Privacy Policy
Privacy Policy
Last updated: July
31, 2023
We know that your personal
information is important to you and we are committed to ensuring it is kept
secure and used carefully. Below you will find a short summary of how and why we collect your
data, who we share it with, and what we’re doing to make sure your data is safe
and secure. You will also find details
of your privacy rights.
This is the privacy policy of Pangaea
Ltd. If we
change our privacy policy, we will notify you of those changes here.
Our Website may include hyperlinks to other
websites that are not operated or controlled by us. This privacy policy
only applies to our Website and we are not responsible for the content or the
privacy practices of third party websites.
What does Pangaea
Ltd. do?
Pangaea Ltd. is a privately
owned publishing company based in Waterford, Ireland. We provide
insight and advice on overseas real estate. We are part of a group of companies.
What personal information does Pangaea
Ltd. collect and why?
We collect information in order
to allow us to provide the services you request from us, and to personalise and
improve your experience of our services, Websites, and communications with you.
All such information is held on secure servers.
We only use personal data you
have given us or that we have collected from you when you visit our Websites
and order forms. We do not obtain personal information from or sell it to third
parties. We sometimes share your personal information with third parties, but
only to provide the services you have requested from us or to improve your
experience with us and make our business more responsive to your interests
and/or those of like-minded individuals or when you have specifically requested
that we do so (such as when you fill in a form requesting more information on a
particular real estate opportunity). We never release your personal information
to others for their mailing or marketing purposes. We may also gather
additional information about you that is publicly available to personalise and
improve your experience of our services, Websites, and communications with you.
The personal information that we may collect about you broadly falls into two
categories:
·
Information that you provide
We may ask you to provide personal information in order to
provide our services to you.
Sometimes,
you have specifically requested that we do this.—For example, if you want more
information on a particular real estate opportunity that we write about, you
can fill in your personal information on an online form provided and hosted by
Pangaea. If you do so, that personal information is automatically passed to
Pangaea’s Salesforce CRM database, and from there, it is passed automatically to
the real estate agent or developer that you are requesting more information
from. Similarly, if you connect with us via email or through the Real Estate
Trend Alert Concierge, requesting information on a specific real estate
opportunity or a real estate market, we will pass your query and personal
information to the real estate agent and/or developer covering that
opportunity/market.
The
personal information you are asked to provide, and the reasons why you are
being asked to provide it, will be made clear to you at the point you are asked
to provide it.
·
Information that we collect automatically
We
do not use cookies or similar technology on this site.
Who does Pangaea Ltd. share my personal information with?
We may disclose your personal information
to the following categories of recipients:
·
To
our group companies who provide data processing services to us, for example,
enhancing the security of our Website, or who process personal information for
the purposes described in this privacy policy or notified to you when we
collect your personal information. International Living Limited (based in
Waterford, Ireland) broadcasts the emails for our Real Estate Trend Alert
service, and provides customer service; Publishing Services LLC (based in Baltimore,
Maryland) provides the majority of the data processing services we use. The
group of companies may also use the data provided to improve your experience
with us, to help us tailor the content that we send you, or to reach
like-minded individuals that may be interested in our products. We also use
these services to determine your membership status, if you inquire via customer
service or the Real Estate Trend Alert Concierge for information on a Real
Estate Trend Alert members-only deal.
·
to
reputable third party service providers who provide additional data processing
services, for example, analysing data, providing marketing assistance, and
assisting with the processing of credit card and direct debit payments. They
have access to personal information needed to perform their functions, but may
not use it for other purposes. In
addition, they must process the personal information in accordance with this
privacy notice and as permitted by applicable data protection laws. A list of
these providers along with a short summary of the services they provide can be
found here:
·
Salesforce.com
EMEA Limited: when you request more information on a real estate opportunity
and fill in your personal information on one of our online forms, that information
is passed to Pangaea’s Salesforce CRM database, and from there it is
automatically passed to the real estate agent or developer offering that real
estate opportunity;
·
Real Estate Agents & Developers
that work with Pangaea: As above, when you request more information on a real
estate opportunity, Pangaea will pass that information (via our Salesforce CRM
database or via email) to the real estate agent or developer concerned.
·
Facebook.com, Google.com &
Instagram.com: For advertising purposes, we occasionally use information about
our customers to generate a “lookalike audience”, a similar audience of
prospective customers on Facebook, Google, or Instagram. This allows us to
target advertisements to potential customers on Facebook, Google, or Instagram
who appear to have shared interests or similar demographics to our existing
customers. We do this by uploading a list of email addresses to Facebook,
Google, or Instagram, and encrypting them before we upload. Facebook, Google,
or Instagram will match the data against their own customers and generate a
lookalike audience. The uploaded list is then deleted (not used for any other
purpose). If you wish to opt out of our use of your data to create “lookalike
audiences” on Facebook, Google, or Instagram, please email: msummerfield@pangearesearchgroup.com.
·
To any competent law enforcement body, regulatory, government agency, or
similar other third parties where we believe disclosure is
necessary(i) as a matter of applicable law or regulation, or (ii) to
exercise, establish or defend our legal rights; and
·
To any other person with your consent.
Legal basis for processing
personal information
Our legal basis for collecting
and using the personal information described above will depend on the
information concerned and the context in which we collect it.
We will normally collect personal
information from you where:
·
we
need the personal information to perform a contract with you (for example, your
email address when you ask for information on a real estate opportunity);
·
the
processing is in our legitimate interests and not overridden by your rights;
·
we
have your consent to do so (for example, to receive marketing emails from us
about another publisher’s publications or services which we think might be of
interest to you); or
·
We need the personal
information to comply with our legal obligations (for example, our tax and
audit requirements and other regulatory obligations)
If we collect and use your
personal information in reliance on our legitimate interests, this will
normally be to operate and improve our services, Website, and communications. It would also include responding to your queries,
undertaking marketing, or detecting or preventing illegal activities. We may have other legitimate interests and,
if appropriate, we will make clear to you at the relevant time what those
legitimate interests are.
How does Pangaea
Ltd. keep my personal information secure?
We use appropriate technical and
organisational measures to protect the personal information that we collect and
process. The measures we use are
designed to provide a level of security appropriate to the risk of processing
your personal information. Where we
share data with third parties, we ensure that your data will be kept secure and
will not be provided or sold to another party.
International data transfers
Your personal information may be
transferred to, and processed in, countries other than the country in which you
are resident. These countries may have
data protection laws that are different to the laws of your country (and, in
some cases, may not be as protective).
Specifically, third party service
providers operate in the United States and elsewhere around the world. This means that when we collect your personal
information we may process it in any of these countries.
However, we have taken
appropriate safeguards to require that your personal information will remain
protected in accordance with this privacy policy. These include implementing the European
Commission’s Standard Contractual Clauses for transfers of personal information
to our third party service providers, which require them to protect personal
information they process from the European Economic Area in accordance with
European Union data protection law.
Data
retention
We retain personal information we
collect from you where we have an ongoing legitimate business need to do so
(for example, to provide you with a service you have requested or to comply
with applicable legal, tax or accounting requirements).
When we have no ongoing
legitimate business need to process your personal information, we will either
delete or anonymise it or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely
store your personal information and isolate it from any further processing
until deletion is possible.
Your data protection rights
You have the following data
protection rights:
·
If
you wish to access, correct, update or request deletion of your personal
information, you can do so at any time by contacting us at msummerfield@pangearesearchgroup.com. We may not be able to delete your personal information if we
have to retain it in order to comply with our legal obligations, to perform a
task carried out in the public interest, to establish, exercise or defend any
legal claims or to exercise our right of freedom of expression and information.
·
In
addition, you can object to processing of your personal information, ask us to restrict
processing of your personal information or request portability of your personal
information. Again, you can exercise these rights by contacting us at msummerfield@pangearesearchgroup.com.
·
You
have the right to opt-out of communications we send you at any time. You can exercise this right by contacting us at
msummerfield@pangearesearchgroup.com.
·
If
we have collected and process your personal information with your consent, then
you can withdraw your consent at any time.
Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect processing
of your personal information conducted in reliance on lawful processing grounds
other than consent.
·
You
have the right to complain to a data protection authority about our collection
and use of your personal information.
For more information, please contact the Data
Protection Commission (“DPC”).
We respond to all requests we
receive from individuals wishing to exercise their data protection rights in
accordance with applicable data protection laws.
Updates to this privacy policy
We may
update this privacy policy from time to time in response to changing legal,
technical or business developments. When we update our privacy policy, we will
take appropriate measures to inform you, consistent with the significance of
the changes we make. We will obtain your
consent to any material privacy policy changes if and where this is required by
applicable data protection laws.
You can see
when this privacy policy was last updated by checking the “last updated” date
displayed at the top of this privacy policy.
How to contact us
If you have
any questions or concerns about our use of your personal information, please
contact us at msummerfield@pangearesearchgroup.com.
The data
controller of your personal information is Pangaea Ltd.