Last updated: [31 March 2020]
We know that your personal information is important to you and we are committed to ensuring it is kept secure and used carefully. Below you will find a short summary of how and why we collect your data, who we share it with, and what we’re doing to make sure your data is safe and secure. You will also find details of your privacy rights.
If you want to skip to a particular section of this policy please click on the relevant link below.
What does Pangaea do?
Pangaea is a privately owned publishing company based in Ireland. We publish newsletters which provide insight and advice on overseas real estate. We are part of the Agora group of companies and you can learn more about Pangaea in the “About Pangaea” section of our Website.
What personal information does Pangaea collect and why?
We collect information in order to allow us to provide the publications you have subscribed to, and to personalise and improve your experience of our services, Websites, and communications with you. All such information is held on secure servers.
We only use personal data you have given us or that we have collected from you when you visit our Websites and order forms. We do not obtain personal information from or sell it to third parties. We sometimes share your personal information with third parties, but only to provide your subscriptions to you or to improve your experience with us and make our business more responsive to your interests and/or those of like-minded individuals or when you have specifically requested that we do so (such as when you fill in a form requesting more information on a particular real estate opportunity). We never release your personal information to others for their mailing or marketing purposes.
The personal information that we may collect about you broadly falls into two categories:
- Information that you provide
We may ask you to provide personal information in order to provide our services to you. This includes asking you to provide your contact details to deliver subscriptions to you or to register an account with us so you can access the subscriber-only areas of our Website. It also includes asking you to provide payment information so you can pay for subscriptions or use a one-click order process.
We may also share personal information that you provide to third parties. This may be to improve your experience with us, to help us tailor the content that we send you or reach like-minded individuals that may be interested in our products.
Sometimes, you have specifically requested that we do this.—For example, if you want more information on a particular real estate opportunity that we write about, you can fill in your personal information on an online form provided and hosted by Pangaea. If you do so, that personal information is automatically passed to Pangaea’s Salesforce CRM database, and from there it is passed automatically to the real estate agent or developer that you are requesting more information from.
The personal information you are asked to provide, and the reasons why you are being asked to provide it, will be made clear to you at the point you are asked to provide it.
- Information that we collect automatically
When you visit our Websites and order forms, we may collect certain information automatically from your device.
The data we collect may include information like your IP address, device type, unique device identification numbers, browser-type, and other technical information. We may also collect information about how your device has interacted with our Website or order form, including the pages accessed and links clicked.
We collect this information so we can better understand the visitors who come to our Websites and look at our order forms and what content may be of interest to them. Using the information allows us to improve the quality and relevance of our Websites and services.
Who does Pangaea share my personal information with?
We may disclose your personal information to the following categories of recipients:
- To reputable third party service providers who provide additional data processing services, for example, analysing data, providing marketing assistance, and assisting with the processing of credit card and direct debit payments. They have access to personal information needed to perform their functions, but may not use it for other purposes. In addition, they must process the personal information in accordance with this privacy notice and as permitted by applicable data protection laws. A list of these providers along with a short summary of the services they provide can be found here:
- Salesforce.com EMEA Limited: when you request more information on a real estate opportunity and fill in your personal information on one of our online forms, that information is passed to Pangaea’s Salesforce CRM database, and from there it is automatically passed to the real estate agent or developer offering that real estate opportunity;
- Real Estate Agents & Developers that work with Pangaea: As above, when you request more information on a real estate opportunity, Pangaea will pass that information (via our Salesforce CRM database) to the real estate agent or developer concerned.
- Facebook.com, Google.com & Instagram.com: For advertising purposes, we occasionally use information about our customers to generate a “lookalike audience”, a similar audience of prospective customers in Facebook, Google or Instagram. This allows us to target advertisements to potential customers in Facebook, Google or Instagram who appear to have shared interests or similar demographics to our existing customers. We do this by uploading a list of email addresses to Facebook, Google or Instagram, encrypting them before we upload. Facebook, Google or Instagram will match the data against their own customers and generate a lookalike audience. The uploaded list is then deleted (not used for any other purpose). If you wish to opt out of our use of your data to create “lookalike audiences” in Facebook, Google or Instagram, please email: email@example.com.
- To any competent law enforcement body, regulatory, government agency, or similar other third party where we believe disclosure is necessary(i) as a matter of applicable law or regulation, or (ii) to exercise, establish or defend our legal rights; and
- To any other person with your consent.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the information concerned and the context in which we collect it. We will normally collect personal information from you where:
- We need the personal information to perform a contract with you (for example, your email address when you subscribe to a free or paid service);
- The processing is in our legitimate interests and not overridden by your rights;
- We have your consent to do so (for example, to receive marketing emails from us about another publisher’s publications or services which we think might be of interest to you, or to receive information from a real estate agent or developer on a real estate opportunity); or
- We need the personal information to comply with our legal obligations (for example, our tax and audit requirements and other regulatory obligations)
By subscribing to any free emails we offer, you are consenting to receive promotions from other group companies and/or third parties (we cannot send a free email alone without the promotional emails). There is an unsubscribe link in each of these emails and you can unsubscribe at any time.
If we collect and use your personal information in reliance on our legitimate interests, this will normally be to operate and improve our services, Websites, and communications. It would also include responding to your queries, undertaking marketing, or detecting or preventing illegal activities. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
How does Pangaea keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Where we share data with third parties, we ensure that your data will be kept secure and will not be provided or sold to another party.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, some Agora group companies and third party service providers operate in the United States and elsewhere around the world. This means that when we collect your personal information we may process it in any of these countries.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. We may not be able to delete your personal information if we have to retain it in order to comply with our legal obligations, to perform a task carried out in the public interest, to establish, exercise or defend any legal claims or to exercise our right of freedom of expression and information.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we may send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the Data Protection Commission (“DPC”).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
How to contact us
The data controller of your personal information is Pangaea Limited.