TNG Realty (Bayside ) Limited Website privacy policy
Policy version:28th October 2024Welcome to TNG Reality (Bayside) Limited’s website, accessible via Elysiumbayside.com (our Website). References to ‘we, ‘our’, or ‘us’ in this privacy notice is a reference to TNG Realty (Bayside) Limited. We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Website. It also explains your rights in relation to your personal data and how to contact us or the regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the Gibraltar GDPR
What this policy applies to
This privacy policy relates to your use of our Website only.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our Website. We will collect and use the following personal data about you (“Contact Data”):
- your first and last name, email address and telephone number, city, country of residence, post code
- any additional information you provide us including your particular interest for contacting us and in any subsequent exchanges with us.
If you do not provide us with information when we ask it from you we may not be able to deal with your enquiries.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us messages or feedback via our Website.
In addition as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies Please see our cookie policy for further details and how to change your preferences.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for, the lawful basis we rely on and the type of information we use for that purpose.
|
What we use your personal data for |
Our reasons/ Lawful basis relied on |
Relevant Categories of Personal Data |
|
To managing your relationship with us |
Depending on the circumstances -to perform our contract with you or to take steps at your request before entering into a contract -our legitimate interests to respond to your enquiries |
Contact Data |
|
Updating and enhancing customer records |
Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with you |
Contact Data |
|
|
|
|
|
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
Contact Data |
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
With your consent, we will use your personal data to send you updates (by email, text message, telephone or post) about our properties including any future developments by an associated development company. We will also use the information you provide us to target our digital and social media advertising effectively. This could include securely providing contact details such as your name and email address to digital advertising networks or social media companies such as Meta, Google and Twitter. For example, we may use your information to enable us to display adverts to you, or to prospective customers who have similar characteristics to you. Any information we share with social media companies will be shared in an encrypted format and will not be used for their own purposes.
You have the right to withdraw consent in respect of receiving marketing communications at any time by:
- contacting us at nevillepage@tnfo.org; or
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
Note you may still see adverts relating to TNG Realty (Bayside) Limited or other group companies, even after you have asked us not to use your information for targeted digital advertising. This is because the social media site or advertising network may select you based on information they hold, such as your age and location, or websites you have visited, without using information that has been provided by us. You can control the kind of advertising which you see through the relevant social media sites directly.
We may also ask you to confirm or update your marketing preferences in the future if there are changes in the law, regulation, or the structure of our business
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf at your request. Such third parties may include IT service providers (such as hosting and email management), our agents or property promotors in order to send you information you are interested in and market our properties as well as third parties who carry out market research/feedback on our behalf.
We or the third parties mentioned above occasionally also share personal data with:
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. Upon your request to unregister, we will deactivate or delete your information from our active databases. However, we may retain some information in our files to prevent fraud, assist with any investigations, enforce our legal rights and/or comply with applicable legal requirements.
Transferring your personal data out of Gibraltar
Countries outside Gibraltar, the UK and the EEA have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside Gibraltar. In those cases we will comply with applicable data protection laws designed to ensure the privacy of your personal data.
Under Gibraltar GDPR we can only transfer your personal data to a country outside Gibraltar where the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR or if there are:
- appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law for example in order to provide you with a particular service from a non Gibraltar country.
Where we transfer your personal data outside Gibraltar, we do so usually on the basis of an adequacy regulation or adequacy decision or (where this is not available) through the use of legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the Gibraltar GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside Gibraltar unless we can do so on the basis of an alternative mechanism or exception provided by Gibraltar data protection laws and reflected in an update to this policy.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
|
Access to a copy of your personal data |
The right to be provided with a copy of your personal data |
|
Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations |
|
Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
|
Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
|
To object to use |
The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
|
Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our Landing Page |
|
The right to withdraw consents |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by following the instructions to withdraw consent in the “Marketing” section above. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself eg your full name, address and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in Gibraltar by contacting the Gibraltar Regulatory Authority (www.gra.gi) or by telephone 20074636.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our Website for a reasonable period or by other means, such as email.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Nevile Page:
Email: nevillepage@tngo.org
Address: TNG Realty (Bayside) Limited Units 1-3, Ground Floor TNG Global house, 39-43 Irish town, Gibraltar
