Introduction
MOVA Property respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how MOVA Property collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for our service.

This service (website) is not intended for children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at above 18 years of age OR that you are the parent or guardian of such a minor and consent to such minor dependent’s use of Services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly remove such data from our records. If a user becomes aware of any data we may have collected from children under 18 years of age, please contact us at dpo@movaproperty.com. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other privacy notices provided and is not intended to override them.

Controller

The data controller responsible for your personal information for the purposes of the applicable GDPR protection law is:

MOVA Property is the controller and responsible for your personal data (collectively referred to as "MOVA Property", "we", "us" or "our" in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity:  MOVA Property 

Name or title of DPO: MOVA Property DPO

Telephone # 020 8133 0801

Email address: dpo@movaproperty.com

Postal address: Kemp House 128 City Road, London, UK ,EC1V 2NX

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Our Data Protection Officer:

Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.

If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to 

Name or title of DPO: Kevin Bartom

Telephone #  020 8133 0801

Email address: dpo@movaproperty.com

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 09 February 2023.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. The data we collect about you

Personal data, or personal information, includes any information from an individual from which that person can be identified. This does not include data where the identity has been removed (anonymous data). If you are identified or identifiable, directly or indirectly from any data we process, it is not personal data unless it ‘relates to’ the user from which the data is collected.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, date of birth and any other data that you may input into the Personal Safety App to assist in an emergency situation.  
• Contact Data email address and telephone numbers. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
• Profile Data includes your username and password. 
• Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose(s). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data in a way that may directly or indirectly identify a user, this combined data will be considered personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (including but not limited to details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.

If you fail to provide personal data:

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the product or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

1. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact details by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: 
• apply for our products or service(s)
• create an account on our website 
• subscribe to our service(s)
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. 
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  1. analytics providers such as Google based outside the EU;
  2. search information providers.
• Contact and location services from the app

1. How we use your personal data

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract and/or services we are about to enter into or have entered into with you. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
• Where we need to comply with a legal or regulatory obligation. 

Consent: We may process your information if you have given us permission (ie. Consent) to use your personal information for a specific purpose. You may withdraw your consent at any time. 

Generally, we do not rely on consent as a legal basis for processing your personal data. 

Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Analyse how our Services are used so we can improve them to engage and retain users. 
• Diagnose problems and/or prevent fraudulent activities. 
• Understand how our users use our products and services so we can improve user experience

Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

Purposes for which we will use your personal data:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

You will not receive marketing communications from us .

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the MOVA Property for marketing purposes.

Cookies
What is a cookie? It’s a file which has within it an identifier (i.e. a combination of letters and numbers) that a web server sends to a browser to be stored by that browser. This assists the server in more quickly identifying the browser – as each time that this browser requests a page from the server it sends this identifier back to the server. We may use both "session" cookies and "persistent" cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date. We will use the session cookies to: keep track of you whilst you navigate the website; keep track of items in your shopping basket; prevent fraud and increase website security; and other uses. We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and other uses. We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http://www.google.com/privacypolicy.html. Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for other reason(s) and those reason(s) are compatible with the original purpose(s). If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If you require further information as to how the processing for a new purpose is compatible with original purpose(s), please contact us directly.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. International transfers

We may transfer your data outside the European Economic Area (EEA), for legitimate IT purposes such as storage with our 3rd Party providers who have servers outside of EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. 
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

1. Data security

We have put in place appropriate and reasonable technical and organisational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

While we have stringent safeguards and efforts to secure your data, no electronic transmission over the internet or information storage technology can be guaranteed 100% secure. Please note that we cannot promise or guarantee that hackers, cybercriminals, and/or other unauthorised third parties will not be able to defeat our security measures and improperly collect, access, steal and or modify your personal data. While we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law, such as legal, tax, accounting, or other 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

When we no longer have ongoing legitimate business needs to process your personal information, we will either delete or anonymise such information or, if this is not possible (ie. Your personal information is stored in backup archives), we will will securely store your personal information and isolate it from any further processing until deletion is possible.

1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data. 
• Request correction of your personal data. 
• Request erasure of your personal data. 
• Object to processing of your personal data. 
• Request restriction of processing your personal data.
• Request transfer of your personal data. 
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties

• Service providers acting as processors Amazon AWS who provide system infrastructure, Data Storage and system administration services. 
• Professional advisers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL PRIVACY RIGHTS

In some regions (like EEA, UK, Canada and US)…

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data, which may be express/implied consent depending on the applicable law. However, please not that this will not affect the lawfulness of any processing carried out before your withdrawal consent nor when the applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent at any time by contacting us using the contact details provided in the section ‘IMPORTANT INFORMATION AND WHO WE ARE’ 

Opting out of marketing and promotional communications:

Cookies and similar technologies: 

We use cookies and similar tracking technologies (like web beacons and pixels) to save your preferences and track your usage of our website . [WC10] Cookies are small data text files stored by your browser. Some web browsers are set to accept cookies by default. You can adjust your browser settings to refuse cookies but please note that this may reduce the functionality of our website. Unless you alter your settings or actively bar cookies by other means, you are accepting we will be using cookies during your session at moveproperty.com. You can delete cookies via your browser settings.