Please take the time to read this policy in full and understand it.
WHAT INFORMATION DO WE COLLECT AND WHEN?
We only collect information that we will genuinely use for the purposes set out in this policy.
Specifically, we collect all information you submit to us including your name, address, e-mail address and contact details, job title, company, identity card details, property details, transaction details and any communications and documentation (including signed documentation) that you send or deliver to us.
You can choose to submit information to us through a lot of different ways:
• Through consent forms, application forms, engagement letters, agency agreements, receipt forms, commission agreements amongst others;
• By sending us emails and messages (WhatsApp, SMS or MMS);
• By interacting with us on social media platforms (such as Facebook or Twitter);
• By speaking to us in our offices or over the telephone, for example in making an enquiry about property; or
• We also may receive personal information about you from lease agreements or public deeds you sign in respect of property for which we have acted as agents, or from other publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you.
• Background information on you available from government sources or other organizations and entities including such entities like credit reference agencies.
HOW DO WE USE YOUR INFORMATION?
We use the information we collect:
• To provide you with our services and to perform any service or contract we have entered into with you but also to enforce a contract against you if you do not honour it, including in seeking to collect any debts that we may be owed;
• To gather feedback from you about our services from time to time;
• To respond to any questions, suggestions, issues or complaints you have raised with us;
• To respond to any social media posts or other public comments you make where these are made directly to or about us or our services;
• To check that you have or are likely to have the means to pay us for services provided;
• To maintain administrative and statutory records about our business to enable us to understand what services we have provided, how, when, where and at what price and account to the tax authorities for the related taxes that we have to pay; and
• To comply with a court order or statutory requirements and to able to defend our legal position in respect of such court orders or statutory requirements.
OUR LEGAL BASIS FOR PROCESSING OF YOUR INFORMATION
The legal basis for processing your information is based either (a) on your consent which you have expressed in the data consent form or (b) when such processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into such contract, or (c) the processing is necessary for us to comply with a legal obligation, or (d) the processing is necessary for our legitimate interests or the legitimate interests of a third party in relation to the execution of a contract and defence of our rights.
WHO DO WE SHARE YOUR INFORMATION WITH?
We only share your information where we can do so in accordance with our legal data protection and privacy obligations.
We share the information we collect with:
• Professionals including sub-agents, contractors, notaries, and other people who help us provide our services to you, for
example, banks or payment services companies who enable you to use cheques, wire transfers, credit or payment cards with
• our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in
running our business or in order to honour a claim;
• credit reference agencies who provide anti-fraud and credit-insight information to us, and central and local government
• any new business partners we may have over time, for example a joint venture, reorganisation, business merger or sale
• our professional advisors for example our lawyers, accountants, auditors, technology and IT advisers and consultants when
they need it to provide advice to us.
• Data storage companies such as third-party Cloud Service Providers for example Bmit cloud backup and OneDrive
Where possible, we take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as
necessary for their service delivery and for no other purpose.
• the Police, local authorities, the Courts and any other central or local government bodies where they request it and we may
lawfully disclose it, for example for the prevention and detection of crime;
• In response to a court order or a request for cooperation from a regulatory, law enforcement or other government agency; to
establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or
• When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding
actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend our rights, property or safety, our
clients, staff, suppliers or others.
SECURITY OF YOUR INFORMATION
The information we receive may be provided by you either by hand delivery at our offices, by post, or electronically. Once your information is received by us, we take its security very seriously. We use appropriate procedures and technical security measures to safeguard your information across all our computer systems, networks, and offices against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
WILL YOUR INFORMATION BE TRANSFERRED ABROAD
All personal data will be mainly held and processed within Malta, except in the case of transfer of data to third-party Cloud Service
Transfers of your information abroad will be carried out with your consent, or when necessary for the performance of a contract between yourself and us, or for pre-contractual steps taken at your request; or when necessary for the performance of a contract made in your interest between us and another person; or when necessary for the establishment, exercise or defence of legal claims; or when necessary to protect your vital interests or of other persons.
HOW LONG DO WE KEEP YOUR INFORMATION FOR
In accordance with our legal data protection and privacy obligations, we will only retain your information for as long as we actually need it to achieve the purpose(s) for which we obtained it in the first place, or as required under any contract or by applicable law.
MANAGING YOUR INFORMATION
You can contact us to discuss your information at any point in time using the details provided below.
It is very important to us that all the information we hold about you remains accurate and up-to-date at all times.
We need your help in doing so. Please ensure that the information you provide to us through that account (e.g. any contact information
you provide) remains accurate and up-to-date. Please review and update it regularly.
You have a number of rights which we respect and aim to uphold in all that we do. These rights include:
1. Correcting inaccurate information.
2. Asking us about your information. You have the right to ask us whether we hold information about you and if so, for us to give
you certain details about that information and/or the information itself subject to any limitations that are imposed by law.
3. Erase your information. You have the right to ask us to have your personal data erased when your information is no longer
necessary for purpose which it was originally collected; when you withdraw the consent that you had originally given, and
which was the lawful basis for us to hold your information without however affecting the lawfulness of processing based on
consent before its withdrawal; you object to having your personal data processed, and there are no other legitimate grounds
for such processing; your information was unlawfully processed or it has to be erased as it does not comply with a legal
obligation. Erasure requests will not apply if processing is necessary to exercise the right of freedom of expression and
information, to comply with a legal obligation, and for the establishment, exercise or defence of legal claims.
4. The right to withdraw your consent at any time where the processing of your information is based on the giving of your
5. The right to restrict the processing of your information or to object to such processing.
6. The right to obtain and reuse your information for different services. Once your information has been provided to us, you can
request to receive such data in a structured, commonly used and machine-readable format, so that it can be transferred and
transmitted. This right applies only to the personal data that you have provided to us, where processing is based on your
consent or on a contract and when processing is carried out by automated means.
7. The right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you
infringes the law.
You have other legal rights over the information we collect from you. We will honour all such legal rights. Please send your requests on the contact details below.
We reserve the right to charge you a small administration fee to meet our costs in honouring your legal rights, where permitted by law.
If you have any complaints about our use of your information, please contact us. We will do our very best to resolve any complaint to your satisfaction.
We may need to change this policy from time to time to keep it accurate and up to date.
If we change this policy, we will tell you about it and request your consent when necessary. That way you can check to see if you are happy with our policy, before proceeding any further.
We may have CCTV in operation at our offices.
All CCTV footage is captured purely for your security and for the prevention and detection of crime. It is kept separate from all of the other information we collect about you (as set out above). For further details, please contact us using the details provided below.
Our Company’s name is Dynamic Services Limited trading as Northern Properties, whose offices are situated at 597, St Paul’s Street, St
Pauls’ Bay, Malta and the following are our contact details:-
Tel: [+356] 20105070;
We are what is known as the ‘data controller’ of the information you provide to us. This term is a legal phrase used to describe the person or entity who controls the way information is used and processed.
I acknowledge that consent is necessary in order for Dynamic Services Limited trading as Northern Properties to provide me with the
services I have requested from it. I further acknowledge that failure to provide such information will result in Dynamic Services Limited trading as Northern Properties not being unable to provide the services I requested.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:
First name and last name
Address, Postal code, City
Cookies and Usage Data
We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Use of Data
Northern Properties uses the collected data for various purposes:
To provide and maintain the Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues