In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data. Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that: We keep several categories of personal data in order to carry out effective and efficient processes. We keep this data in a personnel file and we also hold the data within our computer systems, for example our CRM system. You provide several pieces of data to us directly during the process of expressing interest in our product, purchasing our product or selling our product. The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage your purchase and to provide relevant updates on your purchase. Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you. This could include being unable to purchase and promote our product or for us to administer contractual benefits. We will only collect criminal conviction data where it is appropriate and where the law permits us. This data will usually be collected on the purchase of a fractional share of a property in order to obtain a membership certificate to confirm your investment. Employees within our company who have a responsibility for administrating and processing to perform tasks such as those mentioned ‘Activities requiring your data’ . All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. We only keep your data for as long as we need it for, which will be at least for the duration of your custom and interest with us though in some cases we will keep your data for a period after your custom has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below: You have the following rights in relation to the personal data we hold on you: Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data. We use a high level of security to protect your Personal Data, but cannot guarantee the security of any Personal Data you disclose online. You accept the inherent security implications of dealing online over the Internet and will not hold IQ FUND MANAGEMENT S.R.O. or our associate companies responsible for any breach of security. As is common practice with almost all professional websites, this site uses cookies. These are small files that are downloaded to your computer, if you agree, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. For more general information on cookies see the Wikipedia article on HTTP Cookies. [By continuing to use our site, you are agreeing to our use of cookies.] We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if unsure whether or not you need them, in case they are utilised to provide a service that you use on the site. You can adjust the use of cookies by changing the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the site. Therefore, it is recommended that you do not disable cookies. If you create an account with us then we will use cookies for the management of the sign-up process and general administration. Unless absolutely necessary, i.e. to remember your site preferences, these cookies will be deleted as soon as you log out. We use cookies when you are logged in so that we can remember your sign in details. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in. When you submit data through a form, such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence. In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be recalled whenever you interact with a page that is affected by your preferences. In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter when using this site. This site uses Google Analytics, which is one of the most widespread and trusted analytics site on the web, for helping us to understand how you use the website and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page. We also use social media buttons and/or plug-ins on this site that allow you to connect with your social network in various ways. For these to work, the following social media sites, including LinkedIn, Facebook, Twitter, Instagram, Google + and Pinterest, will set cookies through our site, which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
PRIVACY NOTICE
This notice applies to potential customers, current customers and business partners.A) DATA PROTECTION PRINCIPLES
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal dataB) TYPES OF DATA HELD
Specifically, we hold the following types of data:
a) personal details such as name, address, phone numbers, email address, passport details
b) information gathered via business partners and lead providers such as that entered into a reservation form, online interest submission or expression of interest form
c) details relating to pay administration such as bank account details
d) medical or health information
e) criminal record information
f) information relating to client’s property purchases and business partners commission agreementsC) COLLECTING YOUR DATA
In some cases, we will collect data about you from third parties, such as lead providers and business partners.
Personal data is kept in files or within the Company’s computer CRM system.D) LAWFUL BASIS FOR PROCESSING
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data
Lawful basis
Carry out the promissory contract or trading agreement that we have entered into with you e.g. using your name, contact details and passport unformation
Performance of the contract
Ensuring you are paid
Performance of the contract
Making you aware of our latest developments
Our legitimate interests
Assisting with legal processes and production of documentation required
Our contractual interests
Ensuring efficient administration of processing statements of returns
Our contractual interests
Maintaining comprehensive up to date records about you to ensure, amongst other things, effective correspondence can be achieved
Our contractual interests
E) FAILURE TO PROVIDE DATA
F) CRIMINAL CONVICTION DATA
G) WHO WE SHARE YOUR DATA WITH
Data is shared with third parties for the following reasons:
a) any fractional purchase requests operated by third parties, namely FOC company
b) promissory contacts, addendums, revocations, contract of assignments relating to legal process submitted to our lawyers, namely GPA
c) business partners for the purpose of requesting legal contracts to be issued for a client meeting providing the client has submitted and signed a reservation form confirming they are happy for their completed legal contract to be sent to the business partner.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We may need to share your data with bodies outside of the European Economic Area. We have put measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws.H) PROTECTING YOUR DATA
I) RETENTION PERIODS
Record
Recommended Retention Period
Expression of interest submission
Until erasure requested
Reservation forms for purchase
Permanently
Legally signed documents
Permanently
Statements and payments made
Permanently
Passport copies
Until legal completion of your purchase/expiry
J) RELEVANT INDIVIDUAL RIGHTS
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
More information can be found on each of these rights in our separate policy on employee rights under GDPR.K) CONSENT
L) USE OF THE INTERNET
Emails are not a 100% secure or reliable method of communication. IQ FUND MANAGEMENT S.R.O. accepts no responsibility for any loss you may suffer as a result of interception or non receipt of an e-mail.
It is your responsibility to ensure that your computer is virus protected. IQ FUND MANAGEMENT S.R.O.accepts no responsibility for any loss you may suffer as a result of accessing or downloading information from this site.
Any links on this website may lead you to websites which are not under the control of IQ FUND MANAGEMENT S.R.O.. Such links are provided for your convenience and do not represent any endorsement or recommendation by IQ FUND MANAGEMENT S.R.O.What Are Cookies
We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.How We Use Cookies
Disabling Cookies
The Cookies We Set
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As we sell products, it’s important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.