Who we are
Realtybundles CFP Ltd (trading as RealtyBundles), a company incorporated under the laws of England and Wales under company number 10762180 having offices at: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX ("We", “we”, “us”, “our” and “RB CFP”, as applicable) collects, uses and is responsible for certain personal data about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of those laws.
The personal data we collect and use
Information collected by us from you
- For Purpose A: full name; address; and date of birth;
- For Purpose B: full name; address; and passport number;
- For Purpose C: full name; address; and passport number;
- For Purpose D: full name; and email address;
- For Purpose E: full name; address; nationality; occupation; range of income; and email address;
- For Purpose F: full name; address; date of birth; net worth; financial details; passport; proof of address like utility bill; and any other details necessary to comply with the ML Regulations (each and collectively, the “KYC Information”);
- For Purpose G: full name; country of location; and email address; and
- For Purpose H: full name; and email address.
Information collected from other sources
The following information is the only personal data that we obtain from other sources:
- personal data in support of Purpose F, including without limitation the KYC Information referenced above, from services that provide such information, and any information that is publicly available; and
- Personal data in support of Purpose F, Purpose A, Purpose B and Purpose C from Mangopay S.A, a public limited company incorporated under the Luxembourg law and listed under number B173459 in the Luxembourg Trade and Companies Register.
Who we share your personal data with
We routinely share:
- All the personal data we collect in support of Purpose G mentioned above with the entity that operates www.zapier.com;
- All the personal data we collect in support of Purpose F where a third party properly requests such information from us in support of their compliance with the ML Regulations;
- Your full name, address and passport number with the entity that operates www.docusign.com in support of Purpose B; and
- All your personal data collected in support all the Purposes to the contractors of BundlesLab KFT, one of our main contractors, supporting an aspect of every Purpose, and which has the following principal address: Cg. 01-09- 982269, Hungary.
None of the above third parties are based outside the European Economic Area. We will share personal data with law enforcement or other authorities if required by applicable law. We will not share your personal data with any other third party.
Whether information has to be provided by you, and if so why
The personal data we obtain from you in support of Purpose G does not have to be provided by you to continue to be a user of the Website. In the event you do not provide us with the information we request, as detailed herein, in support of Purpose G, we shall not send you any marketing, promotional and/or business development communications.
Subject to a Requirements Notice (as defined below), the provision of all other personal data referenced herein that we process for any other Purpose other than Purpose G, is required to enable us to support the applicable Purpose.
The “Requirements Notice” shall mean where we inform you at the point of collecting information from you, that you are not required to provide the information to us.
How long your personal data will be kept
- We will hold all the information referenced herein that we collect in support of Purpose F for 5 years, or for as long as necessary to comply with the ML regulations if not 5 years.
- We will hold all other personal data of yours we collect for every other Purpose, for as long as necessary to enable the running and completion of the applicable Purpose.
Reasons we can collect and use your personal data
- The lawful bases for the processing of all personal data we collect in support of Purpose G is the explicit consent provided by you to us via the Website or via email.
- The processing of all personal data we collect in support of Purpose F is necessary to enable RB CFP to comply to the ML Regulations.
- The processing of all personal data we collect in support of every other Purpose (excluding Purpose G and Purpose F, for the avoidance of doubt) is necessary in support of the execution, performance and enforcement of the terms and conditions of the Website between you and RB CFP.
Transfer of your information out of the EEA
We will not transfer your personal data outside the European Economic Area (EEA).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal data;
- require us to correct any mistakes in your information which we hold;
- require the erasure of personal data concerning you in certain situations;
- receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- object at any time to processing of personal data concerning you for direct marketing;
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- object in certain other situations to our continued processing of your personal data;
- otherwise restrict our processing of your personal data in certain circumstances; and
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- let us have enough information to identify you (e.g. account number, user name, registration details);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information to which your request relates.
If you would like to unsubscribe from any promotional email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the promotional email newsletter. It may take up to 1 day for this to take place (but usually happens automatically).
Keeping your personal data secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on 06 October 2017 and last updated on 22 May 2018.
We may change this privacy notice from time to time, when we do we will inform you via email to the email address you have provided us.
How to contact us
Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).