PRIVACY POLICY ACCORDING TO GDPR
Introduction
You should feel confident about our processing of your personal data. Your trust in us is important and we respect your privacy and right to control your personal data. The trust of our customers is of the utmost importance to us. This trust is based, among other things, on how we handle the information we collect about you as a customer and our ability to protect your privacy. The personal data policy describes how we collect and use personal data, for what purpose it is collected and what you as a customer have the right to request from us for that processing. We have appointed a Data Protection Officer to ensure compliance with applicable data protection legislation.
This privacy policy applies when you use websites and services included in websites administered by us. We carry out all collection and processing of personal data in accordance with applicable privacy legislation.
Information on the data controller
Residence Fastighetsmäkleri Sverige AB, corporate identity number 556632-3019, with address Sturegatan 24 BV, 114 36 Stockholm, ("Residence Christie's") alternatively referred to as "we", "our" or "us" in the running text, is the controller of the personal data collected on this website. The controller is the person who, alone or jointly with others, determines the purposes and means of the processing of personal data and who is responsible for ensuring that the processing of personal data is carried out in accordance with applicable privacy legislation.
Residence Christie's is part of a group and operates and collaborates with partners with whom we share personal data such as name, telephone, SMS, e-mail address and, where necessary, social security number and address, referred to as "personal data", in order to provide you with estate-related products and services.
In order to ensure that the possibility of exercising your rights under applicable privacy legislation is not abused by others to your detriment, Residence Christie's has a responsibility under the General Data Protection Regulation to take all reasonable steps to ensure your identity when contacting you about your personal data. Depending on the nature of the contact, we may therefore require you to provide appropriate proof of your identity.
You can contact us in the following ways;
E-mail: [email protected]
Letters sent by post: Data Controller, Residence Christie's , Sturegatan 24 BV, 114 36 Stockholm.
Telephone: 08-662 68 00, extension data controller.
What is personal data?
Personal data is any information that can be directly or indirectly linked to a natural living person. Examples of personal data are name, address, location data, personal or other identification number, telephone number, e-mail address, IP number and image.
What personal data do we collect?
The personal data we collect is mainly the personal data you provide when you use our digital services and data directly from you.
Data collected when viewing and using our digital services
When you register for a viewing of a property on our website, make an offer on a property or if you contact us by email, by phone, our website and social media, if you are or register as a subscriber to digital
services, we collect the personal data from you that we need to be able to handle your offer, registration for a viewing or subscription to newsletters. When you use our digital services, we collect information about how you navigate the service, what type of property and location you are interested in.
Data collected from someone other than yourself
When registering for a viewing of a property or for our housing service, a visitor may provide personal data about other visitors in connection with joint visits to viewings or to obtain information about properties. We assume that the person providing the information has the consent of the person concerned to provide this information. If someone else has made such a request that includes you, we will collect personal data about you from that person. To keep your personal data up to date and accurate, we may need to obtain information from private and public records.
Data provided during personal contacts
For example, when you contact us via our customer service, via e-mail, telephone, when visiting our viewings of homes, registering via the website for a viewing, data created when you use any of our services, we may, depending on what the contact concerns, save information about you that is needed to help you and solve your case, such as booking a viewing. Such personal data may be, for example, name, telephone number, address, or e-mail address. The same applies if you contact us to inquire about or order any other service from us, for example regarding advertising or our viewings where your personal data may be saved in your capacity as a contact person.
If you use social media integrated with our website, this social media will provide us with certain information about you, such as your name and email address. Your activities on our website may also be posted on the social media platform. We may also receive information from our partners, for example, an advertiser may provide us with information about what happened after you clicked on an advertisement for new homes that appeared on our website.
Collaborations
We operate through sister companies and partners. In order to offer housing-related services and products such as brokerage services, mortgages, insurance, etc. we share personal data with companies within the group and our partners. The processing is based on a balance of interests and is necessary to meet our and companies within the group and our partners' legitimate interest in offering you housing-related services and products.
The purposes of our processing
The overall purpose of our processing of your personal data is to administer your access to, and use of, our services and to develop and improve our business and your customer experience.
Administration of services
We use your personal data to administer and fulfill services offered on our website, respond to inquiries, perform services you have ordered from us and to make reservations for viewings of homes. If you are a subscriber to our newsletter, we use your personal data to administer it and the offers you receive. Your data is also used to provide you with service if you have questions or want to make complaints.
Dissemination of information
When you have entered into an agreement, reserved a place to view a property, made an offer for a property or responded to an inquiry or signed up for our newsletter, we will use your personal data to send you confirmation of the matter in question. Such mailings will be sent to the e-mail address or mobile phone number you provided. We may also use the data to provide you with information about upcoming viewings or offers or to ask you questions about your visit after it has ended.
Developing our services
We may use personal data to analyze and to develop and improve our offers and services. This applies in particular to our digital services, where we analyze user behavior to improve our functions and their presentation in order to make them more user-friendly. This is mainly done through analysis of anonymized data at an aggregated level, but in exceptional cases personal data may be used when relevant.
Marketing and promotion
Customer data may be used in marketing contexts by us, other companies in the group or to companies outside the group with which we cooperate for direct marketing or other advertising via mail, e-mail or SMS. In some cases, we share data with our partners so that they can, for example, adapt offers and marketing to you. We enter into agreements to ensure that such partners process data in accordance with applicable privacy protection legislation.
Personification
We may use information about our users for so-called personalization. This means that we use information collected about you and your use of our services to influence how the content of the website looks when you visit us or to provide you with recommendations, customized services and relevant advertisements based on your interests and choices when using our services via email, text message or otherwise. This may include recommendations about homes or services based on what you have visited or what other users have shown interest in. For this personalization we also use cookies, see information on our website. In no case does the personalization form the basis for automated decision-making.
At any time, you have the right to request that we restrict the processing of your personal data or that it not be used for direct marketing purposes, free of charge or at no cost, see below under "Rights".
Legal obligation
Personal data is also used by us to enable us to comply with our legal obligations, e.g. for accounting purposes.
Grounds for our processing, recipients of personal data and erasure
We process your data lawfully. Your personal data may be processed on various legal grounds, e.g. to fulfill our contract with you as a customer, through a consent given by you or based on a balance of interests. This means that even if you withdraw your consent and it has expired, your personal data may still be processed based on another legal basis. The same personal data may be stored in different places for different purposes. Data deleted from one system may remain in another system where it is stored under a different legal basis or for another purpose where the personal data is still needed.
If the legal basis for our processing is based on a balancing of interests, our assessment is based on our legitimate interest to be able to provide customers with whom we have an active customer relationship information about offers and services relevant to the customer through direct marketing.
Your personal data will not be stored for longer than is necessary to fulfill the purposes set out in the policy below. The retention/deletion period varies depending on the purpose of the data and our legal obligations. Your personal data is deleted or anonymized when it is no longer relevant for the purposes for which it was collected.
We use various IT services and systems in our operations. Internally, we process personal data in our brokerage and sales system and in our customer database. Some of these systems store information in hardware that is installed locally with us and then only our staff have access to the data. Some data is stored with our external cloud service providers and consultants or in cloud solutions and involves us transferring personal data to the provider, in which case the provider is our data processor who processes the data on our behalf and exclusively according to our instructions and requirements for the processing of personal data.
For example, if you book a viewing, register interest in a property or create a property watch, your personal data is processed by external service providers. We are part of a group and personal data is shared with subsidiaries and partners, see the section on partnerships.
We use proprietary systems for personalization and analysis of user behavior. It is mainly data collected through cookies that are processed anonymously at an aggregated level.
The policy below describes the purposes, categories, grounds for processing, deletion periods (purging) etc. for our processing of your personal data.
Rights and entitlements
Your right to be informed about what is registered
You have the right to request information from us about what data we have registered about you and for what purpose it is stored. Contact details for such requests are provided above under the heading "Data Controller".
In the event of a request for information about the data we have registered, we will, in order to protect your privacy, require you to provide appropriate proof of your identity. The request should therefore be made in writing in a document signed by you, i.e. not by e-mail or telephone.
Right to rectification or erasure
You have the right to request that inaccurate personal data we hold about you be rectified. If the personal data is no longer necessary for the purpose for which it was collected or you have withdrawn your consent on which the processing is based (see below), you also have the right to request that the personal data be erased.
Withdrawal of consent
To the extent that our processing of your personal data is based on consent given by you, you have the right to withdraw your consent at any time. Upon withdrawal, we will delete the personal data and cease the processing covered by the consent.
As stated above under "The legal basis for our processing", our processing may be based on more legal bases. This means that even if you withdraw your consent, the personal data may still remain with us for other purposes based on a different legal basis.
Right to object, including to direct marketing
To the extent that our processing of your personal data is based on a balance of interests, you have the right to object to our processing, including extensive profiling.
You also have the right to request that the personal data we have stored about you not be used for direct marketing.
Right to data portability
You have the right to request that personal data that you have provided to us be transferred to another controller in a machine-readable format.
Complaints to the supervisory authority
If you believe that your personal data has been processed in breach of the applicable regulations, you should notify us as soon as possible. You always have the right to lodge a complaint about our processing of your personal data with a supervisory authority, which in our case is the Swedish Data Protection Authority. For contact details, see www.datainspektionen.se.
Changes to the privacy policy
This privacy policy may be updated from time to time. You will always find the latest version on this page. However, we will notify you if we make material changes that require your consent.
Grounds for our processing, recipients of personal data and erasure
See below what personal data we collect about you and for what purpose.
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Direct marketing, see also below. | Email, Phone number, Address, Name | 12 months | From the date of entry. | Balancing of interests. The legitimate interest of the processing is to encourage our buyers to recommend us to potential sellers. | Guidance from the Data Protection Authority on the retention of personal data. |
| Measures to prevent money laundering and terrorist financing.fulfilling other legal obligations, such as keeping records | Account number, Name, Address, Social security number, Copy of ID document.Account number, name and fee. | 5 years7 years | From the moment that measures to achieve customer awareness are taken. | Fulfilment of a legal obligation: Processing is necessary for us to fulfill our legal obligations, e.g. the Anti-Money Laundering and Terrorist Financing Act (2017:630). | Retention period in accordance with the Act (2017:630) on Measures against Money Laundering and Terrorist Financing.from the end of the calendar year in which the relevant financial year has ended. |
| Administration of housing brokerage, (e.g. transfer from housing association, management of bank loans, etc. | Name, Social security number, Address, Email, Phone number, Loan details | 10 years | From the signing of the purchase agreement. | The processing is necessary to meet our legitimate interest and the buyer's legitimate interest in conveying the property to you.The processing of personal data is necessary for the purpose of the processing. | General limitation period of the Limitation Act (1977:1160). See below "Processing Other" on the processing of personal data that may be necessary to store for the management of legal claims. |
| Post-purchase follow-up with evaluation of the brokerage service (e.g. that the purchase went well), and administration and communication of offers via e-mail, SMS and social media, of own and partners' housing-related services and products (e.g. offers of valuation of housing, insurance, mortgages), final price and addresses of sales and administration of questions from buyers. | Name, Email, Phone number | 12 months | From the date of entry. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest to evaluate, develop and improve our service to our customers and to provide offers of accommodation-related services and products. | |
| Comply with the filing obligation under the Real Estate Agents Act. | All data necessary for the supervision of the FMI. | 10 years | From the date of entry. | Fulfilment of a legal obligation.The processing is required for us to comply with the Real Estate Brokers Act (2011:666) with reference to the Limitation Act. | The Real Estate Agents Act (2011:666) with reference to the Limitation Act. |
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Administration of valuation question.Valuation assignment. | Name, Social security number, Address, E-mail, Details of the dwelling, Messages. | 12 months10 years | From the completed valuation. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest to respond to your request for a valuation. Contract The processing is necessary for the performance of the contract for the valuation assignment with the potential seller. | Saved for e.g. answering questions from banks regarding valuationsPrescription law. |
| Direct marketing. Offers about our services and those of our partners, for example via email, SMS and social media. | Name, Email, Phone number | 2 years | From the moment the data is collected. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest in promoting our services and those of our partners. | An extension of the DPA's guidance on the retention of personal data. Home purchases take place at longer intervals than a normal purchase. |
| Comply with the filing obligation under the Real Estate Agents Act. | All data necessary for the supervision of the FMI. | 10 years | From the moment the data is collected. | Performance of a legal obligation.The processing is necessary for the performance of legal obligations. | The Real Estate Agents Act (2011:666) with reference to the Limitation Act. |
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Direct marketing and offers about our and our partners' services and, where applicable, products, digitally e.g. via email, SMS and social media. | Name, Email, Phone number | 2 years | From the moment the data is collected. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest in providing housing offers, services and related products. | Extension of the DPA's guidance on the retention of personal data. Home purchases are made at longer intervals than a normal purchase. |
| Keeping a register of speculators, brokering objects, communicating other objects to the speculator based on interest shown. | Name, Email, Phone number | 2 years | From the moment the object is sold. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest in communicating with speculators who have chosen to contact us. | Assessment based on the DPA's statement on direct marketing with corresponding extension of time see above. |
| Keeping a list of tenders | Name, Email, Phone number, Bids submitted | 10 years | From the end of the bidding process. | Performance of a legal obligation.Processing necessary for compliance with a legal obligation. | The Real Estate Agents Act (2011:666) with reference to the Limitation Act (1977:1160). |
| Manage the expression of interest for a specific object, communication about objects, bids submitted, satisfaction survey after the viewing. | Name, Email, Phone number, Social security number. | None3 months | A) From the time the property is sold. If the speculator has reported monitoring of objects, the data is saved until these objects have been mediated.B) From the completed survey. | Processingnecessary for the purposes of our and the seller's interest in managing the expression of interest Processing necessary for the purposes of our legitimate interest in obtaining the speculator's opinion on our services | |
| Keeping of tender records and archiving obligations. | All data necessary for the supervision of the FMI. | 10 years | From the moment the object is sold. | Performance of a legal obligation.The processing is necessary for the performance of a legal obligation under the law. | The Real Estate Agents Act (2011:666) with reference to the Limitation Act. |
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Contact in the framework of the mediation mission. | Name, Email, Phone number | None | Contact details of a related party should be deleted immediately after accession. | Performance of contract.The processing is necessary for us to perform the contract. | |
| Comply with the filing obligation under the Real Estate Agents Act. | All data necessary for the supervision of the FMI. | 10 years | From the date of entry. | Theprocessing is required for us to comply with the Real Estate Agents Act (2011:666) with reference to the Limitation Act. | The Real Estate Agents Act (2011:666) with reference to the Limitation Act. |
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Digital administration of housing surveys and final prices. | Name, Email, Phone number, registered alerts | During the period from monitoring to deregistration. | From the time of notification/monitoring. | Performance of contract The processing is necessary for the performance of the housing and price monitoring contract. | |
| Digital administration and communication on housing/properties, in social media via the use of the website. | User-created data, may also include e.g. visit history and visited objects. | Temporary. | Balancing of interests. The processing is necessary for the purposes of our legitimate interest in communicating with speculators who have chosen to contact us. |
| Purpose | Categories of data | Storage period | Date and time | Legal basis | Basis for retention period |
|---|---|---|---|---|---|
| Establishing, defending, asserting legal claims, managing and administering complaints, grievances, legal disputes. | Name, Email, Phone number, data, treatments performed missions, services. | The applicable limitation period for each measure. | Balancing of interests. The processing is necessary for the purposes of the legitimate interests pursued in the administration, establishment, exercise and defense of legal claims. |
This policy applies from 2018-05-25