Eagle Property Management Limited, referred to as 'Eagle Property Management', 'we' or 'our' is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the Data Protection (Jersey) Law 2018 (DPJL).
Eagle Property Management is a "Data Controller". This means that we are responsible for deciding how we hold and use personal information.
Eagle Property Management is a registered business with the JFSC, registration number 133413. We are also registered with the Jersey Officer of the Information Commissioner (JOIC) Registration number 68377.
We will comply with the Data Protection (Jersey) Law 2018 (DPJL), which means the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Eagle Property Management is accountable to you and the Authorities to not only show compliance with the data protection laws but also to demonstrate how we are compliant.
The Data Protection Manager ("DPM")
We have appointed a DPM to oversee compliance with this Privacy Notice.
If you have any questions about this Privacy Notice or how we handle your personal information, please contact the DPM at office@eagle.je
The Kind of Information We Hold About You
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
To explain this to you, we will when necessary list our different services when we collect or use different information about you.
How Is Your Personal Information Collected?
We collect personal information about you when you contact us, visit our website, make an enquiry about one of our lettings, engage us to lease your property, or contact us for another specific purpose.
Information we may collect about you includes but is not limited to:
When you lease a property through us:
- Name
- Title
- Address
- Details of visitors
- Correspondence with us
- KYC
- Telephone number
- Email Address
- Record of enquiry
- Billing information
- Payment details
- ID Documentation
When you rent a property through us:
- Name
- Title
- Address
- Correspondence with us
- References
- KYC
- Telephone number
- Email Address
- Record of enquiry
- Billing information
- Payment details
- Credit check
- ID Documentation
What Special Category Data We Collect About You?
When we collect Special Category data, we will always have a clear legal basis to process this, or with your explicit consent. If we rely on your explicit consent, you can withdraw this at any time by contacting our DPM at office@eagle.je
Special Category data is any information relating to your health, gender, race, sexual orientation, sex life, genetic or biometric data etc.
An example of this processing would be the information we need to process when we carry out KYC and credit checks on our clients. We have a legal obligation to collect this information and to store it.
How We Will Use Information About You?
We will only use your personal information when the law allows us to, this is called a legal basis for processing your information (data).
Most commonly, we will use your personal information in the following circumstances:
- Where you have entered into a contract with us to provide you with a service. This would be when engage us to sell or lease your property or you wish to buy/let a property with us.
- Where we need to comply with a legal obligation. This would be when we have to comply with a lawful authority to disclose information. An example of this is we provide your information to our banking partners or other competent authorities to meet our legal and regulatory obligations.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. An example of this is when we send you updated information about a service you have had from us in the past that we feel you may be interested in.
We may also use your personal information in the event of an emergency, and we believe it is in your vital interest that we share your information with trusted 3rd parties.
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Data Sharing
We may on occasions pass your Personal Information to organisations outside of Eagle Property Management exclusively to process on our behalf, these organisations are called Data Processors.
We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.
We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental request.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers.
If we do this, we ensure that your privacy rights are respected in line with this Notice and the same protection is given to your personal information as laid down by the DPJL and GDPR legislation.
Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors and other third parties on a need-to-know basis.
They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.
Details of these measures may be obtained from our DPM at office@eagle.je
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
All data is retained securely and only used for the purposes set out in the Law. Data is retained to comply with our statutory obligations and in accordance with our retention schedule. If you would like a copy of our retention schedule, please contact our DPM at office@eagle.je
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 we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of Access, Correction, Erasure, and Restriction
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your relationship with us. Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, please contact our DPM at office@eagle.je
You will not have to pay a fee to access your personal information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
How to Request Your Information and What We May Need From You
Please use the Data Subject Access request form, available on our Cookie Banner. If you have any questions about this process or any of your rights, please contact our DPM at office@eagle.je
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We will respond to your request without undue delay, but certainly within Four Weeks after and upon satisfactory verification of your identity. Depending on the complexity of the request, we may apply an extension of up to Eight Weeks on the response time, but you will be informed of this as soon as possible after a valid request is made.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact our DPM at office@eagle.je
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.
We may also notify you in other ways from time to time about the processing of your personal information or requesting you to confirm the accuracy of the information we hold on you.
Complaints
We would like the chance to resolve any complaints you have about the way we process your information; however, you do have the right to complain to the JOIC about how we have used your personal data.
The details for each of these contacts are:
Eagle Property Management
1st Floor, 3 Broad Street, St. Helier, Jersey JE2 3RR
Telephone: (+44) 7700 770135
Email: office@eagle.je
Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street, St Helier, JE2 3BT
Telephone: (+44) 1534 716530
Email: enquiries@jerseyoic.org