/2019.
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.
We never send information to you via postal services, all our interaction is via email or by phone (which is normally on request and never by cold call).
For all web users we do not collect any personal data apart from your contact number, name and email address and this is not shared with third parties.
For anyone who proceeds to purchase a property via us then we will take further details with your consent, this is in order to prepare contracts and it is not kept by us on record after the contract has been signed. This information is not passed on to third parties, apart from the developer of the property you are purchasing and this is shared only by your consent (via a reservation form).
Once this is passed on to the developer, they will be responsible for how they control the data received and adhering to the applicable laws.
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
* Identity Data includes first name, surname, title, date of birth and nationality (birth and nationality will be required on reservation forms only) and passport copies.
* Contact Data includes postal address, email address and telephone numbers. (Postal addresses are not kept on file for any users and are only for reservation purposes).
* Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
* Usage Data includes information about how you use our website.
* Marketing and Communications Data includes your preferences in receiving marketing from us and we only contact you via email in response to your request for information.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your 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 convictions and offences.
We use different methods to collect data from and about you including through:
* Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
* Download a brochure & contact forms
* Contact via social media
* subscribe to our special offers or newsletter
* request marketing to be sent to you;
* Submit your interest via a property portal or advertising portal we are advertising with
* give us some feedback.
* Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
* Technical Data from the following parties:
* analytics providers such as Google based inside OR outside the EU;
* Social media platforms such as Facebook and twitter
* Instant messenger services such as Zopim
* advertising networks such as Google and Bing, based inside OR outside the EU; and
* search information providers such as Google based inside or outside the EU.
* Identity and Contact Data from third parties who introduce you to us, and in this respect we only deal with third parties who confirm to us that they are providing us with this information for a legitimate purpose (for instance where you request them to do so, or seek information about us or our services from that third party).
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:
* Where we need to perform the contract we are about to enter into or have entered into with you and/or to provide you with anything which you have requested.
* Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw your consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will only use your data for legitimate purposes and we will adhere to legal regulations when doing so.
* When you purchase a property via us we will send you a reservation form which will collect your contact data and identity data (as mentioned above), this is solely for the purposes of drafting the contractual agreement, this agreement will be written by the developer who is a third party and they will be the only other agency who will see this information. By completing a reservation form for the purpose of purchasing a property you are consenting for them to be able to receive this data in order to draw up this contractual agreement between you as the buyer and them as the seller.
* We never take any payment information from you, payments you make will only ever be via bank transfer and this does not require us to collect your bank details or bank billing information.
* We will contact you in order to manage our relationship with you, this will include notifying you of our private policy updates and terms, keeping you updated with the build updates of your property, confirming payments have been received or payment reminders from the developers and any relevant information we think will be informative for you to receive regarding the property you have purchased and the resort it is on.
The above contact will only be made for purchasers and not website users, for website users and purchasers the following will apply if you have opted to receive further information from us.
* We will deliver information we feel will feel relevant to you necessary for our legitimate interests to develop our products and services and grow our business, this will include advertisements and introductions to properties we feel may be of interest to you. You are able to opt out of any of this information being sent to you at any time, there will be an unsubscribe action available on all advertising emails. Once you opt out of receiving these emails then you will no longer be contacted in relation to this
We will also use data analytics to improve our website, products/services, marketing, customer relationships and experiences for our legitimate interests to keep our website updated and develop our business and marketing strategy.
We strive to provide you with choices regarding certain personal data usage, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will never share your data to a third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of any of our services or transactions with us.
DISCLOSURE OF YOUR PERSONAL DATA
We will never share your personal data with any third parties for marketing purposes, we will only disclose information when the law requires it in performance of criminal investigations or for a legitimate legal purpose.
If you purchase your data will only be shared within our legal company Imperial Living and the developer of your chosen property and all their contact details and information will be provided to you via the contract. You will consent to them receiving your information for the purpose of carrying out the legal contract when you reserve the property.
Information relating to users and the data collected from them will not be disclosed to third parties for any reason.
DATA SECURITY AND RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
For buyers, the only data we keep on file for you is your name and contact information, we do not keep any other information on file for you after you have submitted the reservation form. It is passed to the relevant developer and once the contract has been drawn up we delete your reservation details and they are not kept on file or record by Imperial Living. The hard copy of the signed original contract will only be handled by you and the developers directly and will not come via Imperial Living, to protect from any mishandling and to keep the details contained private and secure.
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 retain your contact details during the build time in order to keep you updated about your property but if you wish to opt out this is possible at any time.
Once the property is completed on the contract date, we no longer contact you to update you on anything unless required to do so.
The only reason we will contact you is if you opt to receive further details on new investments.
How long will you use my personal data for?
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 requirements. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
* Request access to your personal data.
* Request correction of your personal data.
* Request erasure of your personal data.
* Object to processing of your personal data.
* Request restriction of processing your personal data.
* Request transfer of your personal data.
* Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.