Privacy
MN Associates registered at Suite 41/41 Victoria House, Main Street, Gibraltar GX11 1AA, with company number 102918 is the Data Controller with respect to the personal data collected from our website visitors and our customers/clients.
Our privacy policy is compiled in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the Data Protection Act 2004.
In line with this regulation, this Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be gathered, used, held and processed by us. Furthermore it explains your rights in relation to this data.
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
1. Contacting us about your Personal Data
Should you wish to speak with us regarding this Privacy Notice or how we treat your Personal Data, please contact us at privacy@mn-associates.gi
2. What Personal Data do we collect?
Information you give us
You can give us information about you by filling in our contact form on our website https://www.mn-assocciates.gi ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you contact us to request information about our services.
Information we collect about you
We only collect the Personal Data from you that is necessary for us to carry out the tasks expected of us effectively and for the greatest ease of communication with you.
This data that we hold varies according to our business relationship with you and your requirements, however it may comprise of any of the following:
· Contact information - name, address, telephone numbers, email address.
· Service requirements - if you are a potential property investor, we will request details about the type of property you are interested in purchasing and may include personal information to help us identify properties that are suitable for your needs. For payroll and financial services we will hold personal and financial / salary information.
· Contractual information –
· Personal data we collect automatically via your use of our website – e.g. via our use of cookies.
· Personal data we collect from other sources – i.e. technical data from third party analytics tools like Google Analytics.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can ask us to rectify or update your personal information at any time by emailing us at privacy@mn-associates.gi
3. How will we use your data
· Personal details such as name, address, email, telephone number etc are used for communication with you and are included in legal contracts if appropriate.
· To process and answer your enquiries or to contact you to answer your questions and/or requests.
· We may process your personal data for a different purpose and without your consent where it is necessary for us to comply with our legal obligations.
4. Our legal basis for collecting this data
We will use this information to carry out our obligations arising from any contracts entered into between you and us, whether verbally or in writing. On the basis of legitimate interest we will use this information to: provide you with the information, products and services that you request from us; to provide you with information about other products and services we offer that are similar to those that you have enquired about; to provide you with information about goods or services we feel may interest you.
5. Special categories of personal data
MN Associates do not collect any of the following list of ‘special categories’ of data, as classified by the GDPR:
· Racial
· Ethnic origin
· Political opinions
· Religious beliefs
· Philosophical beliefs
· Trade union membership
· Generic data
· Biometric data
· Health data
· Data concerning a natural person’s sex life
· Sexual orientation
6. How and where we store this data
Information you provide to us is stored on secure servers. Unfortunately, the transmission of information from you to us via the internet is not completely secure and although we do our best to protect your data, we cannot guarantee the security of data transmitted to our website. Once we have received your information, we follow strict procedures and take security measures to try to prevent unauthorised access.
7. Consent
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
We may disclose your personal information to third parties:
In the event that we buy any business, properties or assets, we may disclose your personal data to third party estate agents acting on our behalf.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or to protect the rights, property, or safety of MN Associates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8. Disclosure
We may share your personal data with third parties as detailed below for the purposes set out in Section 3 “How will we use your data.” We have agreements in place with our third parties that restrict their use of your personal data and we only allow third parties to use your personal data for specified purposes and in accordance with our instructions:
External third parties:
Service providers acting as processors based in Gibraltar who provide IT and system administration services and other services to enable us to perform our contract with you.
Website hosting providers.
9. Retention Period
MN Associates will process personal data for so long as is necessary for the purpose it is being processed for. We will review the personal data we hold and delete it securely when there is no longer a legal or business need for it to be retained.
In compliance with the prevailing laws (anti money laundering, proceeds of crime and tax etc.), we are obliged to hold any personal data pertaining to financial transactions for 6 years after the completion of the transactions. After this period, all personal data relating to inactive clients will be deleted.
10. Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
· Right of access – you have the right to request a copy of the information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organisation.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
· Right to judicial review - in the event that Chestertons Gibraltar refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in section 11. Complaints, below.
Should a third party be involved in processing your data (as stated in 8. Discloser), the above requests will also be forwarded on for action.
11. Requesting information concerning the personal data we hold about you
Any personal data information requests should be made in writing to privacy@mn-associates.gi
12. Complaints
In the event that you wish to make a complaint about how your personal data is being processed by MN Associates (or third parties as described in 8. Disclosure), or how your complaint has been handled, you have the right to lodge a complaint directly with the Gibraltar Regulatory Authority.
Contact details are as follows:
Gibraltar Regulatory Authority
2nd Floor
Eurotowers 4
1 Europort Road
Gibraltar
GX11 1AA
Telephone: (+350) 20074636
Fax: (+350) 20072166
Email: info@gra.gi
13. Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
14. Links
Our website or emails may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
15. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and where appropriate, notified to you by e-mail.