fbpx

Website privacy notice

Shaftesbury 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 General Data Protection Regulation (“GDPR”). 

1. Scope

This Notice is given by Shaftesbury PLC on behalf of itself and its subsidiaries, including Shaftesbury Chinatown PLC (“Shaftesbury”). We act as a data controller for the personal data we collect during the course of our engagement with you.
This means that we determine the purposes for and manner in which we (or our processors) process your personal data. Our registered office at 22 Ganton Street, Carnaby, London, W1F 7FD. We can be contacted by post at this address or by email at shaftesbury@shaftesbury.co.uk. Please mark any correspondence for the attention of the Company Secretary.

2. Audience

This Notice relates to range of data processing activities undertaken by Shaftesbury. 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. If you are residential tenant (either on the basis of an AST or long lease), or a guarantor of any such residential tenancy, please refer to the standalone privacy notice specific to you situation – a copy of the Residential Tenant Privacy Notice is available on request or from your letting agent. If you are a commercial tenant, please refer to the privacy notice on https://www.shaftesbury.co.uk/en/site-services/privacy-policy.html

2.1 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
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. 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 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 any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 only share the information we collect with our suppliers to the extent necessary for them to perform their services to us. This will be our website providers. 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 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 newsletters, then you have consented to us processing that information. We have a legitimate interest in administering, protecting and improving 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.

2.2 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 a Shaftesbury office, 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. When visiting our properties, which include Carnaby, 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. 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 take specific or close up images of individuals, we will seek your consent.

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 advisors; 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 villages 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.

2.3 Social media followers and competition entrants

We have active social media accounts for Shaftesbury PLC, Soho, Carnaby, Chinatown and Seven Dials, including on Facebook, Instagram, Twitter, LinkedIn, 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 villages. 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 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 do not make any automated decisions using this information.


3. WHAT THIS PRIVACY NOTICE COVERS

3.1 This Notice covers:

  • what personal data we collect about you;
  • how we collect personal data;
  • why we process personal data;
  • the transfer of any personal data outside the UK and/or the EEA;
  • the transfer of any personal data outside the UK and/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; and
  • 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:

  • Residential Tenant Privacy Notice – please see reference above
  • Shaftesbury PLC Privacy Notice – please see reference above

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 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:

  • As a visitor to our premises, we may process health related information such dietary requirements and accident details.
  • 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 tenancy.

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:

  • internal business and regulatory requirements, including valuation of the property portfolio in line with accounting standards, undertaking audits, archiving etc;
  • exercising and/or defending our legal rights,
  • 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 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 always 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 are set out in paragraph 4.2 of this Data Privacy Notice. Where we process special categories of data it will be justified by a condition set out at paragraph 5.2 above and also by one of the following additional conditions:

  • based on your explicit consent;
  • 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);
  • 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
  • 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.

6.7 Please note that we may process your personal data without your knowledge, in compliance with the above rules, where this is required or permitted by law.

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”) 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:

  • to service providers, agents and advisors appointed by us (e.g. such as our managing agents, letting agents, solicitors, auditors, credit reference agencies, IT providers and other processors);
  • to a prospective buyer in the event of a sale, merger or restructuring of any part of our business;
  • to any company within the Shaftesbury group of companies; or
  • to any regulatory agency or enforcement body 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. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data about you in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.2 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.

10.3 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.

10.4 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 privacy notice at any time and we will make the revised privacy 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 25 February 2022.

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 privacy notice, please contact the Company Secretary, either by post at Shaftesbury Chinatown PLC, 22 Ganton Street, Carnaby, London, W1F 7FD or by email at shaftesbury@shaftesbury.co.uk

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.

Schedule 1: GLOSSARY

Data Controller: means a natural or legal person which determines the means and purposes of processing of personal data.

Data Subject: means an individual whom the personal data is about.

EEA: means the European Economic Area.

GDPR: means the General Data Protection Regulation (EU) 2016/679. References to the GDPR also include the equivalent regime implemented in the UK by the Data Protection Act 2018.

ICO: the Information Commissioner's Office regulates the processing of personal data by all organisations within the UK.

Legitimate Interests: this is a ground which can be used by organisations as a lawful basis of processing, for example where personal data is used in ways that could reasonably be expected, or there is a compelling reason for the processing.

Member States: means those countries which are part of the European Union.

Service Providers: these are a range of third parties to whom we outsource certain functions of our business. For example, we have 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.