PRIVACY POLICY HOME PRIVACY POLICY PRIVACY NOTICE DATA PROTECTION PRIVACY NOTICE We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you. WHAT IS PERSONAL INFORMATION? Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie. WHO WE ARE Faro Property Holdings Limited is made up of different legal entities. This privacy policy is issued on behalf of the Faro Property Holdings Limited Group so when we mention Faro Property Holdings Limited, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the controller for your data where it is not Faro Property Holdings Limited. Faro Property Holdings Limited is the data controller responsible for this website. Where we have investments or subsidiaries with their own privacy policies these are not listed below. Faro Group Companies: Faro Property Holdings Limited Faro Properties I Limited Faro Properties II Limited Faro Properties III Limited Faro Properties IV Limited Faro Properties VI Limited Faro Properties VII Limited Faro Properties VIII Limited Astbury Hall Limited Astbury Hall Operations Limited Name or title of DPO or relevant contact: Kazim Kanani Postal address: Faro Property Holdings Limited, 39 Sloane Street, SW1X 9LP Telephone number: 0203 174 2382 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. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. WHAT TYPES OF INFORMATION DO WE USE? We may collect, use, store and transfer different kinds of personal data about you. If you are a tenant, supplier, consultant, borrower, visitor, guest or employee, most of the data we hold will have been provided by you. This includes but is not limited to: Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact Data includes home address, email address and telephone numbers. Financial Data includes bank account details. Transaction Data includes details about payments to and from you and other details of services you have obtained from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Profile Data includes your username and password. Usage Data includes information about how you use our website and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. CONSEQUENCES OF NOT PROVIDING SOME TYPES OF INFORMATION Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the products and services you asked for. In this case we may have to cancel the product or services but we will tell you if this is the case. HOW DO WE COLLECT INFORMATION ABOUT YOU? We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you: apply for our services; create an account on our website; subscribe to our service or publications; request marketing or other information to be sent to you; give us feedback or contact us. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We will receive personal data about you from various third parties including property agencies, recruitment agencies, marketing data providers and independent financial advisers. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from publicly available sources such as Companies House HM Land Registry, the Land Registries of Scotland, the Electoral Register and credit reference agencies. HOW WE WILL USE YOUR PERSONAL INFORMATION We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation. Please see the glossary below to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new tenant, supplier, contractor, consultant, borrower or employee (a) Identity (b) Contact Performance of a contract with you To process and manage our obligations to you and your obligations to us, which will include: (a) Managing payments, fees and charges (b) Collecting and recovering money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to analyse how our services are used To enable you to complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how our services are used, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, services, marketing, business relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our services and grow our business) MARKETING We can use your personal information to send you communications if we believe we have a ‘legitimate interest’. We are required to make an assessment with regards to the benefits for us weighed against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you. You are free to change your mind at any time by selecting the email preferences link which you will find at the bottom of all marketing communications or by contacting us or using any contact you already have. PROMOTIONAL OFFERS FROM US We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. THIRD-PARTY MARKETING We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. OPTING OUT You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any transaction that you have entered into with us. COOKIES 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 more information about the cookies we use, please see our Cookie Policy. CHANGE OF PURPOSE We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data with the parties set out below for the purposes set out in the table above Internal Third Parties as set out in the glossary. External Third Parties as set out in the glossary. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. INTERNATIONAL TRANSFERS We do not transfer your personal data outside the European Economic Area (EEA). DATA SECURITY 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. DATA RETENTION How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements. By law we have to keep basic information about those who use our services (including Contact, Identity, Financial and Transaction Data) for six years after they cease using our services for tax purposes. In some circumstances you can ask us to delete your data. Please see below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary to find out more about these rights: Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data. Right to withdraw consent. If you wish to exercise any of the rights set out above, please contact us. NO FEE USUALLY REQUIRED 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 could refuse to comply with your request in these circumstances. WHAT WE MAY NEED FROM YOU 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. TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. Occasionally it could 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. GLOSSARY LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. THIRD PARTIES INTERNAL THIRD PARTIES Other companies in the Faro Property Holdings Limited Group acting as joint controllers or processors and who may provide IT and system administration services and other services. EXTERNAL THIRD PARTIES Service providers acting as processors who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, accountants, property agents and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, Land Registries, Company Registrars, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. YOUR LEGAL RIGHTS 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 data 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 successfully 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data's accuracy. Where our use of the data is unlawful but you do not want us to erase it. 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. 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. 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. PHONE +44 (0) 203 174 2382 ADDRESS 39 SLOANE ST, KNIGHTSBRIDGE, LONDON, SW1X 9LP TERMS & CONDITIONS PRIVACY POLICY © COPYRIGHT FARO CAPITAL 2021. HANDCRAFTED BY CM SYSTEM DESIGNS TO THE TOP REGISTERED IN ENGLAND AND WALES NO: 04393349. REGISTERED ADDRESS: 39 SLOANE STREET, KNIGHTSBRIDGE, LONDON, ENGLAND, SW1X 9LP THIS SITE USES COOKIES TO STORE INFORMATION ON YOUR COMPUTER. Some of these cookies are essential, while others help us to improve your experience by providing insights into how the site is being used. NECESSARY COOKIES Necessary cookies enable core functionality such as page navigation and access to secure areas. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences. ANALYTICS These cookies help us to understand how the website is being used so we can improve it for our users Analytics On Off About this tool External Link Icon Cookie Control