Privacy Policy
Shaftesbury Capital is committed to protecting the privacy and security of your personal data.
This privacy notice (“Notice”) describes how we collect and use personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”).
- SCOPE
- AUDIENCE
- WHAT THIS PRIVACY NOTICE COVERS
- WHAT PERSONAL DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- WHY WE PROCESS PERSONAL DATA
- TRANSFERS OUTSIDE OF THE UK OR THE EEA
- WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
- PROTECTING YOUR PERSONAL DATA
- YOUR RIGHTS IN CONNECTION WITH THE PERSONAL DATA WE COLLECT
- HOW LONG WE HOLD YOUR PERSONAL DATA FOR
- HOW WE UPDATE OR CHANGE THIS NOTICE
- HOW YOU CAN CONTACT US
1. SCOPE
1.1 This Notice is given by Shaftesbury Capital PLC on behalf of itself, its subsidiaries and its joint venture companies (“Shaftesbury Capital”). We act as a data controller for the personal data we collect during the course of our engagement with you.
1.2 This means that we determine the purposes for and manner in which we (or our processors) process your personal data.
1.3 Our registered office is at Regal House, 14 James Street, London, WC2E 8BU. We can be contacted by post at this address or by email at [email protected]. Please mark any correspondence for the attention of the Company Secretary.
2. AUDIENCE
2.1 This Notice relates to range of data processing activities undertaken by Shaftesbury Capital. To help you navigate this Notice we have extracted the key information applicable to you depending on the nature of your relationship with us. Please click on the below tabs to access the relevant summary. Full details of our processing are set out in the rest of the Notice.
2.2 If you are residential tenant on the basis of an AST, or a guarantor of any such residential tenancy, please refer to the standalone privacy notice specific to your situation. You will have been provided with a copy of the privacy notice relevant to you via your letting agent or Shaftesbury Capital contact, but if you'd like another copy of the Residential Tenant Privacy Notice then please contact the relevant letting agent, or Shaftesbury Capital contact.
A. Business and general correspondents
We may collect your personal data if you contact Shaftesbury Capital by email, post, telephone or otherwise in connection with any business or general matter, in order to maintain a general business relationship with you.
The information we collect
We will only collect the information you provide to us directly, such as your name and contact details or other details you might provide when corresponding with us.
Who we share the information with
Depending on the correspondence we have with you, we may share your information with businesses that provide us with services necessary in relation to what you have requested.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We have a legitimate interest to process your personal data in order to maintain normal business operations and to fulfil the request you’ve made through your correspondence with us.
Automated decisions we make about you
We do not make any automated decisions using this information.
B. Website visitors
As a visitor to our website, we will collect information related to you as required for our website to operate, as well as giving you the opportunity to subscribe for our newsletters or alerts.
The information we collect
If you chose to sign up for the press releases, RNS, or alerts from our website, we will collect and store your name, email address and choice of news and information services. The Alerts section of the website allows you to select the type of alert you would like to receive, including Financial Results, Stock Exchange Announcements or Press Releases. We use this information to provide the service you requested.
You are able to unsubscribe from the news and information service at any time and/or “opt out” of receiving communications by clicking the unsubscribe link in any email you are sent from us. If you unsubscribe from the services, we will not retain the data you submitted when you subscribed for the service and will cease sending you news and information.
We collect your personal data to respond to any requests which you have submitted via our website and to deal with ongoing matters relating to such requests.
Technical Information
We use cookies on our website to gather and record on our servers certain information about all users who visit the website, including without limitation, IP address, time zone setting and location, interaction with our website browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may also receive technical data about you from analytics providers such as Google (for example, standard internet log information and details of visitor behaviour patterns). We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not directly identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
At any time, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For further information on this, please see our Cookie Policy.
The information we collect about your use of the website will be used to report on visitor numbers, administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) to improve our website, services, and consumer experiences.
We also collect, use and share aggregated data such as statistical or demographic data (Aggregated Data) for limited purposes. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Who we share the information with
We share the information we collect with our website providers to the extent necessary for them to perform their services to us. We may also share your information with our Registrars, brokers or PR advisers in order to provide you with any information that you have requested from us. These third party service providers may be located in South Africa.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Please note that Shaftesbury Capital does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
Where you have agreed to provide us with your data to receive the email alerts and press releases, then you have consented to us processing that information.
We have a legitimate interest in administering, protecting and improving our website. We also have a legitimate interest to process your personal data for the purpose of providing you with the information you request when accessing and interacting with our website.
Our use of cookies is subject to consent – please see our Cookie Policy.
Automated decisions we make about you
We do not make any automated decisions using this information.
C. Visitors to our buildings or properties
We store and use your information for the purposes of managing and operating our buildings.
The information we collect
If you are visiting our head office at Regal House, 14 James Street, London WC2E 8BU, we may collect personal data where necessary for security, administration and safety purposes – this may include collecting personal and contact details, as well as dietary, health or accident information. Further, we have a guest WiFi network for visitors to access, however no personal data is collected by us in relation to this.
When visiting our properties, which include Carnaby, Covent Garden, Chinatown, Seven Dials, Opera Quarter, Coliseum, Fitzrovia and Soho, we operate CCTV for the purposes of detecting and preventing crime and general estate management. We may also receive information from law enforcement agencies if criminal activity is alleged or suspected in the publicly accessible areas of our portfolio. Our CCTV feeds provide a 24/7 live feed, which is retained for 31 days, unless we are aware of a particular incident, where the footage may be kept for longer to share with law enforcement agencies (see section 8 for further information on why we might share your personal data).
We may also take photographs or videos of within a property or public space, in which case we may capture the image of visitors. Where we hold an event in one of our areas, signs will be displayed during the event to advise you when and where photographs are being taken. If you have any concerns or do not wish to be photographed, you should raise this with a member of our team. Where we take specific or close up images of individuals (for example, as part of our social media, or website images), we will always seek your consent.
As part of the management of our portfolio, we also collect aggregated footfall and visitation data across our portfolio. No personal data is collected through this.
Who we share the information with
We share the information we collect with the following third parties:
- Our suppliers to the extent necessary to perform their services to us;
- Where access control information or fire evacuation information is required to be shared with an occupier;
- Where the information relates to health and safety incidents, security events or any matter giving rise to an insurance claim or relevant to our insurance coverage, our lawyers, insurance brokers and other professional advisers; and
- When requested to do so by relevant authorities such as the police, in the event of criminal conduct.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We have a legitimate interest in wishing to interact with you in order to manage and operate effectively our buildings and our portfolio and ensure that these are safe and secure. The processing we undertake is limited and concentrates on the use of the building.
In some instances, for example health and safety, we are required by law to hold certain records to comply with this obligation.
Automated decisions we make about you
We do not make any automated decisions using this information.
D. Commercial Tenants
We will process the information of commercial tenants (including their employees) only as necessary to manage your contractual relationship with us, such as taking rent and service charge payments, building administration and repairs, energy consumption data, seeking your feedback through surveys, lease negotiations, managing complaints, dealing with arrears, recording accidents, liaising with utility suppliers, and dealing with emergency access to commercial units.
In addition, we may collect further data in relation to your commercial business which can include aggregated consumer spending data and trends. No personal data is collected in relation to this.
The information we collect
We will collect the name and contact details of commercial tenants or their employees, and other limited information to the extent required for the management of the tenancy contract.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform their services to us. This will include our managing agents, the provider of any tenant portals and utility providers as necessary.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We rely on a legitimate interest to process this data to allow for the appropriate management of tenancy contracts and our portfolio.
Automated decisions we make about you
We do not make any automated decisions using this information.
E. Users of our Tenant Portal
We store and use your information for the purposes of managing our relationship with our residential or commercial tenants and to be able to communicate effectively. If you are a residential tenant, please also refer to the standalone Residential Tenants Privacy Notice (referenced above) for additional information on how we process your information.
Across some of our portfolio, we will collect your name and email address in order to contact you through the portal for the above purposes. In addition, if you chose to sign up for newsletters or other marketing promotions from the portal, we will also collect and store your choice of news and information services. You are able to unsubscribe from the newsletter and marketing promotions at any time and/or “opt out” of receiving any other marketing communications by clicking the unsubscribe link in any marketing email you are sent from us. When you are no longer a tenant or a user of the tenant portals, we will not retain the contact information you submitted when you subscribed for the service and will cease sending you news and information.
The information we collect
To allow for communications with tenants on estate management across some of our portfolio we use a tenant portal. As a tenant, we will collect your name and email address in which to contact you directly through this media. Any data collected in relation to correspondence history is retained on the portal for 30 days, at which point it is removed.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform their services to us. This will include our managing agents and the provider of the tenant portal.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We rely on a legitimate interest to process this data to allow for communication with our tenants in respect of estate management. Marketing communications will only be sent on the basis of your prior consent.
F. Neighbourhood Card Members
We collect and store your information for the purposes of running our Neighbourhood Card schemes and the “I Love Covent Garden” reward card, and if you opt in, to contact you in relation to providing marketing updates across Carnaby and Soho, Seven Dials or Covent Garden. For example, where you have provided your consent, we will send marketing updates such as email newsletters, or other email marketing information that we consider to be relevant to you from the relevant portfolio area and our partners. If you have not provided your consent, you will only receive one email containing your digital I love Covent Garden Rewards Card (if you have signed up for this) or confirming you have signed up to the Neighbourhood Card schemes.
The information we collect
Where you have signed up for a Neighbourhood Card or I Love Covent Garden Card reward scheme, you will share with us data which can include your full name, date of birth, address, company or school name and email address to enable us to send you information regarding promotions and special offers for you to benefit from.
You are able to withdraw from the Neighbourhood Card scheme by contacting [email protected] for Carnaby and Soho or [email protected] for Seven Dials at any time. If you withdraw from the Neighbourhood Card, we will not retain the data you submitted when you subscribed for the scheme and will cease sending you marketing information. To withdraw from the I Love Covent Garden Rewards, click ‘unsubscribe’ on existing email footers or contact [email protected]
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform their services to us.
Legal basis for processing
Where you have agreed to provide us with your data to join the Neighbourhood Card or I Love Covent Garden card reward schemes, then you have consented to us processing that information.
Please see section 8 below for additional circumstances where we may disclose your data.
Automated decisions we make about you
We do not make any automated decisions using this information.
G. Social media followers and competition entrants
We have active social media accounts for Shaftesbury Capital PLC, Covent Garden, Soho, Carnaby, Chinatown, Fitzrovia and Seven Dials, including on Facebook, Instagram, Twitter, LinkedIn, Pinterest, Weibo, WeChat, Tik Tok, Douyin and RED. These social media accounts are used to answer any enquiries received from followers, reshare photos tagged to our account and to promote our portfolio.
These social media accounts may periodically run competitions.
The information we collect
By contacting or interacting with us through our social media accounts, you share with us your details on your social media account, which can include your social media username/handle, public profile, public posts, and any personal information included as part of your enquiry such as your name, email address, place of work and job title.
Where you have entered into a competition or prize draw we may also require proof that you are over the age of 21.
If you are successful in a competition or prize draw, we will contact you directly on social media to engage with you on how to collect or redeem your prize. In this instance, we may require your email address, mobile number or home address.
We retain your information for as long as needed for you to claim or redeem your prize, after which it is deleted.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform their services to us. In this instance the main suppliers will be our marketing agents.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
When you enter into the competition, you are accepting our competition terms and conditions, meaning that we are under a contractual obligation with you to process your data for the duration of the competition.
When you contact us through our social media channels, we have a legitimate interest in responding to your query.
Automated decisions we make about you
We may sometimes make automated decisions in relation to specific competitions that you enter – for example, to automatically select a winner. Where this is the case, further detail in relation to automated decision marking will be set out in the information provided to you when you sign up for the relevant competition.
H. Job applicants
The information we collect
CVs may be submitted to us through recruitment agencies or through our general enquiries inbox, or to individuals within our organisation. If a CV is submitted to our general enquiries inbox or to an individual within the organisation, it will be passed to our HR department, and the individual who received it shall delete it from their email. We will store and assess all the information held within your CV for recruitment purposes.
Throughout the recruitment process we will also require information on your job history, passport details, nationality, residence permit (which includes details of immigration status and access to public funds), National Insurance number, and proof of your professional qualifications.
If you are successful in your job application, we will collect further details from you in line with your employment with Shaftesbury Capital, and a separate Privacy Notice will be communicated to you. If you are not successful, we will retain your information for a period of 6 months.
Who we share the information with
Should the CV be submitted to us via a recruitment agency then that agency will also have a copy of the CV itself. If we elect to contact your referees and/or previous employers directly, we will share information with them to the extent necessary to confirm the details provided in your CV.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We will process personal data in the CVs we receive, either directly from you or through a recruitment agency, on the basis of our legitimate interest in recruiting suitable candidates for our roles or where the processing is necessary to perform a contract or to take steps at your request, before entering a contract.
If you provide us with any information about reasonable adjustments you require under the Equality Act 2010 the lawful basis we rely on for processing this information is to comply with our legal obligations under the Act.
We request that CVs do not contain special category data (such as medical information) – to the extent that you voluntarily provide such information, any processing by us will be incidental and we will rely on the fact we have obligations in employment and the safeguarding of your fundamental rights. In other limited circumstances we may ask for your specific consent.
I. Suppliers
The information we collect
When you are engaged with Shaftesbury Capital as a supplier, we collect relevant information about you through our engagement with you in order to enter into a contract with you or your organisation for the provision of goods or services. This data may include your name, contact details, the name of the organisation you represent, VAT number and bank account details in order to make payment to you. We may also require your National Insurance details as required to comply with HMRC rules.
Who we share the information with
We only share the information we collect with our suppliers, contractors and professional advisers to the extent necessary for them to perform their services to us.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We have a legitimate interest in processing this data from you in order for us to undertake necessary due diligence and to ensure that the invoice details match your account details. The data that we collect from you may also be used to ensure we comply with legal requirements.
Automated decisions we make about you
We do not make any automated decisions using this information.
J. Shareholders
We collect and process your personal data as a shareholder so we can manage your shareholding in Shaftesbury Capital PLC to comply with our statutory and regulatory obligations and keep your record on the share register up to date; to make shareholder communications and shareholder meeting materials available to you; to pay you dividends; to allow you to exercise your rights as a shareholder including the right to vote, and to respond to any correspondence you send us or our Registrars: Link Asset Services Limited (UK register and Computershare Investor Services Proprietary Limited (South African register). In South Africa, personal data is also held by Strate (Pty) Ltd.
The information we collect
As a shareholder of Shaftesbury Capital PLC, we may collect your name, registered address, bank sort code and account number, email address, number of shares, date of death, corporate action election options, identification numbers, phone number and communication method preference.
If you are no longer a shareholder of Shaftesbury Capital PLC we will retain your personal data for as long as is necessary to comply with any legal requirement.
Who we share the information with
We may share your data with Link Asset Services Limited (UK register) and Computershare Investor Services Proprietary Limited (South African register), any other professional advisers as required. In compliance with our legal obligations (such as s.811 Companies Act 2006), we may share your data with those who request a copy of the register of members of Shaftesbury Capital. If you have requested hard copies of shareholder documents, we may also share your data with printing professionals and postal services to get these to you.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We are under a statutory obligation to process your personal details on our share register. Other than this, we process your information on the basis of our legitimate interest.
Automated decisions we make about you
We do not make any automated decisions using this information.
K. Local residents, business owners or other interested parties
From time to time, we may contact or engage with local residents, business owners or other interested parties either in connection with specific planning or consultation processes or more generally as part of community outreach or similar programs. This may include surveys, interviews, correspondence or other forms of engagement. We collect and process your personal data only as necessary to enable us to communicate with you in line with your preferences, and where necessary your consent.
The information we collect
We will only collect the information you provide to us directly, such as your name, contact details and topics of interest.
Who we share the information with
We will only share your information with our suppliers to the extent necessary for them to perform their services to us. Where appropriate we may share your information with relevant third parties, for example to facilitate introductions.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
Where we contact you in relation to planning applications, we have a legitimate interest in complying with the formal and informal guidance of relevant planning authorities and more generally in relation to the development of our estate. If you engage with us as part of our community outreach programs, we will only process your information with your consent.
Automated decisions we make about you
We do not make any automated decisions using this information.
L. Long Leaseholders
We will process the information of long leaseholders only as necessary to manage your relationship with us, for example such as taking service charge payments, lease negotiations, building administration and repairs, energy consumption data, managing complaints, dealing with arrears and recording accidents.
The information we collect
We will collect your name, address and lease agreements (for either entering into a new lease, or extending your existing lease), and other limited information to the extent required for the management of your lease agreement.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform their services to us. This will include our managing agents.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We rely on legitimate interest to process this data to allow for the appropriate management of your lease agreement and our portfolio.
Automated decisions we make about you
We do not make any automated decisions using this information.
3. WHAT THIS PRIVACY NOTICE COVERS
3.1. This Notice covers:
a) what personal data we collect about you;
b) how we collect personal data;
c) why we process personal data;
d) the transfer of any personal data outside the UK and/or the EEA;
e) when we may disclose your personal data;
f) protecting your personal data;
g) your rights in connection with the personal data we collect;
h) how long we hold your personal data for;
i) how we update or change this notice; and
j) how you can contact us.
3.2. We issue other privacy notices (alongside this Notice) which relate to specific situations relationships – please refer to the following notices where applicable:
a) Residential Tenant Privacy Notice – please see reference above
b) Employee Privacy Notice – please request a copy from the Head of HR.
4. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
4.1. The types of personal data which we collect about you will vary according to the nature of your relationship with us. Please see the relevant section at part 2 of this notice. We may also process other categories of personal data from time to time, as specifically notified or as may reasonably be anticipated as part of the operation of our business and the management of our property portfolio.
4.2. Under the UK GDPR certain types of information are considered to be more sensitive and so in need of more protection. These “special categories of personal data” are information about your race, ethnic origin, political opinions, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life, or sexual orientation, and may also include information relating to criminal convictions and allegations. Where you provide us with this information, we are required to establish an additional lawful basis for holding this information, which will usually be your explicit consent or our compliance with a legal or regulatory obligation. We may process such information in the following circumstances:
a) As a visitor to our premises, we may process health related information such dietary requirements and accident details.
b) In very rare instances we will process special categories of personal data in order to prevent or detect unlawful acts in connection with a tenancy or on publicly accessible areas of our portfolio (e.g. fraud or antisocial behaviour), which in some circumstances will involve disclosures to the police or other regulatory/legal authorities.
4.3. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the course of your relationship with us.
5. HOW WE COLLECT YOUR PERSONAL DATA
5.1. The way in which we collect your personal data will vary according to the nature of your relationship with us. Please see the relevant section at part 2 of this Notice. We may also collect personal data from other sources from time to time, as specifically notified or as may reasonably be anticipated as part of the operation of our business and the management of our property portfolio.
6. WHY WE PROCESS PERSONAL DATA
6.1. The personal data we collect and process will vary according to the nature of your relationship with us. Please see the relevant section at part 2 of this Notice.
6.2. We may also process personal data for the following purposes:
a) internal business and regulatory requirements, including valuation of the property portfolio in line with accounting standards, undertaking audits, archiving etc;
b) exercising and/or defending our legal rights; and
c) we may also process personal data for other purposes from time to time, as specifically notified or as may reasonably be anticipated as part of the operation of our business and the management of our property portfolio.
6.3. Whenever we process your personal data we do so on the basis of a lawful condition of processing. The applicable legal basis will vary according to the nature of your relationship with us. Please see the relevant section at part 2 of this Notice. In addition, we may also undertake processing: where necessary for compliance with a legal obligation to which Shaftesbury Capital is subject (for example, undertaking mandatory background checks or to comply with court orders); where you provide your consent to the processing of your personal data for certain specific purposes, including where based on additional information made available at the time consent is provided; where we need to protect the vital interests for you or someone else, or where it is necessary to do so in the public interest; and in other circumstances where necessary for our legitimate interests (or those of a third party).
6.4. Where we process your personal data as necessary for our legitimate interests (or those of a third party), we do so only provided it is carried out in a way that is proportionate and respects your privacy rights.
6.5. The special categories of personal data that may be processed by Shaftesbury Capital are set out in paragraph 4.2 of this Notice. Where we process special categories of data it will be justified by a condition set out at paragraph 6.2 above and also by one of the following additional conditions:
a) based on your explicit consent;
b) in accordance with paragraph 10 of Schedule 1 of the UK’s Data Protection Act 2018 – for example where we seek to prevent or detect unlawful acts (e.g. fraud or antisocial behaviour);
c) where necessary to protect the vital interests for you or someone else where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as a medical emergency), or where it is necessary to do in the public interest; or
d) the processing is otherwise permitted by law, such as in relation to legal claims.
6.6. We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7. TRANSFERS OUTSIDE OF THE UK OR THE EEA
7.1. Several of our external third parties are based outside the UK and/or the European Economic Area (“EEA”), in particular South Africa, so their processing of your personal data will involve a transfer of data outside the UK and/or EEA.
7.2. Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards have been implemented. If you would like further information on the specific safeguards used by us when transferring your personal data out of the UK and/or EEA, please contact the Company Secretary.
8. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
8.1. The ways in which we disclose your personal data will vary according to the nature of your relationship with us. Please see the relevant section at part 2 of this Notice. In addition, we may also disclose your personal data to the following recipients:
a) to service providers to whom we outsource certain functions of our business. For example, we have service providers such marketing agencies who provide marketing support or IT service providers who provide / support IT applications or systems, which means that your personal data will be hosted on their servers, but under our control and direction. We require all our service providers to respect the confidentiality and security of personal data;
b) to a prospective buyer in the event of a sale, merger or restructuring of any part of our business;
c) to a prospective buyer and their advisors in the event of a sale, merger or restructuring of any part of our business;
d) to any company within the Shaftesbury Capital group of companies and our joint venture companies); or
e) to any regulatory agency or enforcement body (e.g. the police or intelligence services) or court where we reasonably believe that we are required to do so by applicable law or regulation or by any court order or at their request where it is legal to do so.
9. PROTECTING YOUR PERSONAL DATA
9.1. We have put in place technical and organisational measures to protect the security of your information. Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
9.2. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
10. YOUR RIGHTS IN CONNECTION WITH THE PERSONAL DATA WE COLLECT
10.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. The rights available to you depend on our reason for processing your information.
10.2. You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability.
10.3. If we are relying on your consent to process data (for example you have requested further information from us or marketing materials), you may withdraw your consent at any time by notice to us.
10.4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in these circumstances.
10.5. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
10.6. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. HOW LONG WE HOLD YOUR PERSONAL DATA FOR
11.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements including applicable statutory limitation periods.
11.2. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a tenant, we will retain and securely destroy your personal data in accordance with our data retention policy, although we will retain the signed original agreement and supporting documentation indefinitely.
12. HOW WE UPDATE OR CHANGE THIS NOTICE
12.1. We reserve the right to update this Notice at any time and we will make the revised Notice publicly available. We may also notify you in other ways from time to time about the processing of your personal data.
12.2. This notice was last updated on 18 March 2024.
13. HOW YOU CAN CONTACT US
13.1. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the Company Secretary.
13.2. If you have any questions about this Notice or any queries in relation to how we process your personal data, please contact the Company Secretary, either by post at Shaftesbury Capital PLC, Regal House, 14 James Street, London, WC2R 8BU or by email at [email protected]
13.3. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.