Rose Alexander Property Limited (registered company number 11768424) (“we” or “us”) is committed to protecting and respecting your privacy.
This policy lets you know what personal information we collect about you, how we collect it, what we use it for and on what basis. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This policy explains how we do this and tells you about your privacy rights and how the law protects you. In addition, you have the right to know what information we hold about you and to have a copy of it, and you can ask us to change or sometimes delete it.
Please read this policy carefully as it applies to the products and services we provide you.
This policy comes into effect on 01 January 2020. If you have any questions about these changes, please contact us using the contact information provided in this policy.
What kinds of Personal Information do we collect about you?
We may collect and process the following data about you:
|Type of Information||Description|
|Contact details and other information to confirm your identity||Your name, address, email address, phone number, date of birth, log-in information and password (we never see your password as it is encrypted)|
|Nationality and National identifier||Your nationality and an identifying number or code given to you by a government i.e. your National Insurance Number|
|Financial information||Details about financial transactions from your account to us, and your bank account and card details in order to process payments to you|
|Transactions||Details about the properties you have invested in via our platform|
|Communications||Your communications with us, including emails, phone calls and webchats|
|‘KYC’ information||Details about you collected by us to identify and verify the identity of our customers, including a copy of your passport or identity card and a utility bill noting your home address|
|Anti money laundering verification||As a result of money laundering regulations, we may need to verify the source of the funds which you are investing on our platform. We may therefore collect from you any of the following as evidence – a copy of your bank statement / savings account statement, payslip or completion statement from a house sale, for example|
|Technical information||The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform|
|Behaviour||Details about how you use our website and services, including information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page|
|Consents||Any permissions, consents or preferences that you give us, including communications that you would like to receive from us and how you would like us to contact you|
How do we collect your information?
We may collect personal information:
- Via our website;
- Via livechat;
- Via the internet;
- Via customer surveys;
- Via face to face meetings with members of the team;
- By email and letters; and
- By phone.
We may also collect personal information from third parties we work with:
- Our ‘KYC’ service provider;
- Our payment service provider;
- Credit reference agencies;
- Financial advisers; and
- Companies that introduce you to us.
How do we use your information and for what purposes?
We are only allowed to use your personal information if we have a lawful reason for doing so. We will use your information if we can satisfy that processing it is necessary:
- to provide our product and/or services to you;
- in order for use to comply with a legal or regulatory obligation;
- when it is in our ‘legitimate interests’ (i.e. we have a business or commercial interest to use your information as long as it does not overly prejudice you); and/or
- when you consent to it.
We use information held about you in the following ways:
|What we use your information for||Our basis for using your information|
|To manage our relationship with you:To carry out marketing activitiesTo understand how our customers use our website and servicesTo provide guidance on our website and services||Provision of our product and servicesYour consentCompliance with legal and regulatory obligationsOur legitimate interests – developing products and services; keeping records and contact details up to date; determining which of our services may interest you|
|To deliver our product and services to you:To report transaction activity to youTo help you manage your portfolioTo manage and provide investments and servicesTo adhere to our obligations set out in agreements or contracts||Provision of our product and servicesCompliance with legal and regulatory obligationsOur legitimate interests – being efficient with how we fulfil our legal and contractual obligations|
|To develop our products and services:To test new products and/or services or iterations of existing products and/or servicesTo administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposesTo manage how we work with third parties that provide services to us||Provision of our product and servicesCompliance with legal and regulatory obligationsOur legitimate interests – developing products and/or services; being efficient with how we fulfil our legal and contractual obligations|
|To detect, investigate and report financial crime:To comply with laws and regulationsTo manage riskTo monitor and prevent fraudTo verify a customer’s identityTo respond to and resolve complaints||Compliance with legal and regulatory obligationsOur legitimate interests – develop and improve how we deal with financial crime; being efficient with how we fulfil our legal and regulatory obligations|
|To run our business efficiently and in compliance with applicable regulatory standards:Corporate governanceFinancial and regulatory auditsRegulatory reporting and filingsBusiness, financial and strategic planning||Compliance with legal and regulatory obligationsOur legitimate interests – develop and improve our business operations; being efficient with how we fulfil our legal and regulatory obligations|
Who do we share your information with?
We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) and with other teams / departments within Rose Alexander Property, including Finance & Compliance, Customer Services, Analytics, Marketing and Technology for the purposes described in this policy.
We may share your information with the following third parties:
- The Financial Conduct Authority (FCA), and other regulators and authorities
- Financial Services Compensation Scheme (FSCS)
- HM Revenue & Customs (HMRC)
- Credit reference agencies
- Fraud prevention agencies
- Third parties that we engage with to help us operate, improve, integrate, market and customise our product and/or services
- RAP’s payment service provider
- RAP’s KYC service provider
- IT providers / hosted IT solution providers
- RAP’s auditors
If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us and with controls in place in order to protect your information.
We do not sell your data to any third parties.
What marketing activities do we carry out?
We may use your personal information to provide you with information about products or services that may be of interest to you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. This is where we have a business or commercial reason to use your information as long as it does not overly prejudice you.
You can ask us to stop sending you marketing messages by contacting us at any time, clicking on the ‘unsubscribe’ link that appears in all our emails or by updating your preferences in ‘Settings’.
Irrespective of your contact preferences, you will still receive transaction statements from us, and other important information such as introductory communications following sign up to our platform or any changes to existing products or services.
How long do we keep your personal information for?
We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this policy and in order to comply with our legal and regulatory obligations.
Where do we store your personal information?
We use data hosting service providers located in Ireland (Amazon Web Services (AWS) and Salesforce) to host the information we collect, and we implement technical safeguards to protect your information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. For example, if you access the internet via an unsecure network. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password and PIN which enables you to access certain parts of our website, you are responsible for keeping this password and PIN confidential. We ask you not to share either with anyone.
Do we transfer personal data outside of the European Economic Area (EEA)?
We will only send your information outside of the EEA to:
- Comply with our legal and regulatory obligations; or
- Work with agents, contractors or advisers who we use to help run our product and/or services.
If we do transfer information to our agents, contractors or advisers outside of the EEA, we will put appropriate safeguards in place to ensure that such information is protected in the same way as if it was being used in the EEA.
What are your rights?
Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in this policy.
In certain cases, we may not be able to comply with your request for reasons such as our obligations to comply with any legal or regulatory requirements. In the event that we cannot comply with your request, we will also respond to you and tell you why.
Your rights include:
1. The right to access your personal information:
You are entitled to a copy of the personal information we hold about you and certain details of how we use it.
Your information will be provided to you electronically, unless otherwise requested.
We will respond to your request within a reasonable period of time, but at the latest within one month of the request (assuming we have any requisite information from you in order to be able to process your request).
2. The right to rectification:
You have the right to have your information rectified if it is inaccurate or incomplete. We aim to ensure that your personal information is accurate, however, please do contact us if you require your information to be updated or amended or, alternatively, you can amend your personal details in ‘Settings’.
3. The right to erasure:
You have the right to request the deletion or removal of your information. There are, however, specific circumstances where we may be unable to deal with your request, e.g. if we need to retain your information to comply with a legal or regulatory obligation.
4. The right to restrict processing:
You have the right to request that we limit the way we use your information if you have a particular reason for wanting that restriction e.g. in circumstances where you believe that we don’t have the appropriate rights to process your information.
5. The right to data portability:
You have the right to obtain some of your information in a format you can move from one service provider to another. Should you request it, we will provide you with an electronic file of your basic account information.
6. The right to object:
You have the right to object to us processing your information e.g. you can ask us to stop sending you marketing communications at any time.
You can withdraw your consent at any time. Please contact us if you want to do so.
You can also ask us to stop marketing to you by clicking on the ‘unsubscribe’ link that appears in all of our emails or by updating your preferences in ‘Settings’.
Please note that it can take approximately 24 hours for any changes to your preferences to be actioned.
How to contact us
You can request access to the personal information we hold about you by writing to us at:
Rose Alexander Property Limited
44 Corner Brook, Lostock
Bolton, BL6 4GX
Or alternatively, please email us at firstname.lastname@example.org, noting ‘Subject Access Request’ or ‘SAR’ in the subject line of your email.
If you have any questions about how we collect, store or use your personal information please contact us by telephoning +44 (0) 1204 875 848 or via email at email@example.com.
How to complain
If you want to make a complaint about how we have handled your personal information, please contact us at firstname.lastname@example.org and we will investigate the matter and report back to you. If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the UK’s data protection regulator – the Information Commissioner’s Office – https://ico.org.uk/.