This is the privacy notice of Intouch Property Investing Limited, registered company number 13421079 (“we”, “our”, or “us”). You can write to us in relation to our privacy policy at Ground Floor, The Custom House, The Strand, Barnstaple, Devon, England, EX31 1EU.

Introduction

This notice describes how we collect, store, transfer, and use personal data. It tells you about your privacy rights and how the law protects you. In the context of the law and this notice, “personal data” is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as “processing”. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Personal data we process:

1. How we obtain personal data

The information we process about you includes information:

• You have directly provided to us
• As a result of monitoring how you use our website or our services

2. Types of personal data you provide directly to us

When you use our website or our services, we may ask you to provide personal data to us. This can be categorized into the following groups:

• Personal identifiers, such as your first and last names
• Contact information, such as your email address, your telephone number, and your postal address
• Transaction information, which may include information about your payment method and/or the transactions you have made with us
• Health information, which may include information about current and past medical conditions, medical treatments, injuries, and physical fitness and training
• Your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

3. Types of personal data we collect from your use of our services

By using our website we process:

• Technical information about the hardware and the software you use to access our website including your Internet Protocol (IP) address, your browser type and version, and your device’s operating system
• Usage information, including the frequency you visit our website, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages.

4. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful. However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

5. Special personal data

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

Because of the nature of our business, we may collect special personal data about you if there is a lawful basis on which to do so.

6. If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

The bases on which we process information about you:

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

1. Performance of a contract: We may process your personal data to fulfill our contractual obligations with you, such as providing you with our services or products that you have requested.
2. Legitimate interests: We may process your personal data based on our legitimate interests, such as improving our services, understanding our customers’ preferences, and ensuring the security and integrity of our website and systems. We will always balance our legitimate interests with your rights and interests to ensure that they are not overridden.
3. Consent: We may process your personal data based on your explicit consent, such as when you have given us permission to send you marketing communications or use your health information for specific purposes. You have the right to withdraw your consent at any time by contacting us using the details provided in this privacy notice.
4. Legal obligation: We may process your personal data to comply with legal obligations, such as keeping financial records, responding to lawful requests from public authorities, or meeting regulatory requirements.
5. Vital interests: In certain situations, we may process your personal data to protect someone’s life, such as in a medical emergency.
6. Contractual necessity: In some cases, we may need to process your personal data in order to enter into or perform a contract with you, such as processing payment information when you make a purchase from us.

How we use your personal data

• We may use your personal data for the following purposes:
• To provide you with our services or products, and to fulfill our contractual obligations with you.
• To communicate with you, including sending you marketing communications if you have opted to receive them.
• To personalize and improve your experience on our website, including analyzing how you use our website and services, and tailoring our offerings to your preferences.
• To comply with legal obligations, such as keeping financial records and meeting regulatory requirements.
• To protect our rights and interests, such as detecting and preventing fraud, abuse, or security incidents.
• To respond to your inquiries, requests, or complaints.
• To protect someone’s life in case of a medical emergency.
• For any other lawful purpose for which we have obtained your consent.

Sharing your personal data

We may share your personal data with third parties in the following circumstances:

• Service providers: We may share your personal data with third-party service providers who perform services on our behalf, such as payment processors, IT providers, marketing agencies, and customer support providers. These service providers are only authorized to process your personal data as necessary to provide the services to us and are obligated to keep your personal data confidential and secure.
• Legal requirements: We may disclose your personal data to comply with applicable laws, regulations, legal processes, or governmental requests. We may also disclose your personal data to enforce our legal rights, protect our property or safety or the property or safety of others, and detect, prevent, or address fraud, security breaches, or technical issues.
• Business transfers: If we are involved in a merger, acquisition, sale of assets, or other business transfer, your personal data may be transferred to the relevant third party as part of that transaction.
• With your consent: We may share your personal data with third parties for any other purpose for which we have obtained your explicit consent.

International transfers of personal data

Your personal data may be transferred to and processed in countries outside of the European Economic Area (EEA) or your country of residence. In such cases, we will take appropriate measures to ensure that your personal data receives an adequate level of protection, as required by applicable data protection laws. These measures may include, but are not limited to, implementing standard contractual clauses, obtaining your explicit consent, or ensuring that the recipients are Privacy Shield certified (if applicable).

Security of your personal data

We take the security of your personal data seriously and have implemented appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration. We regularly review and update our security measures to ensure the ongoing integrity and confidentiality of your personal data.

Retention of your personal data

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The specific retention period will depend on the type of personal data and the purposes for which it was collected.

Your rights

• As a data subject, you have certain rights regarding your personal data. These rights may include:
• Right to access: You have the right to request access to your personal data that we hold, and to receive a copy of your personal data in a commonly used and machine-readable format.
• Right to rectification: You have the right to request the correction of inaccurate or incomplete personal data that we hold about you.
• Right to erasure: You have the right to request the deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or when you withdraw your consent (if consent was the basis for processing).
• Right to restrict processing: You have the right to request the restriction of processing of your personal data under certain circumstances, such as when you contest the accuracy of your personal data or when the processing is unlawful.
• Right to object: You have the right to object to the processing of your personal data under certain circumstances, such as when the processing is based on legitimate interests or for direct marketing purposes.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another data controller, under certain circumstances.
• Right to withdraw consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to lodge a complaint: If you believe that your rights regarding your personal data have been violated, you have the right to lodge a complaint with the relevant data protection authority.

Updates to this privacy notice

We may update this privacy notice from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes to this privacy notice, and obtain your consent if required by applicable laws.

Contact us

If you have any questions or concerns about this privacy notice or our data processing practices, please contact us using the contact details provided on our website or through our customer support channels.

Conclusion

Thank you for reading our privacy notice. We are committed to protecting your personal data and respecting your privacy rights. If you have any questions or concerns about how we process your personal data, please do not hesitate to contact us.

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