Introduction

This policy applies to all Hunt Estates Limited’s operations, including Christie’s International Real Estate/Hunt Estates. It applies to our websites, registration process, products or services that link to this policy or do not have a separate privacy policy.

The purpose of this privacy policy is to give you a better understanding of:-

• what information we collect;
• how we use that information;
• how this information is shared;
• your rights; and
• other useful privacy and security related matters.

We hope you take the time to read this policy. It is important to check back often for updates to this policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant service.

Who is the Data Controller?

Hunt Estates Limited, 9 New Street, St Helier, Jersey, JE2 3RA.

The Data Protection Officer (DPO)

Hunt Estates Limited has appointed a Data Protection Officer (DPO). Our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the ‘Your rights’ section below. You can contact our DPO at dpo@huntestates.com.

Website visitors

Like most website operators, we collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non- personally identifying information is to better understand how visitors use our website.

We also collect potentially personally-identifying information like Internet Protocol (IP) addresses for users completing forms on our website. We only disclose logged in user IP addresses under the same circumstances that we use and disclose personally-identifying information as described below.

We may also collect statistics about the behaviour of visitors to our website. For instance, we may monitor the most popular pages on the site. We do not display this information publicly or provide it to others.

Cookie collection

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies to help identify and track visitors, their usage of the website, and their website access preferences. Visitors to the website who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our website, with the drawback that certain features of the website may not function properly without the aid of cookies.

3rd-party Cookies used on this Site:

Google Analytics

Google Analytics collects information entirely anonymously. It reports website trends without identifying individual visitors.

You can opt out of Google Analytics without affecting how you visit our site. For more information on this, please see Analytics opt-out.

YouTube

YouTube uses the ‘PREF’ cookie to store information such as a user’s preferred page configuration and playback preferences like autoplay, shuffle content, and player size. For YouTube Music, these preferences include volume, repeat mode, and autoplay. This cookie expires 8 months from a user’s last use.

Some cookies are used to maintain and enhance a user’s experience during a specific browsing session. For example ‘YSC’ is used by YouTube to remember user input and associate a user’s actions. This cookie lasts for as long as the user keeps their browser open. The cookie ‘pm_sess’ also helps maintain a user’s browser session and lasts for 30 minutes.

Collection of initial Information

Collection of additional information and documentation

We may also collect the following additional information and documentation:-

• Property particulars, including residential address.
• Verification of identity documentation, e.g., passport or driving license.
• Verification of residential address documentation, e.g., utility bill or bank statement.
• Confirmation of your financial history, source of wealth and source of funds.
• Residential and employment status.
• Information from third party databases to comply with credit underwriting, legal and regulatory obligations.

Third party and publicly available sources

Not all the personal and financial information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, credit service providers (applicable to our lettings service only) and publicly available websites (i.e., social media platforms), to comply with legal and regulatory obligations.

How we use this information

We only process your data in the way you would reasonably expect us to. We use your data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our websites. We keep the information we hold about you to a minimum.

We will, from time to time, send you marketing material which may be of particular interest to you based upon your preferences, i.e., your desired location, property type or price category. These marketing messages will provide you with information about the products and services available to you via Hunt Estates Limited.

Except where we use your personal data for marketing purposes, on the basis of your prior written consent, and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.

How information is shared

Your personal and financial information may be transferred or disclosed to trusted third parties, for the processing of that personal information based on our instructions and in compliance with this policy and any other appropriately confidential and secure measures.

Our third-party service providers and partners include:-

• IT hosting platforms.
• Credit reference agencies (lettings service only).
• Regulatory authorities, government agencies and law enforcement agencies.
• Trading Standards and other consumer bodies.
• Auditors and accountants.

We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. We only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested. Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services.

Consent to processing and acceptance of this policy

By providing personal information to us as part of the registration process, you fully understand and expressly consent to the processing of that data as described within this policy. If you do not agree to this policy, please advise the DPO at Hunt Estates Limited.

Your rights

Under the General Data Protection Regulation (GDPR) and more specifically the Data Protection (Jersey) Law 2018, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.

• Access to personal data
  You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the ‘How to contact us’ section for information on how to contact us. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible but no later than within one month.
• Correction of personal data
  You can request us to rectify and correct any personal data that we are processing about you which is incorrect.
• Right to withdraw consent
  Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
• Right of erasure
  You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances and is not a guaranteed or absolute right. Any regulatory or legal requirement to retain your records will take precedence.
• Right to data portability
  This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation.
• Right to restrict processing of personal data
  You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
• Right to object to processing of personal data
  You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal or regulatory claims.
• Rights relating to automated decision making and profiling
  You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect, or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make any automated decisions of this nature.

Changes to the Privacy Policy

Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and at our sole discretion. We encourage visitors to frequently check our Privacy Policy. Your continued use of the website and the products and services after any change in this Privacy Policy will constitute your acceptance of such change.

How to contact us

For any requests related to your personal information or any of your rights referenced above, please feel free to contact us in one of the following ways:-

Filing a complaint

If you are not satisfied with how we manage your personal data, you have a right to make a complaint to the Jersey Office of the Information Commissioner.

Other useful privacy & data security related matters

Record retention

We retain personal information for as long as we reasonably require it for legal or business purposes. For the jurisdictions in which operate, and subject to us not having a legal or regulatory requirement, or a risk management reason for retaining your information for a longer period, your information will not be kept for longer than 5 years following that date on which your relationship with us ceases. We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.

Security

We recognise that online security and data protection is an area of vital importance for all our customers, so it is important to us that you have confidence in the security of your personal details. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and Hunt Estates Limited will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.