This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ is being used online. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your data.
Just like the majority of businesses, Johnson&Rommers Investment Consultants holds and processes a wide range of information about its clients and other persons who may be interested in Johnson&Rommers product and services.
This privacy notice applies to all Johnson Rommers operations within the EEA and all other locations, and explains what type of information we process, why we are processing it and how that processing may affect you.
The privacy notice is split into the sections listed below. The Glossary section explains what we mean by “personal data”, “processing”, and other terms used in this notice.
We may update this privacy notice from time to time, and will post any revised notice on this webpage. Where appropriate we may notify you by email or by a notice on our website that our privacy notice has changed but we recommend that you check this page regularly. Any changes will be immediately effective on posting.
Who we are▼
The company Johnson Rommers S.L. Investment consultants a Real Estate company located inside and outside the EEA.
Johnson Rommers S.L. (Spanish company number B93583656) of Urb. Andasol, Av. Andasol, Ctra. N- 340, km 189. 29604 Marbella Spain, is the primary Data Controller for the purposes of EU Data Protection Legislation.
How and when do we collect your personal data?
- Collection directly from you in response to our request
- Most of the personal data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online) for example:
- when you agree to market or sell your property through Johnson Rommers or ask us to perform a valuation;
- when you express an interest to one of our staff or representatives in buying or selling real property;
- when you subscribe to JR’s Magazine;
- when you sign up on christiesrealestate.com or luxurydefined.christiesrealestate.com to receive news about real estate and upcoming events relating to particular areas of interest;
- when you fill out a form on johnsonrommers.com;
- when you attend a Johnson Rommers event.
Automatic collection when you visit our premises or our website
Your image may be collected by Johnson Rommers if you attend our premises. We use CCTV at our salerooms and offices for the protection of our staff, our visitors and the property that we sell.
We collect data about your computer when you visit our website, which includes your internet address, your operating system and browser type. We use this information for our internal system administration, to help diagnose problems with our servers, to administer our website and monitor and improve the user experience.
We also collect data about you through cookies. A cookie is a simple text file that is stored on your computer or mobile device by our website’s server which allows our website to remember your preferences or transactions that are in progress. You can see more detail on cookies in our Cookies Policy.
Collection of data from other sources
- We may also obtain information about you and/or your property from other sources, for example:
- When someone introduces you to us;
- When we research real property, artwork or other objects and we find information about you in sources such as newspaper articles, exhibition catalogues, public auction results, or one of our contacts gives us feedback in relation to objects or persons they have been told about.
What personal data do we process and why?
We have set out below the types of personal data that we process, the purposes for which we use it and the legal grounds on which we process it. The Glossary contains more information about the legal grounds for processing.
Purpose Examples of personal data
(please note that the list is not exhaustive) Legal grounds for processing
To provide you with requested services(for example, listing/selling real property, property referral, events)
name, title, and contact details (including email address, postal address, telephone numbers)
your bank account details (if we need to pay you) or payment card details or bank transfer receipt (if you need to pay us)
the person or organization who has introduced you, and any fee they receive
details of the property to which the services relate
nature of the services including contractual terms
details of your insurance if your property remains at your risk
records of your communications with us
Performance of a contract
To evidence our compliance with legal requirements, (for example, knowing our clients and preventing money-laundering, payment of taxation and customs duties, anti-discrimination)
your date of birth, identification documents (including photo) and the results of identification verification checks
details of your past transactions (including any tax paid or tax withheld) and/or shipments (including any permits obtained or duties paid)
any requirements relating to CIRE’s obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs
any information relating to a dispute or legal proceeding
Compliance with a legal obligation
To keep you, our staff, and property on our premises secure
CCTV images
Legitimate Interests
To provide you with details about new properties that fit your search criteria, other events or types of property that interest you, and Christie’s wider services
your name, email address and/or postal address
your marketing and communication preferences (in your “My Portfolio” account, your christiesrealestate.com account preferences, or any hard copy or digital sign up)
your communications preferences for christiesrealestate.com and CIRE’s blog luxurydefined.com
Legitimate Interests (for clients who have previously requested or received services)
Consent (for clients who have not requested or received services but have signed up to receive CIRE news online, at an event, by talking to a member of staff)
To monitor the performance of our website and make your user experience better
your internet address
your browser type and operating system
the resources you access on your “My Portfolio” account and our wider website
the data obtained from cookies, web logs and other similar technologies that monitor the use of our website and deliver more appropriate advertisements on or beyond our website
Legitimate Interests
To monitor your use of our services, train our staff and improve your client or user experience
your complaints, opinions, responses to our surveys or market research
Your voice when you call CIRE
Legitimate Interests
Who gets to see your personal data?
Johnson Rommers S.L.
Your personal data will be processed by the Christie’s company that initially receives it, and may also be transferred to and processed by other companies within the Christie’s group. Christie’s uses EU Commission approved standard contractual clauses to regulate the transfer and processing of data between group companies.
Outside Johnson Rommers S.L.
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. We only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us authenticate or value property, event venues, caterers, catalogue and direct marketing fulfilment and distribution). Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside the EEA and you should refer to the section Is your personal data transferred out of the EEA? for more information.
We will also transfer your personal data that you provide to us regarding requested services for properties directly to our affiliate agents and brokers who are able to directly handle your request. Conduct anti-money laundering and trade sanction checks and to assist with fraud and crime prevention and detection.
No government entity has direct access to your data. Where we receive a request from a government or law enforcement authority to provide your data, we will only disclose such information where we are ordered to do so by a court or we are otherwise satisfied after internal review that the body making the request has both the right to seek disclosure and has followed the correct process.
Is your personal data transferred out of the EEA?
At Johnson Rommers S.L. we collaborate with a number of real estate companies throughout the world we may in the normal course of business transfer your personal data outside of the EEA., to other organisations who need to process your data in connection with the services that Johnson Rommers provides to you. Your data will also be held on Johnson Rommers servers located in the USA and EEA.
If you have any questions or would like further information about how we make personal data available to non-EEA countries please contact us (see Contact Information below).
How long will we keep your personal data?
We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.
What steps do we take to keep your personal data secure?
We will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided via our website, or by any other means electronic or otherwise.
We use a variety of security technologies and procedures to help protect your personal details from unauthorised physical and electronic access.
As effective as modern security practices are, we cannot guarantee the complete security of personal data held in our systems, nor that that information you supply through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk. We will not be liable for any resulting misuse of your personal data.
Third party websites
Johnson Rommers S.L, websites may contain links to other websites not operated by Johnson Rommers S.L. The information you provide to us will not be transmitted to other websites, but these other websites may collect personal information about you in accordance with their own privacy notice. Johnson Rommers S.L. cannot accept any responsibility for the privacy practices or content of those websites.
Access to your data and other rights
We try to be as open as we can about the data that we process and recommend you ask us if you have questions about the data we hold on you.
Subject Access Requests
If you are a resident of the EU, you have the legal right to make a “subject access request”. If you exercise this right and we process personal data about you by automated means or as part of a Filing System, we are required to provide you with a description and copy of that personal data, and tell you why we are processing it.
Other rights for EU residents
As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing, or have its processing restricted.
If you have provided us with data about yourself and the grounds for processing is Contract or Consent (see What personal data do we process and why?), you have the right to be given the data in machine readable format for transmitting to another data controller.
If we are relying on Consent as the grounds for processing your data (see What personal data do we process and why?), you may withdraw consent at any time. This will not affect the lawfulness of Johnson Rommers S.L. processing of your data prior to your withdrawal.
Contact Information▼
If you have any queries in relation to Christie’s processing of your personal data, please contact us at dataprivacy@johnsonrommers.com. You can also call our client service team at: (+34) 951-660-916 or email our client service team at: clientservices@johnsonrommers.com.