Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Tower Properties
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
Tower Properties may obtain the following types of information from you or concerning your computer or device (“Information”), which may include information that can be used to identify you as specified below (“Personally Identifiable Information”):
- Email Address
- Mailing Address
- Telephone Number(s)
- Credit Card Information
- Blog or Website URL
- Social Networking Handle or Username
- Demographic Information (e.g., age, gender, interests, and preferences)
- Professional Title
- Activities or Content Viewed on Tower Properties
- Information Collected Automatically ( detailed below )
- Information Received from Third Parties ( detailed below )
In certain cases, we may request that you provide some of the Information identified above in order to obtain specific products or services. If you choose not to provide the Information we request, you may still use Tower Properties, but you may be unable to access certain features or services.
When you register to receive any products or services from Tower Properties or provide information to Tower Properties in any other manner, you agree to provide only true, accurate, current and complete information.
Information automatically collected about you
Tower Properties may automatically receive and log certain types of information when you visit or interact with our websites, services, mobile applications or other products, including:
- Browser Information
- Operating System Information
- Mobile Device Information (e.g., device identifier, mobile operating system, etc.)
- IP Address
- Internet Service Provider
- Content Viewed
- Geographic Location
- Connection Speed
- Time of Visit
- Referring Site, Application, or Service
- Registration Time
Information from our partners
If you choose to use any third party website or service that is integrated with Tower Properties, including a third party social networking or blogging site, such as LinkedIn, Facebook, Twitter or WordPress (“Third Party Websites”) – or if you use any Tower Properties application provided through any Third Party Website – we may receive Information, including Personally Identifying Information, from such Third Party Websites, including, but not limited to:
- Nickname or Username
- Photo or Graphic Avatar
- Unique Third Party Website Identifier (e.g., Facebook User ID)
- Biographical or Demographic Information (e.g. professional title, gender, college attended, etc.)
- Likes and Interests
- Any Information That Is Publicly Available on Third Party Websites
For example, Tower Properties may offer the ability to use certain Third Party Websites to facilitate your registration on Tower Properties. We may also use information about your profile and connections on Third Party Websites to allow you to share or connect with your friends and contacts on Tower Properties or to personalize your experience. In addition, Tower Properties offers “plugins” and “widgets” from various Third Party Websites that allow you to share Tower Properties content off of our service, as discussed in “Disclosure of Information to Third Parties”.
Your decision to use, or share with, a Third Party Website when accessing or using Tower Properties products and services is completely voluntary. Tower Properties is not responsible for compliance with the policies or practices of any Third Party Website. You should ensure that you are comfortable with the information such Third Party Websites may make available to Tower Properties by reviewing those Websites’ privacy policies and service terms, and by modifying your privacy settings and preferences on those Services.
Publicly available information
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- Provide products and services
- Fulfill your requests
- Improve our products and services
- Personalize and tailor your experience on Tower Properties
- Operate our business
- Understand how users are engaging with Tower Properties
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- To identify you for communication purposes
- To provide you a service or to send/offer you a product
- To communicate either for sales or invoicing
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- To send you personalized offers (from us and/or our carefully selected partners);
- To administer and analyze our client base (purchasing behavior and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- To conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behavior to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- To send you newsletters and campaign offers (from us and/or our carefully selected partners);
- For other purposes we have asked your consent for;
We Process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- The link between purposes, context and nature of Personal Data is suitable for further Processing;
- The further Processing would not harm your interests and
- There would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.
We only work with partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. Stored data is encrypted when possible.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organizations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organization.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Last modification was made 06/01/2020.