Date last revised: June 2018
This policy sets out how personal data is processed by Shoreditch Investment and Management Limited (UK company number 05256374). We are the data controller in relation to all personal data we process in connection with the management, sale or rental of our properties. Our registered office is on 81 Rivington Street, London, EC2A 3AY.
Whether you buy or rent a property from us, or visit the website of The Shoreditch Ltd at www.longandwaterson.com (Website), we will collect a range of categories of your personal data. We recognise that this data belongs to you and we have a duty to protect it. Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to provide our services to you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
- This policy
1.1 This policy sets out how we will process your personal data. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 1998 (Act) and/or the General Data Protection Regulation (Regulation), as applicable.
1.2 By visiting our Website, or showing an interest in any of our properties, you understand, accept and consent to the practices described in this policy.
1.3 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
1.4 For more information relating to your rights under this policy, please see section 8.
1.5 If you have any queries relating to this policy, please contact us by [email protected] in the first instance.
- Who we are
2.1 For the purposes of the Act, we are the data controller. We are registered with the ICO to process your personal data and our registration number is ZA378111
2.2 We process personal data in connection with our properties, including the new-build apartments located in Shoreditch, known as the Long & Waterson Apartments. This property is owned by our affiliated company, The Shoreditch Limited, registered in Guernsey (company number 58004). This is a non-EEA territory deemed to ensure adequate protection for personal data.
2.3 Limited categories of residual personal data are held by another of our affiliated companies, Middlewater Trading & Investments Limited (registered in Cyprus with company number HE98627) which used to own a number of our properties, some of which were recently sold.
2.4 All data processed through our Website is stored by our hosting company, Krystal (number 07571790), whose registered office is atAlta Vista, Higher Warberry Road, Torquay, Devon, TQ1 1SD. More information can be found here: https://krystal.co.uk/
- What we will collect (and how we get it)
3.1 Where you are interested in one of our properties, we will receive your name, email address and telephone number. This is either provided to us directly by you when you visit our Website (to register your interest or request a callback) or where we receive it from estate agents (with whom we advertise) when you register or make an enquiry with them, or where you respond to any of our online marketing campaigns outside of our Website.
3.2 Where you are, or have been, a tenant of ours, we process:
- Your name, email address and telephone number;
- Former residential address(es);
- Date of birth;
- Any personal data contained on your passport or driving licence;
- Bank details;
- Details relating to your next of kin;
- Names, addresses, emails, bank and employment details relating to your nominated guarantors and previous landlords; and
- Any information we obtain from your credit file when running checks.
This information is provided by you (or your guarantors), external lettings agencies or reference or credit rating agencies.
3.3 Where you progress with buying one of our properties, we will process your contact details (name, email address and telephone number) and home address, identification (passport) and any personal data relating to your solicitor (including name and contact details) to enable us to correspond with them in connection with your purchase
3.4 Where you are a supplier to us of any products or services, the relevant company within our group (with whom you have contracted) will take your contact details in order to correspond with you in connection with the services or products you are providing to us.
3.5 Where you are a current, potential or former employee, worker or other member of our staff, we may collect additional categories of your personal data for the purposes of providing you with the necessary benefits under our contract with you. In those circumstances, a separate privacy notice applies and a copy is available on request.
3.6 When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings. We also monitor your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.
- What we do with your data
4.1 We process your personal data when you are interested in buying or renting one of our properties, or you supply related services to us, or you are a member of our staff. As such, in nearly all cases, we process your personal data in order to perform a contract we have with you. In those few, minor circumstances where this does not apply, we process personal data only to pursue our legitimate business interests, and we only do so in ways that do not infringe your fundamental rights and freedoms.
4.2 We consider the personal data we obtain is reasonable and necessary for the purposes set out in section 4.1. However, we review this intermittently and remove any inaccurate or obsolete data.
4.3 All hard copy documents and records (that may contain your personal data) are stored, externally with a third party based in the UK (details have been withheld for confidentiality purposes).
4.4 Where you register your interest in any of our properties with us directly, by any means, we will (in most circumstances) automatically refer your details to our appointed estate agents, Knight Frank LLP, a limited liability partnership registered in England (number 0C305934) with its registered office at 55 Baker Street, London W1U 8AN. We have appointed agents to advise you of the specifications of our properties, to answer any related queries, and to arrange viewings, on our behalf, on the terms of a written agreement. They are also an appointed intermediary to negotiate sales and purchases on our behalf.
4.7 Where you purchase one of our properties, your personal data may be transferred to our appointed latent defects structural and home warranty insurance provider, through www.checkmate.uk.com (a division of Lockton Companies LLP, who are FCA regulated). Any personal data we provide to them will be solely for the purposes of managing and implementing your insurance policy.
4.8 Technical information we collect about your visit to our Website is used to enable us to:
- personalise and improve its functionality and security (to keep it safe and secure);
- administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and
- ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary.
5.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer (with your consent). Cookies contain information that is transferred to your computer’s hard drive. By continuing to use our Website, you agree to our use of the cookies stated in this section.
5.3 Our Website uses the following cookies:
- Targeting cookies – these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make it, and the advertising displayed on it, more relevant to your interests. Such cookies include _uuid, run through ads.avocet.io.
- Functionality cookies – these are used to recognise you when you return to the Website. This enables us to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works (for example, by ensuring that users are finding what they are looking for easily); and
- Strictly necessary cookies – these are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to view and provide details on specific webpages.
5.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.
- How long we keep your data for
6.1 Where you are interested in connection with purchasing one of our properties, we will only retain your data for as long as you remain interested in that purchase. We may automatically market to you (using the contact details we already have) about similar properties of ours where you do not purchase one of our properties and we reasonably consider that we may have another property (in a similar location and of a similar budget) that may be of interest. We do not require your consent to market to you in these limited circumstances.
6.2 Any personal data you provide to estate agents appointed on our behalf in connection with the purchase or letting of any of our properties, or www.checkmate.uk.com in connection with the insurance cover you obtain, will be retained by those agents in accordance with their privacy and internal data retention/destruction policies.
6.3 Where we enter into any contract with you, such as for the supply of goods and services, or purchase or rental of a property, or any employment contract, we will retain all details we need in connection with that contract for its term and for up to 6 years following its termination (after which time, we will securely delete your information).
6.4 Where we retain your contact details for marketing purposes, these will only be retained for so long as you have permitted us to contact you for these purposes. Where you opt out, we will remove your details from our marketing database(s), including notifying any third party who carries out marketing services on our behalf. We will, also, not prompt you to opt back in at any time.
- How secure your data is with us
7.1 We are careful to ensure that access to your personal data is restricted to those within our organisations who reasonably need to know in order to perform their various functions, as follows:
- Buyers (actual or potential) are processed by our marketing manager, accounts department and COO only;
- Former tenants’ details are handled by our marketing, accounts and property managers;
- Supplier details are handled by our accounts team and marketing manager; and
- Employee/staff details are handled within our accounts department only (for contractual benefits administration purposes).
7.2 Our systems are configured to ISO27001 standards.
7.3 Our databases are securely stored, centrally, on UK-based servers. These are backed-up, daily, on a local NAS.
7.4 All electronic documents and records are backed up by our external IT supplier, IT4U Limited, whose registered office is at 28 Lechi street, Beni-Brak 5120045, post address P.O.B 472 Raanana, Israel 4310401. Israel is a territory deemed to ensure adequate protection of personal data and, at the date this policy was last revised, this transfer does not require your express consent (but we review this intermittently).
- Your rights
8.1 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Act or the Regulation) to ask us:
8.1.1 not to process your personal data for marketing purposes;
8.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
8.1.3 to amend any inaccurate data we hold about you;
8.1.4 to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
8.1.5 to only process your personal data in limited circumstances, for limited purposes.
8.2 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).
8.3 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
8.4 Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.