1. PRIVACY POLICY

1.1 This Privacy Policy (the “Policy”) sets out how we, Real Estate Balance Limited (further referred to as “REBL”, “our” or “we”), process the Personal Data of our website visitors, mailing list subscribers and participants in our research (each a “User”).

1.2 If you have any questions about this Policy, please contact our Data Controller at hello@realestatebalance.org


2. WHAT IS PERSONAL DATA AND WHAT DO WE PROCESS?

2.1 Personal Data (“Personal Data”) means any information relating to a person who can be identified either directly or indirectly. It may include name, address, email address, job title, employer, phone number, IP address, location data, banking details (if applicable) and other Personal Data.

2.2 For the purposes of our research, which includes but is not limited to the REBL Industry Survey and REBL NextGen Survey, Personal Data may also include personal characteristics that are protected under the Equality Act 2010, including age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. We will only ever ask for Personal Data for our research purposes to be shared with us on a voluntary and anonymous basis.


3. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

3.1 REBL processes Personal Data for reasons related to the legitimate interest of the organisation – a membership body to further equity, diversity and inclusion in UK real estate and its associated sectors. We will only process Personal Data in accordance with applicable laws, for the following purposes:

3.1.1 providing our services in a personalised way.

3.1.2 answering queries relating to any of our services, events, publications or information;

3.1.3 administering promotions that Users may have participated in;

3.1.4 enabling our suppliers and service providers to carry out certain functions on our behalf, including verification, technical, logistical or other functions;

3.1.5 sending personalised communications, where Users have agreed that we may do so, in order to keep them informed of our and our selected partner’s services, which we consider may be of interest to you;

3.1.6 serving personalised services obtained through the use of "Cookies" placed on User devices. Please see our Cookie Statement for more below;

3.1.7 developing and improving our services, for example by reviewing visits to our website and its various subpages, demand for specific services and User comments;

3.1.8 to undertake research in the legitimate interest of furthering equity, diversity and inclusion, and;

3.1.9 to comply with applicable laws, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law.

 

4.1 We process Personal Data based on legitimate interest. This is primarily related to our role as a membership body which aims to further equity, diversity and inclusion in UK real estate and its associated sectors and the necessary day-to-day operations of our organisation.

4.2 We process Personal Data based on consent. We use consent forms to transfer Personal Data provided to REBL from our website, emails and other systems to our Customer Relationship Manager (CRM). Consents are stored and documented in our systems, and we rely on consent in order to share information about REBL activities such as news, events and research with Users.

4.3 We process Personal Data based on contracts and agreements with REBL members, partners and suppliers.

4.4 We process Personal Data based on research. This includes but is not limited to the REBL Industry Survey and REBL NextGen Survey. Processing of anonymous Personal Data does not require a legal basis under Article 6 of the UK GDPR, but it is done in a manner that upholds the spirit of data protection principles.

4.5 We may also process Personal Data on other legal grounds, for example to comply with our legal obligations, resolve any disputes or enforce our rights.

 

5.1 Access to Personal Data processed by REBL is restricted on a need-to-know basis or as required by law. We may need to provide access to Personal Data collected by REBL with third parties in certain circumstances but only when in our legitimate interest.

5.2 All employees and third parties involved in the processing of Personal Data must adhere strictly to this Policy. REBL conducts due diligence on all involved in processing Personal Data to ensure their ability to comply with this Policy and applicable data protection laws. Any breaches of this Policy by employees or third parties may result in disciplinary action, including termination of employment or contract, and may also result in legal action where applicable.

5.3 REBL has implemented appropriate technical and organisational measures to ensure the security of the Personal Data we process. We are committed to doing all we can to protect and safeguard our website, CRM and other communication channels from unauthorised access. However, the nature of the internet and other risk factors, such as hacking, mean that we cannot guarantee that Personal Data processed by us will be absolutely safe.  

5.4 We will only retain Personal Data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need Personal Data for the reason it was intended, we will remove it from our systems and records. We may, however, need to retain Personal Data to comply with legal or regulatory obligations to which we are subject. The need to retain Personal Data is reassessed on a regular basis. Personal Data which is no longer required for any purposes will be disposed of securely and in a timely manner.

 

6.1 Users have various rights connected with REBL processing Personal Data:

6.1.1 Access. Users have the right to request a copy of the Personal Data we are processing about them, which we will provide in electronic format, where appropriate. We may require users to prove their identity before providing the requested information.

6.1.2 Correction. Users have the right to have their incomplete or inaccurate Personal Data rectified.

6.1.3 Deletion. Users the right to request that we delete their Personal Data. We are not obliged to do so if we need to retain such Personal Data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

6.1.4 Withdrawing consent. If Users have consented to our processing of their Personal Data, they have the right to withdraw their consent at any time, free of charge. To opt out of receiving correspondence from us, please contact us using the email address at the beginning of this Policy or by following the unsubscribe instructions in REBL’s emails.

6.1.5 Objection. Where the legal justification for our processing Personal Data is in our legitimate interest, Users have the right to object to such processing on grounds relating to their particular situation. We will abide by those requests unless we have compelling legitimate grounds for the processing which override the User’s interests and rights, or if we need to continue to process the Personal Data for the establishment, exercise or defence of a legal claim.

6.1.6 Making a complaint. Users have the right to lodge a complaint with the local data protection authority if they believe that we have not complied with applicable data protection laws. If you are based in, or the issue relates to, the UK, contact details for the Information Commissioner’s Office can be found at www.ico.org.uk

7.1 In order to collect the information as described in this Privacy Policy, we may use Cookies and similar technology on our website.

7.2 A Cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive, mobile phone or other device.

7.3 You can set your browser to notify you when you receive a Cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through websites may not function properly if your Cookies are disabled.

7.4 Cookies can be first party or third party Cookies. First party Cookies - Cookies that the website you are visiting places on your computer. Third party Cookies - Cookies placed on your computer through the website but by third parties, such as Google.

7.5 We use the following small number of Cookies on our website:

ASP.NET_SessionId

This cookie is a ‘session cookie’. It is used to keep track of a user’s actions as they move between multiple pages on the website, for the duration of their visit.
First party
Lifespan: Session

__utma

This cookie stores each user’s amount of visits and the time of the first visit, previous visit and current visit.
Third party
Lifespan: 2 years

__utmb

This stores how long a user stays on the site - when a visit starts and approximately ends.
Third party
Lifespan: 2 years