Privacy Policy

Estama Ltd. – Privacy Policy

Registered name: Estama Ltd.

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain

Contact details

Post

Estama Ltd., 5-6 Clipstone Street, London, W1W 6BB, United Kingdom

Email

info@estamainvestment.com

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Gender
• Occupation
• Date of birth
• Third party information (such as family members or other relevant parties)
• Financial data (including income and expenditure)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Credit history and credit reference information
• Criminal records data (including driving or other convictions)
• Records of meetings and decisions
• Website user information
• Criteria and preferences for real estate investments

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Purchase or account history

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Identification documents
• Client account information
• Any other personal information required to comply with legal obligations
• Criminal offence data
• bank account statements, information on companies owned and controlled by an individual

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Account information
• Purchase or service history
• Photographs
• Relevant information from previous investigations
• Customer or client accounts and records
• Financial transaction information
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients for information updates or marketing purposes, to comply with legal requirements and for dealing with queries, complaints or claims are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • To register you as a new customer – necessary for performance of a contract with you
  • To deliver our property related services to you – necessary for performance of a contract with you
  • To process and deliver our services including:

(a) Manage payments, fees and charges – necessary for performance of a contract with you

(b) Collect and recover money owed to us – necessary for our legitimate interests (to recover debts due to us)

• To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy – necessary for performance of a contract with you

(b) Asking you to leave a review or take a survey – necessary to comply with a legal obligation

(c) Giving you an opportunity to provide your comments and feedback on our website – necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to generate customer interest in our services and to better understand customer reactions and feedback)

• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) – necessary for (a) our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise and (b) to comply with a legal obligation
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you – necessary for our legitimate interests (to study how customers use our products/services, to collate customer feedback and reactions, to develop them, to grow our business and to inform our marketing strategy)
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences – necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  • To make suggestions and recommendations to you about goods or services that may be of interest to you – necessary for our legitimate interests (to develop our products/services and grow our business)
  • To undertake our required identity verification and anti-money laundering checks – necessary (a) for performance of a contract with you and (b) to comply with a legal obligation (including anti-money laundering legislation)

Where we get personal information from

• Directly from you
• Regulatory authorities
• Legal bodies or professionals (such as courts or solicitors)
• Debt collection agencies
• Publicly available sources
• Credit reference agencies
• Providers of marketing lists and other personal information
• Suppliers and service providers
• Third parties:
  • clients
  • real estate agents

How long we keep information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Who we share information with

Data processors

onOffice GmbH

This data processor does the following activities for us: store client and prospective client information in cloud based CRM database

Microsoft

This data processor does the following activities for us: host files in cloud storage, provide email server

Others we share personal information with

• Debt collection agencies
• Other financial or fraud investigation authorities
• Insurance companies, brokers or other intermediaries
• Professional or legal advisors
• Insolvency practitioners
• Regulatory authorities
• External auditors
• Organisations we’re legally obliged to share personal information with
• Professional consultants
• Third parties:
  • sell-side clients, e.g. where we have offered you a property we may disclose to the selling client the identities of who was offered the property, their preferences and details of our discussion of the property

Sharing information outside the UK

Some companies that provide services to us run their services from outside the UK or the European Economic Area (EEA). We only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information it could be transferred, stored or processed in a location outside the UK and the EEA.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

18 November 2024