PRIVACY POLICY
LAST UPDATED 24 MAY 2018
1. WHO ARE WE
This
website (“Site”) is operated by Ecclestons
Properties London a company trading in the United Kingdom
(“Ecclestons ,” “we,”
“us” and/or “our”). Our
registered address is L33, 25 Canada Square, London E14 5LB. You
can contact us as indicated under the “Contact” section
below.
The
data controller responsible for your personal data
is Ecclestons with whom you contract as a client, member or
membership applicant , tenant or landlord (“Ecclestons ”
“we,” “us” and/or
“our”).
This
privacy policy (“Privacy Policy”) applies to
personal data that we collect from you as a user of this Site or as
an investment client, Homebuyer , tenant or
landlord, membership applicant or member
(“you” or “your” being
interpreted accordingly). It provides information on what personal
data we collect, why we collect the personal data, how it is used
and the lawful basis on which your personal data is processed, and
what your rights are under the applicable data protection and
privacy laws, including the General Data Protection Regulation
(“GDPR”) which will become applicable to us and
you as of 25 May 2018.
‘Personal data’ as used in this Privacy Policy
means any information that relates to you from which you can be
identified.
By
using our Site or submitting your personal data you are taken to
accept the terms of this Privacy Policy, so please read it
carefully.
We
collect the following personal data about you:
Property Sourcing, Relocation Property
Management, Renting & Lifestyle
serviices Application: The personal details
you provide when submitting an application. This includes your
name, address, e-mail address; business address and phone number;
gender and date of birth; country; information about your
work and other information that you elect to provide to support
your application. If you are a tenant, we will require you to
attach to your application a copy of your passport, driver’s
license or birth certificate in order to allow us to verify whether
you are eligible to rent in the UK pursuant to the Right
to Rent Legislation . We also collect information about your
bank account information provided by you to our referencing
service providers, that we require for the purpose
of verification and processing your
properrty application (and administration). For further
details please also refer to the section below headed “Payment
Information”.
•
Other Information: Personal details you choose to
give when corresponding with us by phone or e-mail, participating
in user/customer/member surveys or otherwise visiting and
interacting with this Site or any other websites we operate, and
personal data that you provide to us when you visit us
for office meetings aro at your premises. We can
also combine personal data that you provide to us with other
information we collect about you when you make a reservation
through third-party services such as online restaurant-reservation
or travel fare aggregator websites, as necessary to process your
requests.
4. AUTOMATICALLY COLLECTED PERSONAL DATA
•
Log Data: When you visit our Site, our servers
record information (“log data”), including information that your
browser automatically sends whenever you visit the Site. This log
data includes your Internet Protocol (“IP”) address (from which we
understand the country you are connecting from at the time you
visit the Site), browser type and settings, the date and time of
your request.
COOKIES
Our Site uses cookies (small text files
placed on your device) and similar technologies to distinguish you
from other users. This is to provide you with a good user
experience when you browse our Site and allows us to improve its
features.
A cookie is a piece of information sent to your browser from a
website and stored on your computer’s hard drive. Cookies can help
a website like ours recognize repeat users and allow a website to
track web usage behavior. Cookies work by assigning a number to the
user that has no meaning outside of the assigning
website.
.
We
use your personal data in the following ways:
• To
acknowledge, confirm and process your
property application (and where necessary put you on our
waiting list). Such use of your data is necessary in order to
implement your request to become a property client, tenant or
lifestyle member.
•
Where you are a a client, tenant or member, to provide you
with property or membership services, administer your
membership, property or tenancy account and contact you
regarding your use of the services. Such use is necessary to
respond to or implement your request and for the performance of the
contract between you and us.
•
Where you are a short-term rental guest, to complete and fulfill
your reservation and stay in our temporary accomodation, for
example, to process your payment, ensure that your room is
available, and provide you with related customer service, including
sending confirmations or pre-arrival messages, assist you with
meetings, events or celebrations. Such use is necessary for the
performance of the contract between you and us.
• To
contact you in connection with user/customer/member surveys and use
any information you choose to submit in response, provided that you
gave us your consent to being contacted in this way at the time you
provided us with the personal data.
•
Ecclestons and our affiliated businesses may provide you, or permit
selected third-party service providers to provide you, with
information about goods or services, events and other promotions we
feel may interest you as a property client, tenant,
lifestyle member or membership applicant. We (or such third
party providers) will contact you by email only with your consent,
which was given at the time you provided us with the personal
data.
• As
necessary for certain legitimate business interests, which include
the following:
o
where we are asked to deal with any enquiries or complaints you
make.
o to
administer our Site, to better understand how visitors interact
with our websites and ensure that our Site is presented in the most
effective manner for you and for your computer/device.
o to
conduct analytics to inform our marketing strategy and enable us to
enhance and personalise the experience we offer to our members and
our communications, including by creating customer or member
profiles to enable personalised direct marketing
communications.
o to
provide postal communications which we think will be of interest to
you.
o if
you ask us to delete your data or to be removed from our marketing
lists and we are required to fulfil your request, to keep basic
data to identify you and prevent further unwanted
processing.
o to
share personal data among our affiliated businesses for
administrative purposes, for providing membership and property
services and in relation to our sales and marketing
activities.
o we
may anonymise, aggregate and de-identify the data that we collect
and use such anonymised, aggregated and de-identified data for our
own internal business purposes, including sharing it with our
current and prospective members, business partners, our affiliated
businesses, agents and other third parties for commercial,
statistical and market research purposes, for example to allow
those parties to analyse patterns among groups of people, and
conducting research on demographics, interests and
behavior.
o
for internal business/technical operations, including
troubleshooting, data analysis, testing, research, statistical and
survey purposes and as part of our efforts to keep our Site,
network and information systems secure.
o to
(a) comply with legal obligations, (b) respond to requests from
competent authorities; (c) enforce our Ecclestons Rules; (d)
protect our operations or those of any of our affiliated
businesses; (e) protect our rights, safety or property, and/or that
of our affiliated businesses, you or others; and (f) enforcing or
defending legal rights, or preventing damage.
• We
may use your personal data for other purposes which you have
consented to at the time of providing your data.
As
used in this Privacy Policy, “legitimate interests” means the
interests of Ecclestons and our affiliated businesses in conducting
and managing our organisation. When we process your personal data
for our legitimate interests, we make sure to consider and balance
any potential impact on you, and your rights under data protection
laws. Our legitimate interests do not automatically override your
interests. We will not use your personal data for activities where
our interests are overridden by the impact on you, unless we have
your consent or those activities are otherwise required or
permitted to by law. You have the right to object at any time to
processing of your personal data that is based on our legitimate
interests, on grounds relating to your particular situation (for
more information on your rights, please see “Your Data Protection
Rights” section below).
We
may share your personal data with third parties in the following
situations:
•
Service Providers: Ecclestons like many
businesses, sometimes hires selected third parties who act on our
behalf to support our operations, such as (i) card processing or
payment services (see the section below headed “Payment
Information”), (ii) credit reference agencies to protect against
possible fraud, (iii) IT suppliers and contractors (e.g. data
hosting providers or delivery partners) as necessary to provide IT
support and enable us to provide membership services and other
goods/services available on this Site or to members, (iv) web
analytics providers, (v) providers of digital advertising services
and (vi) providers of CRM, marketing and sales software solutions.
Pursuant to our instructions, these parties may access, process or
store your personal data in the course of performing their duties
to us and solely in order to perform the services we have hired
them to provide.
• Ecclestons Affiliated
Businesses: We operate on a globally. In order to provide
the services you request from us, our affiliated businesses may
access and process the information which we collect from you for
the purposes described above, including to offer products and
services to you. Our affiliated businesses will only use your data
for the purposes for which we originally collected it.
•
Business Transfers: if we sell our business or our
company assets are acquired by a third party personal data held by
us about our members, membership applicants or customers may be one
of the transferred assets.
•
Administrative and Legal Reasons: if we need to
disclose your personal data to comply with a legal obligation
and/or judicial or regulatory proceedings, a court order or other
legal process. to enforce our Terms & Conditions, Ecclestons
properties and members Rules or other applicable contract terms
that you are subject to or to protect us, our members, membership
applicants, or contractors against loss or damage. This may include
(without limit) exchanging information with the police, courts or
law enforcement organisations.
Any
credit/debit card payments and other payments you make through our
Site will be processed by our third-party payment providers and the
payment data you submit will be securely stored and encrypted by
our payment service providers using up to date industry standards.
Please note that we do not ourselves directly process or store the
debit/credit card data that you submit.
We
may arrange that card or payment data you submit in support of a
membership application or subscription fee is stored for the
purpose of processing your application, initiating your membership
and collecting your subscription fees if your initial application
is successful (or if you are put on to a membership waiting list,
please note that this data may be stored for later use to initiate
your membership and subscription).
We
store and use this card or payment information for the purpose of
processing any future payments that you make as a member for
additional goods and services. We will store this data in
accordance with our legal obligations under applicable law and only
for so long as legally permitted.
You
may choose to opt out of us holding your card or payment data
although this means that you will need to re-supply us with
card/payment details to initiate your membership subscription fee
or for the purpose of making any future purchases.
Your
personal data will be transferred to and stored in countries other
than the country in which the information was originally collected,
including the United States and other destinations outside the
European Economic Area (“EEA”), to our service
providers and affiliated businesses for the purposes described
above.
Please note that the countries concerned may not
provide the same legal standards for protection of your personal
data that you have in the United Kingdom or EEA. Where we transfer
your personal data to countries outside of the EEA we will take all
steps to ensure that your personal data will continue to be
protected. We will implement appropriate safeguards for the
transfer of personal data to our service providers in accordance
with the applicable law, such as relying on our service providers’
Privacy Shield certification or implementing standard contractual
clauses for data transfers. We have implemented data transfer
agreements pursuant to applicable data protection law in order to
implement appropriate safeguards for the transfer of personal data
to Ecclestons group companies in countries outside the EEA. If
you would like to receive more information on the safeguards that
we implement, please contact us as indicated below.
Where we have given you (or where you have
chosen) a password or log-in which enables you to access certain
restricted parts of our Site, you are responsible for doing
everything you reasonably can to keep these details secret. You
must not share your password or log-in details with anyone
else.
Unfortunately, the transmission of information
over the internet or public communications networks can never be
completely secure. We will take appropriate technical and
organisational security measures to protect the personal data that
you submit to us against unauthorised/unlawful access or loss,
destruction or damage, although we cannot 100% guarantee the
security of personal data that you provide to us online.
We
will keep your personal data only for as long as is reasonably
necessary for the purposes outlined in this Privacy Policy, or for
the duration required by any legal, regulatory, accounting or
reporting requirements, whichever is the longer. In particular, we
retain membership records for six years after expiration or
termination of your membership. We retain information submitted
through the Site and the other websites we operate for two years
following account closure or contact with you, as applicable. When
you consent to receive marketing communications, we will keep your
data until you unsubscribe.
To
determine the appropriate retention period for your personal data,
we consider the amount, nature, and sensitivity of the personal
data, the purposes for which we process your personal data,
applicable legal requirements or operational retention needs, and
whether we can achieve those purposes through other
means.
Upon
expiry of the applicable retention period we will securely destroy
your personal data in accordance with applicable laws and
regulations. In some circumstances we may anonymise your personal
data so that it can no longer be associated with you, in which case
it is no longer personal data.
Certain applicable data protection laws give you
specific rights in relation to your personal data. In particular,
if the processing of your personal data is subject to the GDPR, you
have the following rights in relation to your personal
data:
•
Right of access: If you ask us, we will confirm
whether we are processing your personal data and, if so, provide
you with a copy of that personal data along with certain other
details such as the purpose of the data processing. If you require
additional copies, we may need to charge a reasonable
fee.
•
Right to rectification: If your personal data is
inaccurate or incomplete, you are entitled to ask that we correct
or complete it. If we shared your personal data with others, we
will tell them about the correction where possible. If you ask us,
and where possible and lawful to do so, we will also tell you with
whom we shared your personal data so you can contact them
directly.
•
Right to erasure: You may ask us to delete or
remove your personal data, such as where our legal basis for the
processing is your consent and you withdraw consent. If we shared
your data with others, we will tell them about the erasure where
possible. If you ask us, and where possible and lawful to do so, we
will also tell you with whom we shared your personal data with so
you can contact them directly. We may continue processing personal
data where this is necessary for a legitimate interest in doing so,
as described in this Privacy Policy.
•
Right to restrict processing: You may ask us to
restrict or ‘block’ the processing of your personal data in certain
circumstances, such as where you contest the accuracy of the
personal data or object to us processing it. We will tell you
before we lift any restriction on processing. If we shared your
personal data with others, we will tell them about the restriction
where possible. If you ask us, and where possible and lawful to do
so, we will also tell you with whom we shared your personal data so
you can contact them directly.
•
Right to data portability: You have the right to
obtain your personal data from us that you consented to give us or
that was provided to us as necessary in connection with our
contract with you. We will provide you with your personal data in a
structured, commonly used and machine-readable format. You may
reuse it elsewhere.
•
Right to object: You may ask us at any time to
stop processing your personal data, and we will do so: o If we are
relying on a legitimate interest to process your personal data --
unless we demonstrate compelling legitimate grounds for the
processing or o If we are processing your personal data for direct
marketing.
•
Right to withdraw consent: If we rely on your
consent to process your personal data, you have the right to
withdraw that consent at any time. This will not affect the
lawfulness of processing of your data before we received notice
that you wished to withdraw your consent.
•
Right to lodge a complaint with the data protection
authority: If you have a concern about our privacy
practices, including the way we handled your personal data, you can
report it to the UK data protection authority (the Information
Commissioner’s Office or ICO), or, as the case may be, any other
competent data protection authority of an EU member state that is
authorised to hear those concerns (you may find EU Data Protection
Authorities’ contact information).
If
you wish to exercise any of these rights please contact us as
described in the “Contact” section below. We may also need to ask
you for further information to verify your identity before we can
respond to any request.
Any
changes we may make to our Privacy Policy in the future will be
posted on this page. Please check back frequently to see any
updates or modifications. If required by the applicable law, we
will notify you of any material or substantive changes to this
Privacy Policy.
Questions, comments or requests regarding this
Privacy Policy should be addressed to enquiries@ecclestons-properties.com
I am a text block. Click on me to drag me around or click a corner handle to resize me. Click the settings icon (it's the left one, looks like a cog) to change this text. You can type new text into me or cut and paste text from somewhere else. Click outside of me when you're done and any changes will be saved.
Ecclestons Properties London Copyright 2015 Ecclestons One Canada Square London E14 5DY Tel: 0845 257 0188 enquiries@ecclestonproperties.com.
Registered Member of The Property Redress Scheme : PRS 005428
An
Ecclestons Property Group Company