This is your guide as to how your personal data is managed by Broll. Data privacy is taken very seriously by us. This document outlines our approach under the General Data Protection Regulation 2018 (GDPR). In this notice we explain how we collect personal information about you, how we use it and how you can interact with us about it.
Who are Broll?
Broll Auction Limited with a registered address OF Atholl Square, 116 Katherine St, Sandton Ext 3, Johannesburg, 2196
Why do you collect information about me? What information will you collect?
There are a number of reasons why Broll collect information. We need to know how to contact you, we need to be certain of your identity and we need to understand your circumstances so that we can offer you the best possible customer experience.
The type of information that Broll may collect from you includes:
How do you collect information about me? And when do you do so?
We collect information about you in a number of different ways. Some examples include:
How do you use my information?
We may use your personal data for matters such as confirming your identity, to help us in the processing of an application for one of our services or to improve your customer experience with us. Your data is used to manage and administer your account. Your data is also used to process transactions. An example is where you have provided us with your credit or debit card information or if you have provided us with your bank account details. We may use your data to contact you by post, phone, text message, email or social media using our website or other means but not in a way that is contrary to your instructions to us, legitimate interest or contrary to law. We may monitor and record our conversations when we speak on the telephone (to check your instructions to us and for training and quality purposes) but will advise you if we are doing so. Your data may also be used to recover debts you may owe and also to manage and respond to a complaint or appeal that you have. We may also use your data to manage our business for our legitimate interests, such as gathering location information from your mobile phone or other electronic device you may use to interact with us. Another legitimate interest of Broll is to conduct marketing activities such as direct marketing (provided that you have not objected to us using your details in this way) and research, including customer surveys, analytics and related activities. Your data may be used to carry out strategic planning and business portfolio management. This could include compiling and processing your information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand trends in our customer behaviour and to understand our risks better, including providing management information, operational and data risk management. We may use your data to protect our business, reputation, resources and equipment, to manage network and information security (developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services). We protect your information with security measures under laws that apply and we meet international standards in doing so. We keep our equipment, files and buildings secure. Personal data could be used to prevent and detect fraud, dishonesty and other crimes (such as preventing someone trying to steal your identity), including using CCTV at Broll office premises. Broll may in the future wish to sell, transfer or merge part or all of its business or assets or to buy a new business or the assets of another business or enter into a merger with another business. If so, we may disclose your personal information under strict duties of confidentiality to a potential buyer, transferee, merger partner or seller and their advisers, so long as they agree to keep it confidential and to use it only to consider the possible transaction. We need to use your information to manage and administer legal and compliance matters within Broll, including compliance with regulatory, legislative and voluntary codes of practice to which we have committed. We use your data to comply with your information rights, to establish your identity and to comply with laws and regulations concerning the prevention of money laundering, fraud and terrorist financing. As a result, we may need to disclose information to government and other statutory bodies. Your data may be used to comply with binding court orders, search warrants, requests to assist the Gardai with the investigation or prevention of an offence and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies. In relation to properties which we offer for sale, legal documentation is uploaded onto our website by Solicitors acting on behalf of Vendors. This documentation is uploaded for the sole purpose of allowing interested parties to carry out due diligence prior to placing a bid in relation to a property. Legal documentation will generally only be available to view for the marketing period relating to an auction, unless a property has sold prior to, or is withdrawn prior to, the auction. If a property is unsold at auction the legal documents will remain available for a 7 day period only post the auction.
Does Broll use automated processing or analytics? What is the legal basis?
We do not use automated processing in relation to the information we collect from you as part of our business.
Broll use analytics for statistical purposes. This enables us to make more informed business decisions, including improving the quality of services we can offer.
Do you share my information with anyone else?
We only share your information with a certain number of other parties and only as necessary. Examples of information sharing here include:
What about links on your website to other sites and social media?
Our Site may, from time to time, contain links to and from other websites and web platforms. In addition, third parties websites may also provide links to our Site. If you follow a link to any of those websites or web platforms, please note that those websites and web platforms have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites. We do not accept, and we disclaim, any responsibility for the privacy statements and information protection practices of any third party website (whether or not such website is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third party website’s privacy statements before you submit any personal data to their websites.
How long do Broll hold onto my information?
The length of time we hold your data depends on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data we hold about you, whether the data is required for a legal dispute and whether you or a regulatory authority ask us to keep it for a valid reason.
As a general rule, we keep your information for a period of 8 years. However, if you request that Broll delete your data (prior to this 8 year period elapsing) we shall process your request unless there is a valid reason not to delete the data (such as a requirement to hold onto your data as we have a legal obligation to do so).
What happens if I do not provide requested information to Broll?
Sharing information with us is in both your interest and ours. We need your information in order to provide our services to you, fulfil any contracts we have with you, to manage our business for our legitimate interests and to comply with our legal obligations.
You can choose not to share information with us but must understand that this may limit the services we are able to provide to you. We may not be able to provide you with certain services that you request. For example, if you do not provide us with all requested information when registering for an auction we may not be able to approve you to bid on a property.
What is the legal basis for Broll using my information?
We will use your data and may share that data where:
Does Broll process my information outside the South AfricanEconomic Area (EEA)?
Your information is stored on secure systems within the premises of Broll and with providers of secure information storage. Broll do not generally transfer information about you outside the EEA.
In certain circumstances, we may allow the transfer of information about you outside the EEA by our service providers, but only if they agree to act solely on our instructions and to protect your information to the same standard that applies in the EEA. Where we authorise the processing/transfer of your personal information outside of the EEA, we require your personal information to be protected to at least Irish standards.
What rights do I have under GDPR?
You have several rights in relation to how we use your information and we have significant obligations in this regard.
You have the right to:
We shall process your request without undue delay. In most instances, we will process your request within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar month period. Should this be necessary, we will explain the reasons why.
You also have the right to complain to Broll, the Data Protection Commissioner or another supervisory authority. If you have a complaint about the use of your personal information, please let Broll know and we shall seek to resolve your issue as soon as possible. If you wish to make a complaint to Broll you may do so in person, by telephone, in writing or by email. Please be assured that all complaints received by us will be fully investigated. We ask that you supply as much information as possible to help us to resolve your complaint quickly.
How do I contact Broll and/or your Data Protection Officer?
Telephone: +27 (87) 700 8289
Address: Atholl Square, 116 Katherine St, Sandton Ext 3, Johannesburg, 2196
Can I contact anyone else?
If you are not satisfied with how Broll are dealing with your complaint you can contact the THE INFORMATION REGULATOR (SOUTH AFRICA) at http://www.justice.gov.za/inforeg/.
Tel: 012 406 4818
Address: SALU Building, 316 Thabo Sehume Street, PRETORIA