Privacy Policy
Your privacy is important to us.
Hills Properties Ltd needs to collect and use certain personal data in order to be able to provide a service to our clients and acts as the data controller in this respect. We are committed to ensuring that the procedures and practices we employ in respect of the processing of such data are in compliance with the Data Protection Act 2004 ("DPA") and the EU General Data Protection Regulation (Regulation [EU] 2016/679) ("GDPR"). This Privacy Policy sets out the basis upon which we process such personal data and is effective as of 23 May 2018.
Hills Properties has nominated Brian Hill as data protection and compliance representative and you may contact him by email brian@hills-properties.com or telephone +350 200 50605.
PERSONAL DATA WE COLLECT
We may ask for personal information such as your: name; email; telephone number; home or mailing address; property details. This data is considered "personal" as it could reasonably allow an individual to be identified.
We collect such data by fair and lawful means with your knowledge and consent. We do not disclose your data to third parties unless authorised to do so, examples of which include but are not limited to: you instructing us to publicly market a property for sale or to let; sharing information with authorised auditors or accountants where we are managing one of your properties, and; sharing information with lawyers when you are purchasing or selling a property with us.
Any data gathered via email from this website will be kept strictly confidential and will not be sold or shared with any other party.
This site does not collect or save any personal information about any visitor without their consent and will not send any unsolicited information (spam) to anyone. We log statistical information about browsers, operating systems, and referring websites for security purposes and to further improve the website. None of this information is distributed to any third parties. We do not use 'cookies'.
We may receive personal data about you from various third parties such as contact and service requirement information from: gibproperty.gi based inside the EU; propertygibraltar.com based inside the EU; Twitter based outside the EU; Facebook based outside the EU.
HOW WE USE YOUR DATA
Any data we collect and process is limited to that which is relevant to the instructions that we receive from you and is determined by the specific purpose(s) of your business relationship with us. Such purposes include but are not limited to: sell a property; let a property; purchase or rent a property.
Personal data such as name, address, email, telephone number etc is used for communication with you and is included in legal contracts if appropriate or necessary. We make you aware of the uses of the information you provide and you are free to refuse our request for this information with the understanding that we may be unable to provide you with some of your desired services without it.
We may use your personal data to contact you with updates about our website and services, along with promotional content that we believe may be of interest to you. If you wish to opt out of receiving promotional content, you can follow the "unsubscribe" instructions provided alongside any promotional correspondence you receive from us.
We may process your personal data for a different purpose and without your consent where it is necessary for us to comply with our legal obligations. We do not otherwise share or supply personal information to third parties. We do not sell or rent your personal information to marketers or third parties.
OUR LEGAL BASIS FOR COLLECTING THIS DATA
We will use this data to carry out our obligations arising from any contracts entered into between you and us, whether verbally or in writing. On the basis of legitimate interest we will use this data to provide you with: the information, products and services that you request from us; information about other products and services we offer that are similar to those that you have already purchased or enquired about; information about goods or services we feel may interest you.
CONSENT
When you enter into a relationship with Hills Properties Ltd for us to provide you with our services, your implied consent is given for us to use your data in order to fulfill your request for these services.
If you no longer wish for us to provide you with our services or you no longer wish to receive communications from us you may withdraw consent at any time by contacting us via email brian@hills-properties.com or telephone +350 200 50605.
SPECIAL CATEGORIES OF PERSONAL DATA
We do not collect any of the following list of 'special categories' of data, as classified by the GDPR: racial; ethnic origin; political opinions; religious beliefs; philosophical beliefs; trade union membership; generic data; biometric data; health data; data concerning a natural person's sex life; sexual orientation.
DATA PROCESSING AND STORAGE
Any data we collect is stored securely and protected by physical security measures such as cabinets and locks and by technological security measures such as usernames and passwords which only our employees may access. All computer screens in Hills Properties Ltd's 219 Main Street Gibraltar premises automatically lock when left unattended.
In circumstances where we are required to transfer your data to a destination outside the EEA we will ensure that the data transfer will be conducted in accordance with the GDPR and we will treat the data securely and protect the transferred data in accordance with this Privacy Policy.
ACCURACY AND RETENTION
We take reasonable measures including regular reviews of personal data held to ensure that the data we hold is accurate and up to date and is kept only for as long as is necessary. As soon as the purpose(s) for which we obtained any personal data has been completed such data is deleted unless there is some special reason for keeping it.
Please keep us informed if your personal data changes during your business relationship with us by emailing us at brian@hills-properties.com or calling us on +350 200 50605.
We are committed to operating our business in a transparent and open manner consistent with our legal and regulatory obligations. In accordance with the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations under the Proceeds of Crime Act (2015) (POCA), we are required to obtain evidence pertaining to our client's/applicant's identity and, where appropriate, obtain proof of ownership of property and source/destination of funds prior to entering into a business relationship.
In compliance with the prevailing laws (anti money laundering, proceeds of crime and tax etc.), we are obligated to hold any personal data pertaining to financial transactions for 6 years after the completion of the transactions. After this period, personal data relating to inactive clients will be deleted.
YOUR RIGHTS AND RESPONSIBILITIES
You, the data subject, have rights regarding your personal information which include the right to:
- be informed about how your data is collected and used
- know what data we collect about you and how it is processed
- update any personal information about you
- request this information be deleted
- restrict or object to our use of your data while retaining the right to use your personal information for your own purposes
- opt out of data about you being used in decisions based solely on automated processing
You may exercise any of these rights by contacting us via email brian@hills-properties.com or telephone +350 200 50605. We may charge a reasonable fee to cover our administrative costs.
In the event that you wish to make a complaint about how your personal data is being processed by Hills Properties Ltd or how your complaint has been handled you have the right to lodge a complaint directly with the Gibraltar Regulatory Authority, 2nd floor, Eurotowers 4, 1 Europort Road. Telephone +350 200 74636, email info@gra.gi
LIMITS OF OUR POLICY
This Privacy Policy only covers Hills Properties Ltd's collecting and handling of personal data.
Our website or emails may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before submitting any personal data to these websites.
CHANGES TO OUR POLICY
Any changes to our Privacy Policy will be posted on this page.