Our contact details
Name: Sublime Property Investments
Phone Number: 02036339175
The type of personal information we collect
Personal information/data means any information capable of identifying any living individual or natural person. From the data you share on this website we may process the following information:
Customer Data this includes data relating to any purchases of goods/services including but not limited to your name, title, billing/delivery address, email address, phone number, contact details, purchase details and your card details.
We endeavour to collect and use your personal information only with your knowledge and consent and typically when you purchase goods, use our services, make customer enquiries, register for information or other services, request product information, or when you respond to communications from us (such as questionnaires or surveys).
If you choose to provide us with personal information, it will be used in support of the intended purposes stated at the time at which it was collected, and subject to any preferences indicated by you.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.
We process this data to operate our website effectively and ensure relevant content is provided to you. Like all companies to ensure the security of our website we maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business.
Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Communication Data this includes but is not limited to any communication that you send to us through our website, through email, text, social media messaging, social media posting, online chats or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims.
Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Technical Data this includes but is not limited to data about your use of our website and online services such as your IP address, any login data, information regarding your choice of browser, length of visits to webpages, your journey through our website, how often you revisit the site time zone settings and other technology on the devices you use to access our website.
The source of this data is from our analytics tracking system, we process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our marketing.
Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly maintain our website and help our business and to grow and define a marketing strategy.
Marketing Data this includes but is not limited to data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this marketing.
Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display marketing on platforms including but not limited to YouTube, Instagram, Twitter, Google ads display) and to measure or understand the effectiveness of the marketing you see.
Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Collection of Sensitive Data
We do not collect any Sensitive Data about you. Under the GDPR (General Data Protection Regulation) sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, we have no need to collect this data so don’t.
How we get the personal information and why we have it
We will also receive data about you from third party companies such as Google where we access their analytics platform, and Facebook where we use their display network, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Under the GDPR, the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting email@example.com
(b) We have a contractual obligation.
(c) Legitimate interests
We may have to share your personal data with the parties set out below:
- Other companies in our group who provide services to us.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the GDPR and other Laws. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions and we will always have a legitimate reason for doing so.
When we engage with marketing activity our lawful ground of processing your personal data to engage with you using marketing communications is either your consent or our legitimate interests (specifically to grow our business).
Under PECR we may send you information about our business if:
- you made a purchase or asked for information from us about our goods or services or;
- you agreed to receive marketing communications and, in each case, you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by selecting the unsubscribe option that will be on all marketing communication going forward. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
Third party links
Our website sometimes includes links to third-party websites, plug-ins and applications. By clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, therefore we encourage you to read the privacy notice of every website you visit.
How we store your personal information
Your information is securely stored on our CRM system provided by HubSpot. More information can be found on their website here: https://legal.hubspot.com/privacy-policy
International transfers of your data
Unfortunately, countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal information, so the GDPR and other European Laws prohibit the transfer of personal data outside of the EEA unless the transfer meets certain criteria. Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Sometimes we need to transfer your data outside of the EEA, when we do, we do our best to ensure a similar degree of security of data by ensuring a minimum of one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data (there is a full list on the ICO website that you can look at) by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place. (Note Safe Harbour is invalid and we will never trust a company with this certificate)
Throughout our business we have put in place significant security measures to prevent your personal data from being breached. This includes your data being lost, used, altered, disclosed, or accessed without authorisation.
We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential and all employees will have signed a non-disclosure agreement to this effect.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
The data we collect from you will be retained only for as long as necessary to fulfil the purposes we collected it for. This will naturally include the purposes of satisfying any legal, accounting, or reporting requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
After the retention period has lapsed, we will then dispose of your information by deleting all your personal information held on the CRM system we use.
Your data protection rights
Under data protection law, you have rights including:
Your right of access– You have the right to ask us for copies of your personal information.
Your right to rectification– You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure– You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing– You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing– You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at firstname.lastname@example.org if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk