- BACKGROUND: CHAHINE INTERNATIONAL AGENCY LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website. www.cia-agency.co.uk (Our Site) will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- We will only gather personal details such as D.O.B (Date of Birth), N.I. (National Insurance) and or Passport and or Driving Licence, Full Contact Details (Including Email and or Mobile Number and or Landline Number), for the full period you are a customer with CHAHINE INTERNATIONAL AGENCY (CIA) LTD.
- The only purpose of us maintaining this information for the period you are a customer with CIA is so that we comply with the current GDPR rules and regulations.
- When “you” as the (customer/ client) contacts CIA we can ask the relevant security questions and understand that we are communicating with the correct (legitimate) customer/ client and not communicating with fraudulent people trying to commit fraud or fraudulent activity using your identity.
- We will not gather certain data unless you specifically request from CIA to do so, additional information means, i.e., Nationality, Ethnicity, Religious Beliefs, and any additional data/ Information you wish for CIA to keep on our records.
- If you no longer wish to be a customer/ client of CIA, we will automatically delete (erase) all your personal details (plus all additional data relating to you as the (customer/ client) and all data relating to you as the customer/ client after a 30-day period. CIA will only retain your information after the 30-day period if you the customer/ client request this in writing.
Definitions and Interpretation In this Policy the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Information About [Us] OR [Me]Our Site is owned and operated by CHAHINE INTERNATIONAL AGENCY LTD, a Real Estate business registered in England under company number 13296684.
Registered address: 71-75 SHELTON STREET, COVENT GARDEN, LONDON, WC2H 9JQ, UNITED KINGDOM.
Main trading address: 71-75 SHELTON STREET, COVENT GARDEN, LONDON, WC2H 9JQ, UNITED KINGDOM.
Please Note: Do only contact us electronically and do not post any documentation under no circumstances (your postal deliver may fail and you may lose any personal or non-personal documentation you may post hence the reason we advise that you do not post any documentation to us.)
CIA does not hold any legal or non leal responsibility if you as the customer/ client decide to post any documentation to our registered office.
What Does This Policy Cover?
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability.
This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling e do not use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights, this can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
What Data Do You Collect and How?
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we [will] OR [may] use your personal data, and our lawful bases for doing so:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on our [Products] AND/OR [Services]. You will not be sent any unlawful marketing or spam.
- We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to [opt-out.]
- We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to [opt-out at any time.]CIA currently has no Third Parties connection with any company. If matters do change later in the future CIA will inform you as the (customer/ client) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
- CIA don’t use any automated system[s] for carrying out certain kinds of [decision-making] AND/OR [profiling]. If at any point you wish to query any action that [we] take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method, the Data Protection Legislation gives you the right to do so. Please contact [us].We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If [we] do use your personal data in this way and you wish for [us] to explain how the new purpose is compatible with the original, please contact [us] using the details in Part 15. If [we] need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, [we] will inform you and explain the legal basis which allows [us] to do so. In some circumstances, where permitted or required by law, [we] may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
[We] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
How and Where Do You Store or Transfer My Personal Data?
[We] will [only store or transfer your personal data] OR [store or transfer some of your personal data] within the UK. This means that it will be fully protected under the Data Protection Legislation.]
AND/OR [We] will [only store or transfer your personal data] OR [store or transfer some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
AND/OR [We] [may] store or transfer some or all of your personal data in countries that are not part of the [European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein)] OR [EEA]. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that [we] will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows.[We] share your data within the group of companies of which [we are] a part. Where this involves the transfer of personal data outside the EEA, [our] limited company ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
AND/OR [We] share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard[s] [are] applied to such transfers:[We] [will only] transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
AND/OR [We] use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
AND/OR Where [we] transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission. Please contact [us] using the details below in Part 15 for further information about the particular data protection mechanism[s] used by [us] when transferring your personal data to a third country. The security of your personal data is essential to [us], and to protect your data, [we] take a number of important measures, including the following:
- Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where [we are] legally required to do so;
- We will use and process your data in accordance with current GDPR Rules and Regulations for the sole period in which you are a customer/ client of CIA and all your data will be deleted after a 30 – day period from you as customer/ client choose to leave CIA.
Do You Share My Personal Data?
How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via [Our] Site, you may be given options to restrict [our] use of your personal data. In particular, [we] aim to give you strong controls on [our] use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from [us] which you may do by unsubscribing using the links provided in [our] emails [and] OR at the point of providing your details [and by managing your Account]).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access [certain areas of] [Our Site] without providing any personal data at all. [However, to use all features and functions available on [Our] Site you may be required to submit or allow for the collection of certain data.] The access of information is only applicable to your personal data and you will not, and we will not give you access to other customer(s)/ client(s) data.
How Can I Access My Personal Data?
If you want to know what personal data [we] have about you, you can ask [us] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15 AND/ OR contact us electronically via our website as this would be the most secure method to avoid an loss of any correspondence you may send us. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] everything [we] need to know to respond to your request as quickly as possible.] There is not normally any charge for a subject access request (But administration charges fees will be applicable). If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] administrative costs in responding.[We] will respond to your subject access request within [1-2 month period depending on how busy we are but we also may respond within a 30-day period depending on workload) and, in any case, not more than] 1 month of receiving it. Normally, [we] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] receive your request. You will be kept fully informed of [our] progress.
By using [Our] Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than [us]. Third-party Cookies are used on [Our] OR [My] Site for . For more details, please refer to the table below.
These Cookies are not integral to the functioning of [Our] Site and your use and experience of [Our] Site will not be impaired by refusing consent to them.
All Cookies used by and on [Our] Site are used in accordance with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a Cookie Notice requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling [us] to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of [Our] Site may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]
[Certain features of [Our] Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that [Our] Site may not work properly if you do so. [We] have taken great care to ensure that your privacy is not at risk by allowing them.]
The following first-party Cookies may be placed on your computer or device:
In addition to the controls that [we] provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
How Do I Contact You?
To contact [us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of – Managing Director Youssef Chahine)]: Email address: <firstname.lastname@example.org> Telephone number: <+44 7592 695 100> Postal Address: 71-75 SHELTON STREET, COVENT GARDEN, LONDON, WC2H 9JQ, UNITED KINGDOM.