2.1 If you are a tenant or a representative of a tenant of a Grosvenor property
2.1.1 How do we collect personal information about you?
Information provided directly by you
- We collect personal information that you provide to us or which is provided to us on your
behalf by your
legal advisors and/or managing agents in relation to your or organisation’s lease (including
contact details
and Know Your Client due diligence information).
- If you are a tenant or representative of tenant of an office or retail unit, you may provide
information
about your commercial or retail performance to us (or a third party on our behalf). We
consider this
personal information if it relates to you as an individual.
- You may provide information directly to us about your preferences to receive marketing.
- We may also receive information about your opinions, interests and preferences if you
complete surveys and
feedback forms for us or if you have attended events that we host
Information from other sources
- If you access our websites, cookies may be set on your device. Information about cookies are
explained in
our website cookie policy.
- We may collect personal data about you which is publicly available from reputable sources,
where you might
expect your information to be read by the public. This includes professional profiles
(LinkedIn, corporate
biographies etc.), resources such as Companies House and the Charity Commission, media
coverage and
third-party publications such as The Sunday Times Rich List.
2.1.2 What personal information may we process about you?
We may process any or all of the following personal information that relates to you:
- your name, date of birth, place of birth and nationality;
- your email address, postal address, telephone and mobile number;
- your bank account details;
- identifiers from your passport, driving licence or other ID card; and
- details of the products and services that you specify in your marketing preferences,
provided we have
received your consent to do so
- personal and financial references
- details of the products and services that you specify in your marketing preferences,
provided we have
received your consent to do so
- your preferences and interests that you have expressed
2.1.3 What we may process your personal information for
We process your personal information for the following purposes:
- carrying out our standard Know Your Client background checks relating to you prior to you
entering into the
lease (including sanctions, anti-money laundering, financial and credit checks);
- managing and administering the lease and the property to which the lease relates, including
the billing of
sums payable under the lease and the management of any alterations to the property that are
requested by
you;
- carrying out our obligations under the lease, including the refunding of the appropriate
proportion of your
deposit on the termination or expiry of the Lease and the arrangement of your access to
nearby secured
gardens and squares (if provided for under the Lease);
- enforcing the terms of the lease or notifying you about changes to the lease;
- arranging our access to your property as and when required, including where our access is
required in order
for us to comply with our legal obligations;
- making decisions about you continuing as a tenant when your tenancy expires and making
arrangements for the
termination or expiry of your lease, including managing and administering our relationship
and any related
communications with you;
- if relevant, enforcing the terms of the ‘Belgravia Estate Management Scheme’ and ‘Grosvenor
Mayfair Estate
Management Scheme’, which provide a framework of management for the continued conservation
of the Belgravia
and Mayfair areas of London;
- analysing trends and performance of individual office and retail units, as well as
collective performance
across streets and areas;
- informing you about developments and changes in the vicinity which may impact you living in
your property;
- building a profile of your interests and preferences (including your potential to support
our charitable
work) and informing you about opportunities to support fundraising and charitable events
based on our
profile;
- sending you electronic marketing communications about news and events that we believe may be
of interest to
you, provided we have received your consent to do so
- combining tenant addresses with public data sets for internal research purposes to
understand the property
market and long term trends
- complying with any applicable present or future law, rule, regulation, guidance or
directive, and complying
with any applicable industry or professional rules and regulations or any applicable
voluntary codes;
- complying with demands or requests made by government and law enforcement authorities, and
complying with
court orders (or equivalent), or in connection with any litigation; and
- activities connected with any sale, merger, acquisition, disposal, reorganisation or similar
change of our
business.
2.1.4 Who we may share your personal information with
We may share your personal information with any of the following recipients as may be necessary
or desirable for
the purposes described above:
- Grosvenor Estate entities that own GBI businesses, own assets managed by GBI business or
provide services to
GBI businesses and their respective employees;
- our banks and investors;
- our service providers, including legal and financial advisors, managing agents, management
surveyors,
research and analytics providers, insurance brokers, debt recovery agents, hosting service
providers and
communications and marketing providers;
- government, regulators, law enforcement authorities, courts, tribunals and arbitrators,
other judicial
committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, financing, reorganisation or
similar change
to our business (including any potential or actual purchaser or that business and that
purchaser’s
advisors).
All third parties to whom we transfer personal information relating to you will be under an
obligation to protect
the confidentiality and security of that personalinformation.
2.1.5 Retention of your personal information
For audit and financial reasons, we will hold your personal information on our systems for 3
years following the
date on which the Lease terminates or expires. We may continue to hold your personal information
for a longer
period if required to do so by applicable law.
2.2 If we manage your property on behalf of a third party
2.2.1 How do we collect personal information about you?
Where we provide property management services for a third-party landlord for a property which is
not owned by
Grosvenor, we will be provided with information by you or that landlord in order to carry out
and charge for
these services. This will include contact details about the tenant, banking details, access to
the building.
2.2.2 What personal information may we process about you?
We may process any or all of the following personal information that relates to you:
- Your contact details
- your bank account details;
- property management queries relating to you; and
- your preferences and interests that you have expressed.
2.2.3 What we may process your personal information for
We process your personal information for the following purposes:
- providing property services to you and/or the landlord for the effective managing and
administering the
property, including the billing of sums payable under the relevant management agreement;
- arranging our access to your property as and when required, including where our access is
required in order
for us to comply with the landlord’s legal obligations;
- carrying out our standard Know Your Client background checks, including sanctions screening;
- sending you electronic marketing communications about news and events that we believe may be
of interest to
you, provided we have received your consent to do so
- complying with any applicable present or future law, rule, regulation, guidance or
directive, and complying
with any applicable industry or professional rules and regulations or any applicable
voluntary codes;
- complying with demands or requests made by local and foreign regulators, governments and law
enforcement
authorities, and complying with any subpoena or court process, or in connection with any
litigation; and
- activities connected with any sale, merger, acquisition, disposal, reorganisation or similar
change of our
business.
2.2.4 Who we may share your personal information with
We may share your personal information with any of the following recipients as may be necessary
or desirable for
the purposes described above
- other members of our company groups and their respective employees;
- our banks and investors;
- our service providers, including legal and financial advisors, managing agents, management
surveyors,
insurance brokers, debt recovery agents, hosting service providers and communications and
marketing
providers;
- regulators, governments, law enforcement authorities, courts, tribunals and arbitrators,
other judicial
committees and enactments of laws;
- persons connected with any sale, merger, acquisition, disposal, financing, reorganisation or
similar change
to our business (including any potential or actual purchaser or that business and that
purchaser’s
advisors).
All third parties to whom we transfer personal information relating to you will be under an
obligation to protect
the confidentiality and security of that personalinformation.
2.2.5 Retention of your personal information
We will hold your personal information on our systems for as long as we manage the relevant
property. We may
continue to hold your personal information in accordance with our IT backup procedures and for a
longer period
for accounting, audit and legal reasons (including if required to do so by applicable law).
2.3 If you are a member of a Grosvenor garden or square
2.3.1 How do we collect personal information about you?
We collect personal information from the forms that you submit to us as well as through email,
written and verbal
correspondence.
2.3.2 What types of personal information may we process about you?
If you apply to access one of Grosvenor’s squares or gardens you may provide us with
- your name, email address, postal address, telephone, mobile numbers and bank details. You
may also provide
details of your dog(s).
- details of the products and services that you specify in your marketing preferences,
provided we have
received your consent to do so
2.3.3 What we may process your personal information for
We process your personal information to screen your application and assess your eligibility for
our services
including
- Garden membership and access
- Parking arrangements
- Dog registration
- Garden and arboriculture maintenance
- Tennis membership
- Garden parties and event organisation
- to advise and invite you to suitable events
- in the logistics of providing our services to you.
We may also process your personal information to carry out our standard Know Your Client
background checks,
including sanctions screening.
2.3.4 Who we may share your personal information with
We may share your personal information with Grosvenor employees and selected third parties acting
who act on our
behalf such, as tree surgeons and event organisers. These approved parties provide our service
to you which may
be necessary or desirable for the purposes described above.
All third parties to whom we transfer personal information relating to you will be under an
obligation to protect
the confidentiality and security of that personal information.
2.3.5 Retention of your personal information
We will hold your personal data on our systems while you are a member or continue to use our
services and for as
long afterwards as it is in the our legitimate interest to do so or for as long as is necessary
to comply with
our legal obligations e.g. compliance with tax requirements and exemptions, and the
establishment, exercise or
defence of legal claims.
2.4 If you are requesting permission to make alterations to your property
2.4.1 How do we collect personal information about you
If your property is subject to the provisions of the Grosvenor Mayfair Estate Management Scheme
or the Belgravia
Estate Management Scheme we will process your personal information in connection with your
application to make
alterations to your property. We collect personal information that you provide to us or which is
provided to us
on your behalf by your advisors on the application form.
2.4.2 What types of personal information may we process about you?
We may process any or all of the following personal information that relates to you:
- your name,
- your email address, postal address, telephone and mobile number;
- your bank account details.
2.4.3 What we may process your personal information for
We process your personal information to enforce the terms of the ‘Belgravia Estate Management
Scheme’ and
‘Grosvenor Mayfair Estate Management Scheme’, which provide a framework of management for the
continued
conservation of the Belgravia and Mayfair areas of London;
- Review of the proposal by internal and 3rd party engineers
- Collection of fees, and return of refundable deposit
- Visit the property
- Review the works during the alterations and on completion
- Manage the deposit and return the fee on completion of the works
We may also carry out our standard Know Your Client background checks, including sanctions
screening.
2.4.4 Who we may share your personal information with
We may share your personal information with any of the following recipients as may be necessary
or desirable for
the purposes described above
- other members of our company groups and their respective employees;
- our service providers, including legal and financial advisors, managing agents, management
surveyors,
insurance brokers, debt recovery agents, hosting service providers and communications and
marketing
providers;
- regulators, governments, law enforcement authorities, courts, tribunals and arbitrators,
other judicial
committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, reorganisation or similar
change to our
business (including any potential or actual purchaser or that business and that purchaser’s
advisors).
All third parties to whom we transfer personal information relating to you will be under an
obligation to protect
the confidentiality and security of that personalinformation.
2.4.5 Retention of your personal information
For audit and financial reasons, we will hold your personal information on our systems for 3
years following the
date when any refund due to you has been repaid or 3 years after your application has been
rejected. We may
continue to hold your personal information for a longer period if required to do so by
applicable law.
2.5 If you visit our websites
2.5.1 What personal information do we hold?
We collect and processes the following personal information from you:
- First and last name, email address, telephone number and postcode (if you provide them to
us)
- Details of preferences for marketing events or materials you wish to receive; and have given
us consent
- Details of access to our websites and applications including, but not limited to, traffic
data, location
data and other communication data (such as IP addresses), and the pages that are accessed.
2.5.2 How we collect this personal information
We collect information (including personal information) when you visit our websites and if you
contact us via
email or phone.
As you navigate through websites, certain information may be passively collected (that is,
gathered without you
actively providing the information). This is done by using various technologies and means, such
as cookies and
navigational data collection. You can alter how or if you receive cookies via your web browser
settings. Please
read the cookie policy for specific websites to check what data is gathered.
When you visit websites, we collect your Internet Protocol (IP) address. An IP address is a
number assigned
to your computer by your Internet service provider so that you can access the Internet.
Grosvenor uses your IP
address to diagnose problems with our server, to report aggregate information, to determine the
fastest route
for your computer to use in connecting to this Website, and to administer and improve this
Website. We use
Google Analytics for collecting this data.
In addition, we gather information such as what browser and which version of it you are using,
the type of
operating system you have, your internet service provider and which site you came from. If you
access this
website via your mobile device, we may also collect information about your mobile provider and
your mobile
device. This information allows us to recognise when your device accesses our website.
2.5.3 What we may process your personal information for
We may use the information we collect about you to:
- improve the content of websites to ensure that content is presented in the most
effective manner for
you and for your computer;
- customize websites to your preferences;
- communicate with you (including via email or SMS where such contact details have been
provided);
- provide you with the information about our products and services that you request from us;
- notify you of any changes to our services; and
- administer our Websites and for internal operations, including troubleshooting, data
analysis, testing,
research, statistical and survey purposes.
2.5.4 When we may disclose your personal information
We may disclosure your personal information to third parties if they are best placed to handle
your request. For
instance, if you request information about buying a house, we will pass your details to the
appropriate
housebuilder.
We may disclose your personal information with third parties such as analytics and search engine
providers that
assist us in the improvement and optimisation of our websites.
All third parties to whom we transfer personal information relating to you will be under an
obligation to protect
the confidentiality and security of that personal information.
2.5.5 How long will we hold your personal information
We will retain your personal information for as long as necessary to fulfil your request, such as
to provide
marketing information where requested. Website analytics is not generally accessible to us in a
personalised
form and in is held in accordance with our provider’s retention practices.
2.6 When we engage with the community
2.6.1 What personal information do we collect about you?
We collect information that you provide to us if you attend an event that we host such about
potential
developments or other activities on the Grosvenor Estate. This will include name, title, phone,
email. We may
record what events you have attended and who at Grosvenor knows you. We may also record your
preferences and
opinions if you provide them to us.
We may access contact information that is in the public domain, such as from an organisation’s
website or
publications or other publicly available sources.
We may also commission third party online engagement platforms to display information about our
development. They
may collect data about you when you use their platform as explained in their privacy policy.
They may share some
of this data with us such your contact details and preferences (if you have provided them).
2.6.2 What personal information may we process about you
We may process any or all of the following personal information that relates to you:
- Your name, title, phone, email which you provide when you attend an event or access our
websites.
- Opinions, preferences and feedback that you might provide
2.6.3 Why we use your personal data
We may use the information we collect about you to
- Advise you about our developments
- Invite you to events which we think will be of interest to you
- Ensure that we provide a consistent and effective contact with you
- Receive your feedback (where provided) about our development
2.6.4 Who we may share your personal information with
We may share your details with website platform providers, our PR companies working on our behalf
and other
service providers.All third parties to whom we transfer personal information relating to you
will be under an
obligation to protect the confidentiality and security of that personalinformation.
2.6.5 How long we retain your personal information
Your personal data is retained for the duration of our relationship with you as a contact or
until the
development is completed.It may be retained for longer if necessary for legal reasons. You can
request that we
delete your details at any time.
2.7 Business contacts
2.7.1 How do we collect personal information about you?
If you are a supplier, we will collect information that you will provide to us to complete our
new supplier
process. This will include your name, contact and financial details. We may also obtain
references.
If you are a business contact or other stakeholder we collect information that you provide to us.
This will
include your name, employee name, title, phone address and email. We may record what events you
have attended
and who at Grosvenor knows you and what areas of interest you have in Grosvenor’s business and
services.
If you are a personal representative of our business contacts, Grosvenor Trustees or
non-executive directors we
will collect information that you have provided to us. This will include you name, employee
name, title, phone,
address and email.
We may sometimes access contact information that is in the public domain, such as from an
organisation’s website
or publications or other publicly available sources. We may collect personal data about you
which is publicly
available from reputable sources, where you might expect your information to be read by the
public. This
includes professional profiles (LinkedIn, corporate biographies etc.), resources such as
Companies House and the
Charity Commission, media coverage and third-party publications such as The Sunday Times Rich
List.
2.7.2 What personal information we may process about you
- Contact information
- Financial details (if you are a supplier)
- Events you may have attended
- Your preferences, and areas of interest
2.7.3 What we may process your personal information for
We may use the information we collect about you to
- Manage our supplier relationship
- invite you to events which we think will be of interest to you
- inform you about our range of services.
- Building a profile of your interests and preferences (including level of potential
charitable donations) and
informing you about opportunities to support fundraising and charitable events based on out
profile.
2.7.4 Who we may share your information with
Your personal data is held on secure internal systems accessed by selected Grosvenor teams. Third
parties may
have access to your data for mailshots or printing direct mail. All third parties to whom
we transfer
personal information relating to you will be under an obligation to protect the confidentiality
and security of
that personal information.
2.7.5 Retention of your personal information
Your personal data is retained for the duration of our relationship with you as a contact, or
your personal
representative. You can request we delete your details at any time.
2.8 Anonymised Information
We (or third party processors on our behalf) may process your personal information in order to
generate anonymous
statistical information and we may use this for any purpose (including strategic business
planning or management
decisions).
We also generally allow our third party process (such as those providing cloud services to us) to
process your
personal information to generate anonymous statistical information in order to improve their
products and
services.
We may also receive anonymous reports and analysis from third party data controllers that have
been prepared
using personal information that they or their business partners collect about you (for example,
footfall
analysis). Those third parties are responsible for providing notice and obtaining consent where
required by
applicable data protection laws.
3. Your rights regarding the personal information you provide to us
UK data protection laws provide you with rights concerning your personal information. These may
include:
- A right to receive information about our processing of your personal information, such as
what is collected,
where it is obtained from, what it is used for, whether it is disclosed and to whom.
- A right to receive or port a copy of the personal information we hold on you in a
structured, commonly-used
and machine-readable format.
- A right to correct inaccurate or incomplete personal information we hold on you.
- A right to require us to stop or to restrict our processing (including transfer to third
parties) of your
personal information (particularly where unlawfully used or obtained).
- A right to require the erasure of personal information we hold on you once it is no longer
necessary in
relation to the purposes for which the personal information was collected or is being
processed.
If you wish to exercise any of these rights, or if you have a complaint about how we manage your
personal
information, please contact us using the details in section 7.
4. Legal grounds for processing personal data
We process personal information if at least one of the following bases applies
- To comply with our legal obligations to you, such as our obligations as a landlord
- To comply with contractual obligations, such as in a lease or other agreement
- To meet our legitimate interests, for example to inform you of our services, or providing
new services. We
must ensure that if we process personal data to meet our legitimate interests we have
ensured that our
legitimate interests are not overridden by your interests or fundamental rights and
freedoms.
We may ask for your consent to processing personal data as required by law, in relation to direct
marketing and
in relation to processing sensitive data. If you provide your consent you can withdraw that
consent at any time
by contacting us.
5. Data Transfers
We (or third parties working for us) may store your personal data on systems anywhere in the
world, including in
particular the UK, Europe and the US. Where your personal data is transferred outside of the
United Kingdom to a
country that the applicable authorities do not consider to have laws providing adequate
safeguards for your
personal information, we (or third parties working for us) will ensure the data importer is
subject to Standard
Contractual Clauses approved by the European Commission (unless an exemption applies under
applicable data
protection laws).
6. Security Warnings
Please note that messages you send to us by e-mail or via any internet connection may not be
secure. If you
choose to send any confidential information to us by such means you do so at your own risk with
the knowledge
that a third party may intercept this information and we do not accept any responsibility for
the security or
integrity of such information.
Please also take time to consider the legitimacy of any communications purporting to be from us
or third parties
working on our behalf. Do not respond to requests for payment or click on links unless you know
they are not
malicious. If in doubt, please contact us via other means.
7. Contact
If you have any questions, comments or requests regarding any aspect of these privacy notices,
please contact our
Data Protection Officer by email at: dataprotectionGGL@grosvenor.com.
Should you not be satisfied with our response and remain concerned your personal data is not
being processed in
accordance with UK data protection law, you also have the option of raising the matter with the
Information
Commissioner’s Office (https://ico.org.uk/).
August 2020
Annex
Grosvenor Companies / Data Controllers
Our primary data controller is Grosvenor Estate Management Ltd.
However, for particular purposes, other GBI businesses may instead control the processing of your
personal data:
- Belgravia Leasehold Properties Ltd
- Drummond Road
- Eaton Square Properties Ltd
- Grosvenor (Mayfair) Estate
- Grosvenor Estate Belgravia
- Grosvenor Investments Ltd
- Grosvenor Properties
- Grosvenor Property Management Services Ltd
- Grosvenor West End Properties
- London Leasehold Flats Ltd
- London Leasehold Investments LLP
- Mayfair Leasehold Properties Ltd
- Southwark GP 2 Ltd
- Southwark Real Estate Investments Ltd
- 2nd Duke of Westminster Trust
- Grosvenor Developments Ltd
- Grosvenor Eighty Six LLP
All of these companies have their registered office at 70 Grosvenor Street London W1K 3JP
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