The protection of your personal data and transparency regarding its use is particularly important to IMMO. This “Privacy Policy” informs you about the processing of your personal data by IMMO and the data protection provisions we have in place, including your rights under applicable law.
1. INTRODUCTION
In the following, we inform you about the processing of personal data when:
- Using our website
- Using further services provided by us
- Engaging us in a real estate transaction
- Engaging with our profiles on social media.
Personal data is all data relating to a specific natural person, including your name or IP address, from which a person’s identity is apparent or can be ascertained.
1.1. Contact information
IMMO Investment Technologies UK Limited and its affiliates and subsidiaries (collectively, “IMMO” or “we”) are data controllers for the personal data we process about you.
Please read this Privacy Policy to make sure you understand how we process your personal data and your rights relating to such processing.
If you have any questions, please contact us at hello@immo.capital.
1.2. Data processing outside the EEA or UK
For the reasons set out in this Privacy Policy, the personal data we collect may be transferred to and stored or otherwise processed by our affiliates, service providers or other third parties outside of the UK, Switzerland and the EEA, including (but not limited to) Canada, Israel, USA and India. We ensure that such transferred personal data is subject to at least the same level of security and protection as is required under the GDPR, whether through adequacy decisions of the EU Commission (Art. 45 Off. 3 GDPR), or standard contractual clauses (“SCCs”), unless we state otherwise. The SCCs are a set of rules adopted by the EU Commission which ensure the security of data transfer, which have been included as part of the contract with the respective third party. Many of the providers we use have agreed to contractual guarantees beyond the standard contractual clauses that further protect the data. These could include guaranteeing encryption of the data or obligations to inform data subjects if law enforcement bodies want to access their data.
1.3. Data security
We have physical, technical and operational measures in place to help protect data we collect and store from any loss, damage or unauthorised access. However, the provision of data via the internet cannot be guaranteed to be completely secure. By using our website and services, you understand and agree that any data you share with us may be read or intercepted by others. If you have any further questions on our security procedures, please contact us at hello@immo.capital.
1.4. Storage period
Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer necessary for its intended purpose, subject to any storage obligations we have as mandated by legislation or regulation. Unless the data is necessary for other, legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and no longer processed. This applies, for example, to data that we need to keep for commercial or tax reasons.
1.5. Disclosure of personal data
We do not share your personal data except as follows:
- To our affiliates and subsidiaries, for the purposes to described in this Privacy Policy. Since members of the IMMO group are located in different jurisdictions around the world, this may include processing outside of the EEA or UK, in accordance with section 1.3 above.
- To our third party service providers, to the extent necessary for them to perform their services for us (see section 3.5 below). Since some of our providers are located in different jurisdictions around the world, this may include processing outside of the EEA or UK, in accordance with section 1.3 above.
- To our professional advisors involved in transactions, to the extent necessary for them to perform their own services.
- To the extent necessary to comply with applicable law or legal process (including requests from regulators or governmental authorities).
- Where you have consented to the disclosure, in accordance with the provisions of this Privacy Policy.
1.6. Rights of data subjects
You have the following rights with regards to your personal data that we process:
- Right to obtain information about how we process you data
- Right of access to the personal data we process about you
- Right to rectification or deletion of the personal data we hold about you
- Right of erasure of the personal information we hold about you
- Right to restriction of processing of your personal data
- Right to object to processing if your personal data
- Right to data portability to another data controller
- Right to revoke your consent to process your data at any time
Data subjects also have the right to complain to a data protection supervisory authority (in the UK, the Information Commissioners Office) about the processing of their personal data.
2. NEWSLETTER
We provide interested parties with the opportunity to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. The legal basis for this processing is consent of the recipients. This consent can be revoked (and recipients can unsubscribe) at any time, e.g. by clicking on the corresponding link in the newsletter or by referring to our e-mail address (hello@immo.capital).
We reserve the right to inform previous customers (those who have already used our services or have purchased goods from us) about our offers and newsletter from time to time by e-mail or by other means, unless they have objected to this. The legal basis for this data processing is our legitimate interest in direct advertising. Customers can unsubscribe or object to the use of their e-mail address for advertising purposes at any time at no additional cost, for example via the link at the end of each e-mail or by e-mail to our above e-mail address.
3. DATA PROCESSING ON OUR WEBSITE
3.1. Collection of personal data
We may collect personal data from you that you provide to us directly, for example through a contact us form or responding to a job advert including:
- First name, last name
- Email address
- Telephone number
- Address, including street, city and postcode
- Other information relevant to your inquiry
We process this data on the basis of the consent you provide to us, along with the legal bases set out below. You can withdraw your consent at any time by emailing us at hello@immo.capital.
3.2. Use of personal data
We may use the personal data collected under section 3.1 to:
- Respond to your enquiry or any other communications from you (the legal basis for this processing is our legitimate interest in providing information to you that you have requested)
- Provide products and services to you (the legal basis for this processing is the performance of any agreement between IMMO and you)
- Inform you about products or services that we believe may be of interest to you (the legal basis for this processing is our legitimate interest in providing information about products and services that may be of interest to you)
- Develop and manage our products and services (the legal basis for this processing is our legitimate interest in understanding our customer base and exploring ways to develop and improve our products and services)
- Detect and prevent fraudulent transactions, breach of contract and other illegal activities, including money laundering (the legal basis for this processing is our legitimate interest in preventing fraud, contractual breach and other illegal activities)
3.3. Informational use of the website
We may also collect personal data from you automatically when you use the website for information purposes, i.e. if site visitors do not directly provide us with information, we may collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. The legal basis for this is our legitimate interest in providing you with a functional website, e.g. with cookies that are necessary for the technical operation of our website (see our Cookies Policy for more information).
This data is:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software
This data is also stored in log files. They will be deleted when their storage is no longer necessary, at the latest after 14 days.
3.4. Web hosting and provision of the website
Our website host are Amazon AWS. The provider is Amazon Web Services, EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxembourg. The provider processes the personal data transmitted via the website in the EU, e.g. content, usage, meta/communication data or contact data. Further information can be found in the provider's privacy policy at Amazon. The legal basis for this is our legitimate interest for providing users with a functioning website.
3.5. Third-party providers
- 3.5.1. Google Places API
We use Google Places API for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes content data (e.g. Inputs in online forms) and meta / communication data (e.g. Device information, IP addresses) in the EU.
The legal basis for this processing is consent of users. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital).
We delete the data if the purpose of its collection has ceased to apply or consent has been revoked. Further information can be found in the provider's privacy policy at Google.
3.5.2 Google Maps
We use Google Maps for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of users. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital).
We delete the data if the purpose of its collection has ceased to apply or consent has been revoked.The legal basis for transfer to a country outside the EEA is consent.We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at Google.
- 3.5.3. ZohoCRM
We use ZohoCRM as a live chat. The provider is Zoho Corporation Pvt. Ltd, 4141 Hacienda Dr, Pleasanton, Ca 94588 USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. Entries in online forms), contact details (e.g. E-mail addresses, telephone numbers) and meta/communication data (e.g. Device information, IP addresses) in the EU.
The legal basis for the processing is a legitimate interest in working together effectively and efficiently, creating and storing required documents. The data will be deleted if the purpose of their collection has ceased to apply, subject to a legal obligation to retain it. Further information can be found in the provider's privacy policy at Zoho.
- 3.5.4. Hotjar
We use Hotjar for analysis. The provider is Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's, STJ 3141, Malta. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the EU.The legal basis for this processing is consent of users. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). We delete the data if the purpose of its collection has ceased to apply or consent has been revoked. Further information can be found in the provider's privacy policy at Hotjar.
3.5.5. YouTube videos
We use YouTube videos for videos on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of users. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). We delete the data if the purpose of its collection has ceased to apply or consent has been revoked. The legal basis for transfer to a country outside the EEA is consent.
Further information can be found in the provider's privacy policy at Google.
- 3.5.6. Facebook Custom Audiences
We use Facebook Custom Audiences for advertising. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.
The legal basis for this processing is consent of users. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at Facebook.
3.5.7. Google Marketing Platform
We use Google Marketing Platform for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at Google.
3.5.8. Google Tag Manager
We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at Google.
1.1.4. Google Conversion Tag
We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information can be found in the provider's privacy policy at Google and Google Support.
3.5.9. Zapier
We use Zapier for automation between applications. The provider is Zapier, Inc., 548 Market St. #62411, San Francisco, CA 94104-5401, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for the processing is our legitimate interest in simply connecting the applications in our company and thus optimising the way we work.
The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at Zapier.
3.5.10. Facebook pixels
We use Facebook Pixel for analysis. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information can be found in the provider's privacy policy at https://www.facebook.com/policy.php.
3.5.11. Facebook Conversion API
We use Facebook Conversion API for analysis. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information can be found in the provider's privacy policy at Facebook.
3.5.12. ActiveCampaign
We use ActiveCampaign for analysis. The provider is ActiveCampaign, LLC, 1 N Dearborn St., 5th Floor, Chicago, Illinois 60602, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. Further information can be found in the provider's privacy policy at ActiveCampaign.
3.5.12. wordpress.com
We use wordpress.com to create websites. The provider is Aut O'Mattic A8C Ireland Ltd., 25 Herbert Pl, Dublin, D02 AY86, Ireland. The provider processes contact data (e.g. E-mail addresses, telephone numbers), meta/communication data (e.g. Device information, IP addresses) and master data (e.g. names, addresses) in the USA.
The legal basis for the processing is our legitimate interest in setting up and maintaining a website for our users.The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
We delete the data if the purpose of its collection has ceased to apply. The data will be deleted if the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information can be found in the provider's privacy policy at Automattic.
3.5.13 Mailchimp
We use Mailchimp for email marketing and email management. The provider is Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), contact data (e.g. E-mail addresses, telephone numbers), meta/communication data (e.g. Device information, IP addresses) and master data (e.g. names, addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of its collection has ceased to apply and there are no storage obligations to the contrary. Further information can be found in the provider's privacy policy at Mailchimp.
3.5.14. Google Analytics
We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information can be found in the provider's privacy policy at Google.
3.5.15. Google Webfonts
We use Google Webfonts for fonts on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. Device information, IP addresses) in the USA.
The legal basis for this processing is consent of the user. Affected persons can revoke their consent at any time by contacting us, for example, by email (hello@immo.capital). The legal basis for transfer to a country outside the EEA are SCCs, which we have agreed with the provider.
The data will be deleted if the purpose of its collection has ceased to apply and there are no storage obligations to the contrary. Further information can be found in the provider's privacy policy at Google.
4. DATA PROCESSING IN THE CONTEXT OF OTHER SERVICES
4.1. Prospective Residents
When renting apartments, we process the following data to assess whether we can enter into a contract with the tenant:
- First name, last name
- If applicable, maiden name
- Current address including street, city and postcode
- Telephone number
- Email address
- Name and age of other persons involved in the transaction
- Date of birth
- Profession practiced
- Monthly Net income
- Current employer and length of time with that employer
- Maximum monthly available amount for housing rent
- Intended uses of property
- Rental history of resident
- Whether a legally binding eviction order has been issued against the prospective resident in the last five years
- Whether enforcement measures have been initiated in the last five years due to claims from tenancy relationships
- Whether insolvency proceedings have been opened against the prospective resident in the last five years
Processing is necessary for the preparation of the tenancy agreement and is carried out with the prospective resident’s consent.
The consent can be revoked at any time with effect for the future, e.g. by post or e-mail (hello@immo.capital). The processing until the time of revocation remains lawful.
If a rental contract is not concluded, the documents will be destroyed, subject to any storage obligations we have as mandated by legislation or regulation. If prospective resident consents, we will pass on the personal data listed above to third parties commissioned by the landlord for the purpose of preparing the contract and to previous residents for the coordination and coordination of viewing appointments.
4.2. Social media platforms
We use social media networks to present our company and our services there. The operators of these networks regularly process data of their users for advertising purposes. Among other things, they create user profiles from their online behaviour, which may be used, for example, to show advertising that corresponds to the interests of users. For this purpose, the operators of the networks store information about the usage behaviour in cookies on the user's computer. Please note that these websites have their own privacy policies and IMMO does not accept any responsibility or liability for these policies. Users can obtain further information as well as information on how users can object to the processing from the relevant site operators.
When users of the networks contact us via our profiles, we process the data provided to us in order to answer the inquiries – a legitimate interest justification for this processing.
In individual cases, we may pass on your personal data to banks in order to carry out compliance checks. This processing only takes place if you have given your express consent, so that the legal basis is Art. 6 (1) a) GDPR. Consent can be revoked at any time with effect for the future.
5. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy. A current version is available here.
6. QUESTIONS AND COMMENTS
For questions or comments regarding this privacy policy, please do not hesitate to contact us at hello@immo.capital.
