The Circle takes the protection of your privacy seriously and our use of your personal information is governed by this Privacy Notice. On this site, “The Circle”, “our” and “we” each mean the UK company The Circle Ltd which collects and uses your information in the manner set out in this Privacy Notice. Any reference to “you” or “your” refers to anyone whose personal information we process.
1. Introduction
The Circle is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation. Your personal information will only be shared with others in accordance with this Privacy Notice.
Please read this Privacy Notice carefully and contact us if you have any questions. Should you wish to contact us in relation to our use of your personal data, please contact us at hello@circlethailand.com.
2. Personal information
Personal information is any data, or combination of separate data, that could allow us to identify you. It could include, amongst other things, information including your name, contact details, date of birth or bank account details.
Some personal information is classified as “special categories of personal data” by the UK General Data Protection Regulation (GDPR) and we need to have additional justifications if we are to collect, store or use this type of personal information. This includes the following:
- personal data revealing racial or ethnic origin;
- personal data revealing political opinions;
- personal data revealing religious or philosophical beliefs;
- personal data revealing trade union membership;
- genetic data;
- biometric data, where used for identification purposes;
- data concerning health;
- data concerning a person’s sex life; and
- data concerning a person’s sexual orientation.
Further information regarding special category data is available from the Information Commissioner’s Office.
Any references to personal information in this Privacy Notice will include personal data and, where relevant, special categories of personal data.
We may collect your personal information from a variety of sources including information we collect directly from you, information we collect when you visit our website or other property portals and information collected when you create an account on our website, view our online content or use our mobile applications or other services.
3. Personal information we collect from you
We will collect your full name and contact details, such as phone number, email address and postal address, from you when you engage with us.
Depending on the nature of the interaction with you or the service provided to you, we may also directly collect the following information from you:
- username and password;
- date of birth;
- demographic information;
- gender;
- payment information including card and bank account details;
- proof of identity documents such as passport and driver’s licence;
- proof of address;
- credit reference checks;
- information required to identify you to meet anti-money laundering and counter-terrorist financing requirements; and
- specific identity documents from you for the purpose of preventing and detecting crime, fraud or money laundering.
4. Personal information we collect when you visit our website or view our promotions and other services
We use cookies and other tracking technologies to collect information when you visit our sites, view our online advertisements or promotions, or use our mobile applications or other services.
You may delete and block all cookies from this website, but please be aware that restricting or deleting cookies may impact the functionality of the website.
Your web browser may allow you to restrict or delete cookies set by this website. The Help function within your browser should tell you how. Alternatively, you can visit www.allaboutcookies.org, which provides general information about cookies and how you can manage cookies on your computer.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
The following are examples of information we may collect using cookies:
- information about your device, browser and operating system;
- IP address;
- web pages you view on our sites; and
- The Circle emails opened by you.
5. Use of personal information
Under UK GDPR we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information:
- for employment-related purposes;
- where we need information to perform the contract we have entered into with you;
- where we need to comply with a legal obligation; and
- where the processing is necessary for us to carry out activities in our legitimate interests, or those of a third party, provided that your interests and fundamental rights do not override those interests.
These legitimate interests include:
- processing that is necessary for us to promote our business and to measure the reach and effectiveness of our campaigns. This includes sending marketing information to you for services that may be of interest to you or that you have expressly indicated you would like to receive information about. You have the right to opt out of receiving this information at any time;
- processing that is necessary to improve our knowledge of the real estate sector, including through market analysis and research;
- processing necessary for us to operate our business efficiently and effectively by creating a better understanding of you as a customer;
- processing that is necessary to outsource certain functions to third parties who specialise in such services;
- processing for network and information security purposes so that we can better protect your information against loss, damage, theft or unauthorised access; and
- processing to comply with a request from you in connection with the exercise of any of your rights outlined in this Privacy Notice.
In relation to purchases, sales and lettings, we will use your personal information in the following ways:
- for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging viewings, obtaining feedback and arranging a contract for sale or a lease for you;
- to conduct due diligence in accordance with other legal or regulatory obligations;
- to share with your appointed solicitors and the solicitors and agents acting for the other side of the deal as is necessary to facilitate the sale or purchase. We may also share your personal information with joint or multi agents or developers, as the case may be; and
- to share with third-party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent a property. In such circumstances, the third-party referencing agency may act as a data controller for your information.
If we are providing property management services to you, we may also need to pass your personal information from time to time on to third-party contractors whom we have engaged to carry out maintenance on your properties.
Your personal information may also be used for the following purposes:
- to share with governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our legal obligations; and
- to share with third-party service providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third-party referencing or screening agencies for the purposes of the prevention and detection of crime.
6. Keeping your information secure
When you provide us with your personal information we endeavour to keep it secure by processing it in our secure client management systems and we have put in place security measures designed to protect your data from being lost, stolen, accessed by unauthorised third parties, or tampered with in any way. In addition, we restrict access to your personal information to only those members of our staff that have a need to see it.
Despite the measures we have taken, we cannot, however, guarantee your personal data will be free from every security risk that may be possible when your information is sent to and from our website.
7. Information retention period
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. Generally, we will keep your personal data for as long as you are registered for our services or have an account with us.
This is so we can:
- communicate with you about any questions or complaints you may have after you have stopped being a user of our services;
- comply with rules on accounting, reporting or other law; or
- provide you with relevant information about products and services that you may be interested in.
8. Your rights in relation to your personal information
You have rights in relation to your personal information and its use by us.
These include the right to:
- be informed about how we use your personal information;
- obtain access to your personal information that is held by us; and
- request that your personal information is corrected where you believe it to be incorrect or incomplete.
In the following circumstances, you may request that we erase your personal information:
- if we continue to process your personal information beyond the period when it is necessary for us to do so;
- if our sole legal basis for processing your personal information is your consent and you withdraw that consent;
- if we are relying on legitimate interests as the legal basis for processing your personal information, you object to this processing and there is no overriding ground which enables us to continue to process the personal information;
- if the personal information has been processed in breach of the requirements of data protection legislation; or
- if the erasure is necessary to comply with a legal obligation.
You may also request that we restrict our data processing activities where you consider that:
- the personal information is inaccurate;
- processing the personal information is unlawful;
- we no longer need to hold the personal information but you require us to keep it so that you can establish, exercise or defend a legal claim; or
- you have raised an objection to our continued use of your personal information.
You have the right to request a copy of personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that we need to perform our agreement with you and/or personal information where we are relying on consent as the legal basis to process your personal information.
You also have the right to object to our processing of your personal information where the legal basis for our processing is either legitimate interests or exercise of a public interest task. Should an objection be raised, we will assess whether we have an overriding legitimate ground which entitles us to continue to process your personal information. Where none exists, we will cease to process your personal information.
In order to comply with our data protection obligations and to adequately manage your request and any associated queries or complaints, we keep records of all requests to exercise these rights, including our responses to each request. These records are kept in accordance with our information retention period outlined at section 7.
Please contact us at hello@circlethailand.com should you wish to exercise any of your rights pertaining to your personal information.
9. Complaints and contact
If you are unhappy about the way in which we have used your personal information and wish to make a complaint, please contact us at hello@circlethailand.com.
We will attempt to resolve the issue but if we cannot resolve it to your satisfaction, you have the right to complain to the Information Commissioner in the UK or the equivalent data protection authority in your country. Information regarding making a complaint to the Information Commissioner is available from the Information Commissioner’s Office.
If you wish to contact us regarding any aspect of this Privacy Notice, please email us with your feedback at hello@circlethailand.com.
10. Updates
Our Privacy Notice is reviewed periodically as our services develop or if the law changes. The latest version of our Privacy Notice will always be displayed on our website.
