Nokkel Technologies Ltd
This Privacy Notice was last updated in December 2021.
OUR CONTACT DETAILS
Nokkel Technologies Ltd
Company Number: 13149003
Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
Email Address: email@example.com
WHO WE ARE
In this privacy notice (“Privacy Notice”), whenever you see the words ‘We’, ‘Us’ or ‘Our’, it refers to Nokkel Technologies Ltd, a company registered in England, with company number 13149003 and registered offices at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ (“Nokkel”). For the purposes of the UK GDPR (as defined in the Data Protection, Privacy and Electronic Communications Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations SI 2019/419) and to the extent relevant, the General Data Protection Regulation (Regulation (EU) 2016/679), or 'EU GDPR', (and together, “Data Protection Laws”), we are a Controller in respect of the personal information that we collect and process about you as described in this Privacy Notice. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Laws to notify you of the information contained in this Privacy Notice. We are registered with the Information Commissioner’s Office as a Controller, with registration number: ZB273169.
In this Privacy Notice references to the “Nokkel App” include all Nokkel applications and websites.
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Nokkel is committed to protecting and respecting your privacy, and we value any personal data we have in our organisation. This Privacy Notice, together with any other documents referred to in it, sets out the basis on how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and the care in which it will be handled.
This Privacy Notice applies to the personal data of: (a) prospective buyers; (b) home owners; and (c) financial advisors who register with the Nokkel App.
WHAT IS PERSONAL DATA?
Personal Data (or personal information) is defined in Data Protection Laws as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
DATA PROTECTION PRINCIPLES
In order for Us to comply with Data Protection Laws, the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
BUYERS - THE TYPE OF PERSONAL INFORMATION WE COLLECT
We will collect, store and use personal information about you that relates to your engagement with us. The personal information that we collect includes the following (some of which is sensitive data relating to your financial position):
HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A BUYER
PROPERTY OWNERS - THE TYPE OF PERSONAL INFORMATION WE COLLECT
HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A HOME OWNER
FINANCIAL ADVISORS - THE TYPE OF PERSONAL INFORMATION WE COLLECT
HOW WE GET YOUR PERSONAL INFORMATION IF YOU ARE A FINANCIAL ADVISOR
SPECIAL CATEGORY PERSONAL DATA
We will not ask you to share details of any information regarded to be special category personal data under Data Protection Laws (for example, details of your race or ethnicity). If we do ever require such details, we will let you know first and we will ask for your permission before processing data of this sensitive nature.
We will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to provide it. You should be aware that it is not a condition of your contract with us that you agree to any request for permission from us.
In order to use the location functionality when using the Nokkel App, you will be asked to turn on your location in the settings on your phone.
HOW WE WILL USE THE INFORMATION ABOUT YOU – LEGAL BASES
We must have a legal basis to process your Personal Data. In most cases the legal basis will be one of the following:
“Legitimate Interest”: we might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. This could include understanding how you use our services to enable us to derive knowledge that enables us to develop the services. When we process Personal Data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
We aim to tailor our communications and ensure you are able to ‘opt-in’ to receive the information that you want. To achieve this, we will inform you, before collecting your data, if we intend to use your data for such purposes. You can exercise your right to prevent such processing and withdraw your consent by letting us know in writing. You will always have the right to ask us not to process your personal data for marketing purposes and you can exercise your right to erasure by contacting us at: firstname.lastname@example.org.
SHARING DATA WITH THIRD PARTIES
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. They must only process your personal data for specified purposes and in accordance with our instructions.
We may additionally disclose your personal information to third parties for reasons including the following:
This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we must comply with.
We may share your personal data in connection with any proposed or actual sale of our business or assets or an investment into our business. In such circumstances we will ensure the transfer of your personal data complies with Data Protection Laws.
No other third parties have access to your personal data unless it is specifically required to meet either contractual obligations or the legitimate interests of Nokkel as defined under Article 5 of the UK GDPR.
INTERNATIONAL DATA TRANSFERS
We may share your personal data overseas from time to time. Where we do, to ensure that your personal information receives an adequate level of protection we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may enter into data sharing agreements that contain up to date standard contractual clauses.
HOW DO WE STORE YOUR PERSONAL DATA AND FOR HOW LONG?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. Once our relationship with you has come to an end, we will retain your Personal Data for a period that enables us to:
If you are a Buyer, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.
If you are a Home Owner, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.
If you are a Financial Advisor, we keep your personal data for as long as you remain a registered user of the Nokkel App and for a period of six years thereafter. We will then dispose your information by deleting it, including any copies held.
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
HOW YOUR PERSONAL DATA IS KEPT SECURE
To help protect the privacy of your personal data, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
While we strive to protect your personal data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
AGE LIMIT FOR OUR USERS
The Nokkel App is not intended for children and we do not knowingly collect data relating to children. You must not use the Nokkel App unless you are aged 18 or older.
We collect your data automatically through cookies when you visit our website, in line with cookie settings in your browser. We may collect information about your computer, operating system and browser type for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual unless you choose to complete a form. We will only collect your data through the placing of non-essential cookies with your prior consent. More information on cookies and the data they capture is available in our Cookies Policy, accessible here.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
YOUR DATA PROTECTION RIGHTS
Under certain circumstances, by law you have certain rights.
Your right of access: you may request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Your right of rectification: you may request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Your right to erasure: you may request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Your right to object to processing: you may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Your right to restriction of processing: you may request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Your right to data portability: you may request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please let us know in writing.
CHANGES TO THE PRIVACY NOTICE
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
HOW TO COMPLAIN
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com. You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address: Information Commissioner's Office
Telephone: 0303 123 1113 (local rate)
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