Privacy Policy
GibFirst Property Services Ltd (“GibFirst”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use and protect personal data when you visit www.gibfirst.com, contact us or enquire about our properties and services.
1. Who is responsible for your personal data?
GibFirst Property Services Ltd is the data controller responsible for the personal data covered by this Privacy Policy.
You can contact us at:
GibFirst Property Services Ltd
Don Place
8 Governor’s Lane
P.O. Box 335
Gibraltar
Email: gibfirst@gibfirst.gi
Telephone: +350 20076172
We process personal data in accordance with applicable Gibraltar data protection legislation, including the Gibraltar General Data Protection Regulation (“Gibraltar GDPR”) and the Data Protection Act 2004, as amended.
2. Personal data we collect
Depending on how you interact with us, we may collect:
- Contact details, such as your name, email address, telephone number and, where relevant, company name.
- Enquiry information, including the property or service you are interested in, your requirements and information you include in your messages.
- Correspondence, including records of communications with us.
- Technical information, such as your IP address, browser type, device information and website access logs.
- Cookie preferences, including your choices concerning optional cookies and similar technologies.
Please only provide information relevant to your enquiry. Do not submit identity documents, financial information or sensitive personal data through a general website enquiry form.
If a proposed transaction or service requires additional information, we will explain the relevant processing when we request it.
3. How and why we use your personal data
We use personal data for the following purposes:
Responding to enquiries
To answer questions, provide information about properties and services, and manage correspondence. We rely on our legitimate interests in responding to people who contact us and managing our business relationships.
Taking steps towards a contract
To discuss your requirements, arrange property viewings and take steps at your request before entering into a contract with you. Where you act on behalf of a business, we rely on our legitimate interests in managing that business relationship.
Operating and protecting our website
To maintain website functionality, troubleshoot problems, prevent misuse and protect our systems. We rely on our legitimate interests in operating a secure and reliable website.
Meeting legal obligations
To comply with applicable legal requirements and respond to lawful requests from competent authorities.
Where we rely on consent, including for optional cookies where required, you can withdraw that consent at any time. Withdrawal does not affect processing carried out lawfully before you withdrew it.
We do not treat a website enquiry as consent to receive unrelated marketing communications.
4. Providing your information
Providing personal data through our website is voluntary. However, we need sufficient contact details and information about your enquiry to respond or arrange a requested service.
If information is required by law or necessary to enter into a contract, we will explain this when we request it, together with the consequences of not providing it.
5. Who we share personal data with
Where necessary for the purposes described above, we may share personal data with:
- Authorised staff who handle enquiries and provide our services.
- Providers supporting our website hosting, email, IT maintenance and security.
- Professional advisers where their assistance is necessary.
- Public authorities, regulators or law enforcement bodies where disclosure is legally required.
If your enquiry needs to be handled by another GibFirst group company or a property owner, we will explain the proposed disclosure and identify the relevant organisation before sharing your details, unless disclosure is otherwise required by law.
Service providers processing personal data on our behalf must act under appropriate contractual instructions and confidentiality and security obligations.
6. International transfers
Some service providers may process personal data outside Gibraltar.
Where this involves a restricted international transfer, we will ensure that an appropriate legal transfer mechanism applies, such as an applicable adequacy decision or approved contractual safeguards.
You can contact us for information about the safeguards relevant to your personal data and how to obtain a copy.
7. How long we retain personal data
We retain personal data only for as long as necessary for the purpose for which it was collected.
Our retention periods are:
- Enquiries that do not lead to a contract: [insert confirmed period] after the enquiry is closed.
- Website security and access logs: [insert confirmed period], unless longer retention is necessary to investigate a security incident.
- Cookie preference records: as described in our Cookie Policy.
Where an enquiry develops into a contractual relationship, we will provide information about the retention arrangements relevant to that relationship.
Information may be retained for longer where necessary to meet a legal obligation or establish, exercise or defend legal claims. Once retention is no longer necessary, we will securely delete or anonymise the information.
8. How we protect your personal data
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration and disclosure.
Access is limited to people and service providers who need the information for their work.
Although we take reasonable measures to protect personal data, no website, email service or internet transmission can be guaranteed to be completely secure.
9. Your data protection rights
Subject to applicable law and the circumstances of the processing, you may have the right to:
- Access your personal data and receive a copy.
- Have inaccurate or incomplete data corrected.
- Request deletion of your personal data.
- Request restriction of processing.
- Object to processing based on legitimate interests.
- Receive certain data in a structured, commonly used and machine-readable format and request its transfer to another controller.
- Withdraw consent where processing is based on consent.
To exercise your rights, contact gibfirst@gibfirst.gi.
We may request information reasonably necessary to verify your identity. We will respond within the time limits required by applicable law, normally within one month. Where a permitted extension is necessary, we will explain the reason and revised response period.
10. Cookies and similar technologies
Our website uses cookies and may use similar technologies.
Please read our Cookie Policy for information about the technologies used, their purposes, retention periods and relevant third parties.
Where optional technologies require consent, you can accept or reject them and change your choices through the website’s cookie preferences tool.
11. External websites and embedded content
Our website may contain links to third-party websites or content provided by external services.
Those services may process personal data under their own privacy notices. We encourage you to review the relevant information before interacting with them.
Where embedded content requires consent before loading, it will be managed through the website’s consent controls.
12. Complaints
If you have concerns about how we handle your personal data, please contact us using the details above.
You also have the right to lodge a complaint with the Gibraltar Regulatory Authority, acting as Gibraltar’s Information Commissioner. You do not need to contact us before exercising that right.
Website: www.gra.gi
Data protection information: www.gra.gi/data-protection
13. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our website, services, processing activities or legal obligations.
The latest version will be published on this page with its updated date. Where required, we will also notify you of material changes.