Privacy Policy
Sager Management Limited
PRIVACY NOTICE
Last Updated Feb, 2021
This Privacy Notice (“Privacy Notice”) sets out how Sager Management Limited processes your personal data in connection with its business including the provision of the Sager Management Limited website at www.sagergroup.com ([together] the “Site), and obtaining feedback on development projects from the Site[s] and [insert any other locations from where the services are offered e.g. offices] (together “Services”).
This Privacy Notice applies to visitors to Sager Management Limited’s Site, suppliers and other third parties that we interact with during the day to day provision of our Services.
Purpose of this privacy notice
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Use and our Cookie Policy.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).
About us
The Site[s] and our Services are made available by Sager Management Limited (“Sager Management”, “we”, “us, “our”). Sager Management is the data controller responsible for your personal data. For more information please read paragraph below:
Sager Management Limited (company no: 03803134) is an English company with its registered office at Sager House, 50 Seymour Street, London, W1H 7JG.
How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in Section 16 of this Privacy Notice, you can contact us by:
using the Contact Form on our Site
sending an email to dataprotection@sagergroup.com
calling 02077236693insert phone number
writing to Sager House, 50 Seymour Street, London, W1H 7JG.
What personal data we collect
In the course of providing you with Site[s] and Services, we may collect the following types of personal data about you:
Contact Data, such as your:
name;
address;
email address; and
telephone number;
Registration Data, such as your:
first name and last name;
date of birth;
gender;
country;
nationality;
any KYC information that we may collect; and
any other personal data you may provide when you register with us;
Profile Data, such as:
your contact preferences;
whether you have participated in any promotions or competitions; and
information about any of our events that you have attended;
Behavioural Data, such as:
data relating to your browsing activity or interaction with our emails, through the use of cookies, pixel tags and other similar technologies;
when your current or previous sessions started; and
details about any content you viewed through the Site[s];
Technical Data, such as your:
IP address;
browser type and operating system;
geolocation, to ensure we’re showing you the correct notices and information; and
any other unique numbers assigned to a device.
How we collect and receive personal data
We collect and receive personal data using different methods:
Personal data you provide to us.
You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Sitesubscribe to receive our marketing communications or provide feedback to us.
Personal data we collect using cookies and other similar technologies.
When you access and use our Site[s], we will collect certain Behavioural Data or Technical Data. We collect this personal data by using cookies and other similar technologies (see the ‘Insight, analysis and retargeting through Cookies’’ section below).
Personal data received from third parties.
From time to time, we will receive personal data about you from third parties. Such third parties may include retail and estate agents, analytics providers, data brokers and third parties that provide technical services to us so that we can operate our Site[s] and provide our Services.
Publicly available personal data.
From time to time we may collect personal data about you (Contact Data or Profile Data) from publicly available sources (including open source data sets), media reports or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories[ or posts on social media platforms.
Who we collect personal data about
We collect and process personal data from the following people:
If you browse our Site[s], submit a response to a consultation through the Site, contact us with an enquiry through our Site[s], submit a complaint through our Site[s] or use any Services available on our Site[s], we will collect and process your personal data in connection with your interaction with us and our Site[s].
Visitors to Sager Head Office
If you attend Sager Head Office, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest. CCTV footage may also be collected for security purposes.]
If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.
Personnel that work for our partners and suppliers (including subcontractors).
If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.
If you apply for a job with us, whether through the Site[s] or otherwise, we will collect and process your personal data in connection with your application.
How we use your personal data
We use your personal data for the following purposes:
We collect and maintain personal data that you submit to us during your use of our Site[s] in the following ways
Using our Site[s] and the features we provide on the Site[s].
Once on our Site you are able to use various features on our Site[s], which we offer as a part of the Services we provide.
We will collect and use personal data about you when you use these features, for instance we will process certain Behavioural Data and Technical Data when you browse our Site.
Your access to and use of our Site[s] is subject at all times to our Terms of Use.
Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Services in a secure and effective way.
Your contributions to our Site.
If you submit any content to us, including via our Site[s], such as feedback on projects, or testimonials, we may process any personal data comprised within that content for the purposes of making available particular Services via our Site[s] and promoting our Site and Services.
Our legal basis for processing
Where we use your content in connection with Services that we provide via our Site[s], it is in our legitimate interest to use any personal data that you provide to us to ensure that we provide the relevant Service in an effective way.
Where we permit a third party to use your personal data contained within content that you submit, we will do so without your permission if we are satisfied that it is within our or the third party’s legitimate interest to use your personal data, including to promote our Services or services offered by the third party. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.]
Linking to social media sites and interacting with our social media pages.
If you click on one of the social media links on our Site[s] or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site[s] or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the ‘Insight, analysis and retargeting through Cookies’ section below.
Please note that the relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.
Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media.
Fulfilment of our Services.
We collect and maintain personal data that you submit to us for the purpose of supplying our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your Contact Data, Registration Data, and Payment data (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.
If you attend the Sager Head Office we will process personal data about you which you volunteer in connection with your visit and any enquiries you may have. This will usually include your Contact Data, and any other personal data you volunteer. Some Services we offer are also subject to separate terms and conditions which will also apply.
Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way.
Customer service and general enquiries.
Our Site[s] feature a “Contact Us” page which invites you to submit general enquiries about our Site[s] and our Services by email or telephone
You may also be able to submit specific enquiries on other pages of our Site[s] in relation to particular Services offered via those pages.
When you make an enquiry, we will collect and process your Contact Data and certain Profile Data, as well as any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
Our legal basis for processing
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.
Hosting and managing events.
From time to time, we may organise and host events for the purpose of community engagement and development promotion We may process your Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.
If you attend one of our events, we may use your Contact Data and certain Profile Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.
Our legal basis for processing
It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.
We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.
From time to time, we will invite you to provide feedback about us, our Site[s] or our Services in the form of online surveys, postal and email]. We will collect and process your Contact Data, certain Profile Data, and any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve our Site[s] and our Services, to assist with the selection of future service lines, and to train our personnel.
You can also voluntarily provide feedback by contacting our Customer Service team. Please see the ‘Customer service and general enquiries’ section above for more information.
Our legal basis for processing
It is in our legitimate interest to use the personal data provided by you so that we can improve our Services and provide them in an effective way.
Prize draws, prize competitions and other promotions. For more information click here.
From time to time, we may run prize draws, prize competitions and other promotions on our Site[s] and/or on our social media accounts. For the purposes of administering such draws, competitions and promotions, we may process your Contact Data, Payment Data (if relevant), Profile Data, and any other personal data volunteered by you in your prize draw, competition or promotion entry.
Our prize draw, competition and promotions may be subject to separate terms and conditions which you may be required to accept as a condition of entry.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the prize draw, competition or promotions to which you may be asked to agree) or it is in our legitimate interest to use your personal data to enable us to administer the applicable prize draws, prize competitions or promotion.
Insight, analysis and retargeting through Cookies. For more information click here.
We and our third party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the device(s) that you use to access our Site[s] [and emails that you receive from us]). The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data.
Please see our Cookie Policy for further information, including details of the third party partners that are used.
We and our third party partners use this data, in combination with your Contact Data, for the following purposes:
[for the purposes described in the ‘Online personalised advertising’, ‘Advertising to you on social media and other platforms’, and the ‘Advertising to other people who share similar interests and characteristics to you’ sections below;]
to analyse how you use, and the effectiveness of, our Site[s] and Services, including:
to count users who have visited our Site[s][ or opened an email] and collect other types of information, including insights about our visitors’ browsing habits, which helps us to improve our Site[s], Services[ and the effectiveness of our emails];
to measure the effectiveness of our content;
to learn what pages of our Site[s] are most attractive to our visitors, which parts of our Site[s] are the most interesting and what kind of features and functionalities our visitors like to see; and
to help us with the selection of future service lines, website design and to remember your preferences
[In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.]
Our legal basis for processing
Where your data is collected through the use of non-essential cookies we rely on consent to collect your data. Please see our Cookie Policy for further details.
However, we may rely on other legal basis when we use your personal data that has been collected via the use of Cookies for the purposes described in this section.
[Where we use this personal data for the purposes described in the ‘Online personalised advertising’ and ‘Advertising to other people who share similar interests and characteristics to you’ sections of this Privacy Notice, please see those sections to see the legal basis that we rely on.]
Where we use this personal data to analyse how you use our Site[s] and Services, it is in our legitimate interest to use your personal data in such a way to improve our Site and our Services.
Advertising and Marketing activities.
We carry out the following marketing activities using your personal data:
We use your Contact Data to send you (or the organisation you represent) marketing communications by post. Our postal marketing communications will include press releases and information about the development projects, as well as general information about our organisation, our Site[s], the Services we provide and the events and promotions we offer from time to time.
Our postal marketing will include personalised and non-personalised postal marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised postal marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services, events, offers and/or promotions generally and is not tailored to any particular individual.
Where we are sending you personalised postal marketing, we may also use Profile Data and Behavioural Data in order to decide what sort of personalised marketing communications to send you. Please see the ‘Insight, analysis and retargeting through Cookies’ section above for more details about the personal data collected and how it is collected.
Our legal basis for processing
Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form (for example, your postal address), it is in our legitimate interest to use your personal data for postal marketing purposes.
Email and SMS/MMS marketing . For more information click here.
We use your Contact Details to send you (or the organisation you represent) marketing communications by email, and to send you marketing communications by SMS/MMS. Our email and SMS/MMS marketing communications will include press releases and information about the development projects, as well as general information about our organisation, our Site[s], the Services we provide and the events and promotions we offer.
Our email and SMS/MMS marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services, events, offers and/or promotions generally and is not tailored to any particular individual.
Where we are sending you personalised email or SMS/MMS marketing, we also use Behavioural Data and other information that we observe about you from your interactions with our Site[s], with our email communications to you, and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the ‘Insight, analysis and retargeting through Cookies’ section above for more details about the personal data collected and how it is collected.
Our legal basis for processing
Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for postal marketing purposes.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.
Online personalised advertising.
We and our third party partners use may use your Behavioural Data, Profile Data and Technical Data and other data that is collected through your interactions with third party Site[s] and Services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the Advertising to you on social media and other platforms section below).
By ‘personalised ads’, we mean advertisements for products and services that you have shown an interest in when you have used our Site[s] or which you otherwise might be interested in based on your browsing habits, although our third party partners may use the data that is collected to show personalised ads for products and services offered by third parties.
Our legal basis for processing
Please see the ‘Insight, analysis and retargeting through Cookies’ section above to learn about the legal basis that we rely on to collect data via the use of Cookies.
Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site and our Services to you.
Our third party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy policy of the relevant third party provider, as set out in our Cookie Policy [and/or our Cookie preference centre].
Advertising to you on social media and other platforms.
We share your [email address – insert other relevant data e.g. phone numbers] ([usually] in an encrypted or ‘hashed’ form) with third party providers of social media platforms and other services, such as [Facebook, Snapchat, Sky, [insert others or describe generically]] (“Platforms”), so that the third party providers can try to ‘match’ your data with the data of their registered users of their Platforms.
Where there is a successful match, we will display our advertising to you when you use the relevant Platform (e.g. on your Facebook newsfeed). This is known as ‘custom audience’ advertising, because we ‘customise’ the audience that we want to reach on the relevant service.
Some of the advertising that you see may be personalised to you. [The data that we use to personalise our advertising, such as your Behavioural Data and Profile Data, will not be provided to the third party providers of the Platforms]. Please see the ‘Insight, analysis and retargeting through Cookies’ section above to learn more about how we personalise advertising to you.
This activity is also subject to the privacy choices you have elected to make on such Platforms.
Our legal basis for processing
[We will only share your personal data with the third party providers of the Platforms, so that we can advertise our Services to you when you use those Platforms, where you have provided your consent.]
OR
[It is in our legitimate interests to share your personal data with the third party providers of the Platforms so that we can advertise our Services to you when you use those Platforms, although where this activity is undertaken through the use of Cookies please see the Insight, analysis and retargeting through Cookies section above) to learn about the legal basis that we rely on.][You can opt-out of our sharing of your personal information with the third party providers of the Platforms by exercising your rights as set out below.]
Advertising to other people who share similar interests and characteristics to you.
We will provide your personal data to third party providers of other services as described in the Advertising to you on social media and other platforms and the ‘Insight, analysis and retargeting through the use of Cookies’ sections. If you are a user of those third party services, we may ask the third party providers of those services to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users.
This is known as ‘lookalike’ audience advertising because we are trying to show our advertising to people who ‘look like’ you.
Please note that such activity is also subject to the privacy choices you have elected to make on such services.
Our legal basis for processing
[We will share your personal data with the third party providers of other services, so that we can advertise our Services to other individuals that use those services and share similar interests and characteristics with you, where you have provided your consent.]
OR
[It is in our legitimate interests to share your personal data with the third party providers of other services so that we can advertise our Services to other individuals that use those services and share similar interests and characteristics with you, although where this activity is undertaken through the use of Cookies please see the Insight, analysis and retargeting through Cookies section above) to learn about the legal basis that we rely on.][You can opt-out of our sharing of your personal information with the third party providers by exercising your rights as set out below.]
We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include your Contact Data, Registration Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Our legal basis for processing
Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Receipt of services from suppliers.
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.
The personal data we collect from you may include your Contact Data and certain Payment Data, and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and provide our Services to others, in an effective way.
We have security measures in place at offices, development sites and constructions sites, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
Our legal basis for processing
It is in our legitimate interests to process your personal data so that we can keep our offices, development sites and constructions sites secure and provide a safe environment for our personnel and visitors to our offices, development sites and constructions sites.
Business administration and legal compliance.
We use your personal data for the following business administration and legal compliance purposes:
to comply with our legal obligations;
to enforce our legal rights;
to protect the rights of third parties; and
in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.
Our legal basis for processing
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.
If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide our Services or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services, in which case we will notify you.
How we obtain your consent
Where our use of your personal data requires consent, you can provide such consent:
• at the time we collect your personal data following the instructions provided; or
• by informing us using the contact details set out in the “How to Contact Us” section above.
Third party links and services
This Privacy Notice does not apply to your interaction with services provided by third parties.
Our Site[s] may contain links to third party websites and services.
When you use a link to go from our Site[s] to another website (even if you don’t leave our Site[s]) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider. For more information click here .
Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. For example, our website invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such platforms, you will be transferred from our website to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal data processed by us through your use of our Site[s], your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.
Sharing personal data
We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties (including other entities within our group of companies) as follows:
Third-party organisations that provide applications/functionality, data processing or IT services:
We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy .
Event partners and suppliers:
When we run events, we will share your personal data with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.
Advertising partners.
We share personal data with the third party advertising partners, including those set out in our Cookies Policy [and/or our Cookie preference centre] when you use our Site[s]. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.
Third-party email marketing and CRM specialists:
We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications.
Suppliers of postal and courier services:
We share personal data with suppliers who assist us in sending out our postal marketing communications.
Third-party organisations that assist us with the administration of our promotions:
We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
Recruitment agencies and related organisations:
We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.
Real Estate agents:
We share personal data with external agents that provide a service of selling at letting real estate and for the purposes of marketing of a development.
Auditors, lawyers, accountants and other professional advisers:
We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies:
We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Sharing with other third parties:
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site[s] and to provide our Services.
Transfers outside the European economic area (“EEA”) and the UK
Where necessary in order to operate our Site[s] and to otherwise deliver our Services, we will transfer personal data to countries outside the UK and the EEA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.
We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:
Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
How long we keep your personal data
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.
Confidentiality and security of your personal data
We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site[s] and our Services.
Personal data of children
We do not specifically target our Site[s] or our Services at children. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. However, if you are under the age of 18, you must ask a parent or guardian for permission before using our Site[s] and our products and services. If you are a parent or guardian, please supervise your child’s use of our Site[s] and our Services.
How to access your information and your other rights
You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in the ‘How to contact us’ section above.
Your 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). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification.
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal data, and we will do so, if we are:
relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal data for the purposes direct marketing.
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.
Changes to this privacy notice
We may make changes to this Privacy Notice from time to time.
To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.
