Zebra Asset Management Limited – GDPR/Data Protection & Privacy Policy

Zebra Asset Management Limited, are committed to protecting and respecting your privacy,
and operate within the requirements of the Data Protection Act 1998 and the General Data
Protection Regulations (“GDPR”).

Zebra Asset Management Limited are referred to in this Data Protection and Privacy Policy as
‘we’, ‘us’, ‘our’ or ‘Zebra Asset Management Limited’.

This Data Protection and Privacy Policy sets out how we collect and process any personal data
that we collect from you, or that you provide to us, in connection with our website at
www.zebra-properties.co.uk our website services and any other pages from which we link to
this Data Protection and Privacy Policy (collectively, the Website and Website Services).

We may amend this policy from time to time by updating this page. You may wish to check it
each time you submit any personal data to us.

We recommend that you read this Data Protection and Privacy Policy alongside our Website
Terms and Conditions.

1. Personal data protection principles

We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:

  • processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
  • collected only for specified, explicit and legitimate purposes (Purpose Limitation);
  • adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (Data Minimisation);
  • accurate and where necessary kept up to date (Accuracy);
  • not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed (Storage Limitation);
  • processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss,
    destruction or damage (Security, Integrity and Confidentiality);
  • not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and
  • made available to data subjects and data subjects allowed to exercise certain rights in relation to their personal data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

2.Lawfulness and fairness

Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.

The GDPR restricts our actions regarding personal data to specified lawful purposes. These restrictions are not intended to prevent processing,
but ensure that we process personal data fairly and without adversely affecting the data subject.

The GDPR allows processing for specific purposes, some of which are set out below:

(a) the data subject has given his or her consent;
(b) the processing is necessary for the performance of a contract with the data subject;
(c) to meet our legal compliance obligations.;
(d) to protect the data subject’s vital interests; or
(e) to pursue our legitimate interests for purposes where they are not overridden because the processing prejudices the interests or fundamental rights and freedoms of data subjects.
The purposes for which we process personal data for legitimate interests need to be set out in applicable privacy notices or fair processing notices.

3. Your Rights Under GDPR

You as an individual have rights as follows:

  • The right to be informed about processing of your personal data.
  • The right to have your personal data corrected in case of inaccuracy and to have incomplete personal.
  • information completed.
  • The right to object to processing to processing of your personal data.
  • The right to restrict processing of your personal data.
  • The right to erasure of your personal data.
  • The right to request access to your personal data and information about how we process it.
  • The right to move your personal data (Data Portability).
  • The right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

4.Information you give us

You may give us information about you by completing forms on our site or by corresponding with us. The information you give us may include (but is not limited to) the items below.

  • If you email us through the Website you will be asked for your name and email address so that we can respond to your enquiry.
  • If you request a brochure or other data through the Website we will usually require your email address.
  • If you sign up to receive any newsletters then we will require your name and email address.
  • If you enter any competitions we publicise on the Website or through our Website Services, we may require your name, address, post code, telephone number and email address.
  • If you choose to make an online payment, our payment services provider will require your card details, personal identifying information and contact details.
  • We will only process any sensitive personal data if you have provided your consent to do so, this may be by way of you specifically ticking a box on our website to provide your consent, or by way of a confirmation e-mail to us.

5.Information we store automatically

    • Like many websites, we obtain certain information when your web browser accesses the Website. We may obtain this information using a third party. This is statistical data about our users’ browsing actions and patterns. This data may identify organisations accessing our Website but we do not use it to identify any individual. For example, we may collect:

 

      • the Internet protocol (IP) address used to connect your computer or other access device to the Internet;
      • aggregate computer and connection information such as browser type and version, operating system and platform; and
      • URL click stream information showing how users have reached our Website and whether they access other sites via any external links.

 

  • We may also store information about you in cookies. Cookies are little files that websites put on your computer that we can access when you make return visits to the Website to monitor how the Website is used, improve our service and make your experience more efficient. For more information on the cookies used across our Website and Website Services please see our Cookie Policy.
  • We may use software tools to measure and collect session information, including response times, download errors, length of visits and page interaction information.
  • We may monitor and record telephone calls, and keep a record of them for quality control, training, and administration purposes. We may also automatically record the number from which you call our customer service centre.

6.How we use your information

(a) We may use your personal data and organisation data to:

  • respond to any email enquiries and complaints we receive from you;
  • administer any service you have asked us to provide;
  • monitor data traffic and any patterns of use;
  • track the success of our marketing activity;
  • ensure the content of the Website and Website Services is fit for the purpose for which it was set up and to develop the experience of its users; monitor compliance with and enforce our Website terms and conditions or our data licensing terms;
  • if you are an individual and have consented, to let you know about updates and promotional offers in relation to other Zebra Asset Management Limited products and services which may be of interest to you;
  • if you are an organisation, to let you know about existing or new products that may be of interest to you;
  • if you have consented, to enable selected third parties to contact you;
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services which you requested from us;
  • to notify you about changes to our service;
  • to ensure that content from our site is presented in the most effective manner for you and your computer;
  • to verify your identity;
  • as part of our efforts to keep our site safe and secure and to prevent or detect fraud;
  • to provide customer support; or
  • to comply with the requirements imposed by law or any court order.

(b) In addition to the purposes listed above, we may use this information:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and your computer;
  • to allow you to participate in interactive features of our service;
  • to measure or understand the effectiveness of advertising we serve to you and others and to deliver advertising to you and others (including via selected third parties);
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them (including via selected third parties).

(c) How we will use information about you we receive from other sources.

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above.

7. Sharing your information

(a) We are committed to protecting your privacy, and we share your personal data with other organisations only as described below:

  • Zebra Asset Management Limited may share information within its group companies;
  • if you have expressly given us permission, we may share your information with third party organisations so they may contact you directly for the purposes to which you have consented (for example, where you have opted in to receive third party marketing information).

(b) We may disclose your information to third parties:

  • in the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets;
  • if Zebra Asset Management Limited sells substantially all of its assets to a third party, in which case personal data held by it about its clients will be one of its transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property or safety of Zebra Asset Management Limited, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
  • our site may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please be aware that these have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before submitting information to these websites.

(c) We do not transfer personal data outside of the EU.

8.Erasing your information and unsubscribing

(a) If you do not want us to retain any of your data, please let us know by post or by email using the contact details at the end of this policy, or by informing us via our Website unsubscribe page. We will then delete all personal data held about you except where required by law to be retained.

(b) You can unsubscribe from our newsletters and emails by the following methods:

  • using the ‘unsubscribe’ button displayed on our emails or Website; or
  • by forwarding the email to [insert e-mail address], with the word unsubscribe in the subject line; or
  • if you have an account with us, by changing your email preferences on your account; or
  • by writing to Customer Services, Zebra Asset Management Limited, [insert address].

(c) We will store your personal data for no longer than reasonably necessary to the relevant service. We will usually retain your personal data for a reasonable period to allow us to respond to any follow-up enquiries or complaints, or for as long as you remain a registered user of the Website or Website Services.

(d) We aim to keep the information which is stored automatically when you access the Website (as set out above) for no longer than a year.

9.Data security

(a) Once it is within our control, we ensure your personal data is kept confidential by storing it on our secure database or taking other appropriate measures to ensure that it remains private, and is not kept for longer than is needed.

(b) Once we have received your information we will use strict procedures and security features to try and prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of information transmitted to our site. Any transmission is at your own risk and you agree that we will not be liable for any breach of security unless it has been proved that we have been negligent. We do not accept any responsibility for the protection of information or images provided to third party online sites that link to or from our website.

10.Contacting Us

(a) For the purpose of the Data Protection Act 1998 and GDPR, the Data Controller is acting through Zebra Asset Management Limited, a company registered in England and Wales with company no. 07011164.

(b) We will use reasonable efforts to supply, correct or delete any of your personal data on request. You are entitled to ask us for a copy of any personal data that we hold about you and we will provide this to you within one month of receipt of your request.

(c) If you have any queries about this Data Protection and Privacy Policy and/or how we use your personal data, or wish to opt out from receiving any marketing communications, please contact us:

Zebra Asset Management Limited:
9 Bedford Square, Houghton Regis, Dunstable, Bedfordshire, England, LU5 5ES
info@zebra-properties.co.uk
01582 866344

Zebra Asset Management Limited, T/A Zebra Properties is registered in England and Wales (registration number 07011164). Our registered office is at 9 Bedford Square, Houghton Regis, Dunstable, Bedfordshire, England, LU5 5ES.