CUSTOMER INFORMATION CONTACT US THE ESTATE EXPLORE OUR PROPERTY STEWARDSHIP NEWS PROJECTS Cadogan Privacy Notice This notice explains how Cadogan Group Limited and its subsidiaries (referred to in this notice as (Cadogan, we, us or our) is a controller for the personal information that it collects and uses about you. Any reference in this privacy notice to you or your refers to anyone whose personal information we process. This privacy notice is to inform you about: ◙ What personal information is; ◙ How we collect your personal information; ◙ The types of personal information we collect; ◙ How we use your personal information; ◙ The legal basis for processing your personal information; ◙ What will happen if you do not provide the information we request; ◙ How we share your personal information; ◙ How we keep your personal information secure; ◙ What will happen if you email us; ◙ Overseas transfers of your personal data; ◙ Your rights in relation to your personal data; ◙ How to make complaints in relation to your personal data; and ◙ How to contact us. The table at the end of this notice provides an overview of the data that we collect, the purposes for which we use that data, the legal basis which permits us to use your information and the rights that you have in relation to your information. Any references to personal information in this privacy notice will include all personal data, and where relevant, special categories of personal data. Any reference to Group refers to the subsidiary companies of Cadogan Group Limited. We will treat all your personal information as confidential and in accordance with the Data Protection Legislation and your personal information may only be shared with others in accordance with this privacy notice. This notice does not form part of any contract to provide services. We keep this privacy notice up to date, so if there are any changes to the way in which your personal information is used this privacy notice will be updated. What is personal information? Personal information is any information that tells us something about you. This could include information such as your name, contact details, date of birth, medical information and bank account details. How do we collect personal information? We collect personal information about you from various sources including: ◙ when you provide information on any of the Group websites; ◙ from you when you contact us or any member of the Group directly by telephone, email or letter; ◙ information which is provided to us on behalf of your legal advisors and/or managing agents in relation to a lease if you are a tenant or are applying for a tenancy with us; ◙ from credit reference agencies who provide us with financial information such as your credit score if you are applying for a tenancy with us. ◙ when you enter into our concierge service membership; ◙ when you enter into a garden membership; ◙ when you enter into a tennis membership and/or book a court through our online system; ◙ when we contact you during our relationship with you; ◙ where we require your consent and/or permission for building works and/or access which affects you; ◙ when we enter into a contract with you either as a contractor or a consultant to provide a service to the Group. What information do we collect? We collect the following categories of information about you: When you contact any member of the Group by telephone, email or post: ◙ personal contact details such as name, title, address, telephone number and personal email addresses. As a residential or commercial tenant: ◙ personal contact details such as name, title, address, telephone number and personal email addresses; ◙ date of birth; ◙ nationality; ◙ gender; ◙ personal references; ◙ employment details ◙ marital status and dependents; ◙ next of kin emergency details; ◙ information about your health including any health conditions and/or disabilities; ◙ information about criminal convictions and offences committed by you; ◙ financial information about you including credit score; ◙ bank account details; ◙ corporate information including audited accounts; ◙ any directorships held; ◙ shareholder information; ◙ a copy of your passport; ◙ a copy of any visa to work and/or reside in the UK; ◙ a copy of utility bills; ◙ details of study; ◙ land registry information; ◙ home ownership details; ◙ any forwarding address; ◙ information relating to any insurance claims; ◙ identifiers from your passport, driving licence or other ID card; and ◙ CCTV footage and other information obtained through electronic means such as swipe cards. As a member of our gardens, tennis courts or concierge service: ◙ personal contact details such as name, title, address, telephone number and personal email addresses; date of birth; ◙ nationality; ◙ gender; ◙ personal references; ◙ employment details; ◙ next of kin emergency details ◙ identifiers from your passport, driving licence or other ID card; ◙ CCTV footage and other information obtained through electronic means such as swipe cards. How do we use your information? We use your information for the following purposes: When you contact any member of the Group by telephone, email or post: ◙ sending you our newsletter and other subscriptions that you have requested; and ◙ to develop, improve and market our services. As a residential or commercial tenant: ◙ to carry out background checks relating to you prior to entering into a lease or membership (including anti-money laundering, financial and credit checks); ◙ managing and administering your lease (in accordance with the terms) and the property to which it relates, including the collection of sums payable under the lease; ◙ to carry out any of our obligations under the terms of the lease including the refunding of your appropriate rent deposit; ◙ the management of any alterations to the property requested by you under the terms of the lease; ◙ when arranging access to your property as and when required, where access is required under the lease or to comply with our legal obligations; ◙ notifying you about changes to the lease; ◙ enforcing the terms of a lease; ◙ in respect of any court claim or legal compliance; ◙ proof of ownership; ◙ poof of address; ◙ instructing our approved contractors to carry out any building work and/or maintenance; ◙ sending you our newsletter and other subscriptions that you have requested; and ◙ to develop, improve and market our services. As a member of our gardens, tennis courts or concierge service: ◙ managing and administering your garden, tennis court and /or concierge membership with the Group; ◙ notifying you about changes to the lease or membership; ◙ enforcing the terms of a lease or membership; ◙ in respect of any court claim or legal compliance; ◙ any activities in connection with the sale, merger or acquisition of any member of the Group; ◙ sending you our newsletter and other subscriptions that you have requested; and ◙ to develop, improve and market our services. As a neighbouring owner, tenant, or landlord: ◙ to notify and/or obtain your consent for any building works to our properties which affect you as an adjacent property owner, landlord or tenant. What is the legal basis that permits us to use your information? Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your information: ◙ Where we need information to perform the contract we have entered into with you. ◙ Where we need to comply with a legal obligation. ◙ 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. The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights. Some information is classified as “special” data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions, sexual orientation and trade union membership. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process special categories of personal information and criminal conviction information in the following circumstances: ◙ In limited circumstances with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent. ◙ Where you have made the information publicly available. What happens if you do not provide information that we request? We need some of your personal information in order to perform and administer our contract with you and to comply with our legal obligations. For example, we need information about your identity to satisfy our money laundering obligations and we need your contact information in order to administer tenancy arrangements. Where information is needed for these purposes if you do not provide it we will not be able to perform our contract with you and may not be able to continue with our relationship. We explain when this is the case at the point where we collect information from you. How do we share your information? We share your personal information in the following ways: As a residential or commercial tenant: ◙ any referencing agencies who will confirm the information you have provided; ◙ utility companies in respect of the administration and provision of the relevant utility to the property which you are a tenant ◙ instructing any of our contractors where work and/or maintenance is required to anything owned and/or managed by Cadogan; ◙ we may share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators in order to comply with our regulatory and legal obligations; As a member of our gardens, tennis courts or concierge service: ◙ any referencing agencies who will confirm the information you have provided; ◙ instructing any of our contractors where work and/or maintenance is required to anything owned and/or managed by Cadogan; ◙ when booking / arranging reservations at restaurants, purchasing tickets, arranging a private car or any other amenity offered by our concierge service which requires interaction with a third party. ◙ we may share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators in order to comply with our regulatory and legal obligations; Where we share your personal information with third parties we ensure that we have appropriate measures in place to safeguard your personal information and to ensure that it is solely used for legitimate purposes in line with this privacy notice. How do we keep your information secure? We store your personal data as set out below: ◙ electronically held data on local drives and shared folders are password protected by IT to restrict access to the appropriate personnel; and our IT systems have firewalls and appropriate security measures in place. ◙ We ensure access to personal information is restricted to employees on a need to know basis. When do we transfer your information overseas? When data is transferred to countries outside the UK and the European Economic Area those countries may not offer an equivalent level of protection for personal information to the laws in the UK. Where this is the case we will ensure that appropriate safeguards are put in place to protect your personal information. The countries to which your personal information may be transferred are detailed below: ◙ New Zealand Your rights in relation to your information You have a number of rights in relation to your personal information, these include the right to: ◙ be informed about how we use your personal information; ◙ obtain access to your personal information that we hold; ◙ request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate; ◙ request that we erase your personal information in the following circumstances: • if Cadogan is continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected; • if Cadogan is relying on consent as the legal basis for processing and you withdraw consent; • if Cadogan is relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing; • if the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or • if it is necessary to delete the personal data to comply with a legal obligation; ◙ ask us to restrict our data processing activities where you consider that: • personal information is inaccurate; • our processing of your personal information is unlawful; • where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim; • where you have raised an objection to our use of your personal information; ◙ request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information; ◙ object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate basis which entitles us to continue to process your personal information; ◙ not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you. If you would like to exercise any of your rights or find out more, please contact the Finance Director at Cadogan’s offices. The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights. Complaints If you have any complaints about the way we use your personal information please email : dataprotectionofficer@cadogan.co.uk. If we cannot resolve your complaint, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). 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