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Barts Square First Limited Privacy Notice

INFORMATION THAT IS GATHERED FROM VISITORS
In common with other websites, log files are stored on the web server saving details such as the visitor's IP address, browser type, referring page and time of visit.
Cookies may be used to remember visitor preferences when interacting with the website.

Where registration is required, the visitor's email and a username will be stored on the server.

HOW THE INFORMATION IS USED
The information is used to enhance the vistor's experience when using the website to display personalised content and possibly advertising.

E-mail addresses will not be sold, rented or leased to 3rd parties.

E-mail may be sent to inform you of news of our services or offers by us or our affiliates.

VISITOR OPTIONS
If you have subscribed to one of our services, you may unsubscribe by following the instructions which are included in e-mail that you receive.
You may be able to block cookies via your browser settings but this may prevent you from access to certain features of the website.

COOKIES
Cookies are small digital signature files that are stored by your web browser that allow your preferences to be recorded when visiting the website. They may also be used to track your return visits to the website. To find out more about the cookies we use on this website, visit our Cookies page

3rd party advertising companies may also use cookies for tracking purposes.

GOOGLE ADS
Google, as a third party vendor, uses cookies to serve ads.

Google's use of the DART cookie enables it to serve ads to visitors based on their visit to sites they visit on the Internet.

Website visitors may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Table of Contents

Key summary   1. Key summary

About us and this notice   2. About us and this notice

Useful words and phrases   3. Useful words and phrases

What information do we collect?   4. What information do we collect?

Why do we process your personal data?   5. Why do we process your personal data?

How is processing your data lawful?   6. How is processing your data lawful?

Who will have access to your personal data?   7. Who will have access to your personal data?

When will we delete your data?   8. When will we delete your data?

Your rights   9. Your rights

Key summary   1. Key summary

We (Barts Square First Limited) process your data in order to administer the reservation, subsequent purchase and leasehold of a property at Barts Square, to manage our relationship with you, to administer and protect our business and this website and to provide you with information that you request the receive.

Savills UK Limited (‘Savills’), as our agent, process your data on our behalf and plays an important role in this relationship as they pass information from your reservation form to us and respond to any queries you may have. Find out more information about Savills privacy policy.

Knight Frank LLP (‘Knight Frank’), as our building manager, also process your data on our behalf and will be another important figure once you have purchased your property. They collect rent and service charge, operate the concierge, cleaning and maintenance of the common areas, operate the building management and maintenance, buildings insurance, waste collection and operation of the residents' amenities.This notice explains what data we process, why, how it is legal and your rights.

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About us and this notice   2. About us and this notice

This Privacy Notice is provided by Barts Square First Limited, company number 09100507 with registered address, 5 Hanover Square, London, W1S 1HQ ("Landlord " or "we" or "our"). We are controllers for the purposes of the General Data Protection Regulation (EU) 2016/679. This Privacy Notice sets out how we use your data in order to administer your reservation ("Reservation") and subsequent purchase of a property at Barts Square ("Purchase"), and to keep in touch with you and send you information that you request to receive.

The pages on this website are published by me&dave Limited (‘Me & Dave’).

As data processors acting on behalf of Barts Square First Limited, Savills, Knight Frank and Me & Dave are required to comply with this policy.

We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.

How to contact us
If you would like to get in touch with us in relation to this Privacy Notice please contact us at the details below.

Development Executive

  • Name: Nikki Dibley
  • Address: Helical plc, 5 Hanover Square, London, W1S 1HQ
  • Telephone number: 020 7629 0113
  • Email: nd@helical.co.uk

Changes to this Privacy Notice
The Privacy Notice can be found on our website at http://www.bartssquare.com/disclaimer

We may change this Privacy Notice from time to time. We will alert you on our website or by email when changes are made.

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Useful words and phrases   3. Useful words and phrases

Please familiarise yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice:

Personal Data
This means any information from which a living individual can be identified. 

This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs, voice recordings.  It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions).

It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.

Sensitive Personal Data or Special Categories of Data
This means any information relating to:

  • racial or ethnic origin;
  • political opinions;
  • religious beliefs or beliefs of a similar nature;
  • trade union membership;
  • physical or mental health or condition;
  • sexual life;
  • genetic data or biometric data for the purpose of uniquely identifying you; or
  • offences or alleged offences or information relating to any offences committed or allegedly committed.

Processing
This covers virtually anything anyone can do with personal data, including:

  • obtaining, recording, retrieving, consulting or holding it;
  • organising, adapting or altering it;
  • disclosing, disseminating or otherwise making it available; and
  • aligning, blocking, erasing or destroying it.

Data Subject 
The person to whom the Personal Data relates.

Information Commissioner
The UK Information Commissioner is responsible for implementing, overseeing and enforcing the Data Protection Laws.

Controller
This means any person who determines the purposes for which, and the manner in which, any Personal Data are processed.

Processor
This means any person who processes the Personal Data on behalf of the data controller.

Data Protection Laws
This means the laws which govern the handling of Personal Data. This includes the General Data Protection Regulation (EU) 2016/679 and any other national laws implementing that Regulation or related to data protection.

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What information do we collect?   4. What information do we collect?

Personal data provided by you
When you make your Reservation we collect the following information about you:

  • Name
  • Address
  • Phone number
  • Email address
  • Date of birth
  • Bank account/credit card details
  • Employment information    
  • Current property ownership information
  • Reason for purchase

When you use this website, we will collect the following information about you:

Technical data – this includes:

  • Internet protocol (IP) address
  • Browser type and version
  • Time zone setting and location
  • Browser plug-in types and versions
  • Operating system and platform and other technology on the device you use to access this website

Usage data – this includes:

  • Information about how you use this website and our products/services

Marketing and communications data – this includes:

  • Your preferences in receiving marketing from us and our third parties
  • Your communication preferences

We process your contact details when you contact us, send us feedback, or raise any complaints.

We also collect, use and share aggregated data, such as statistical and demographic data for any purpose. Aggregated data may be derived from your personal data, but it is not considered to be personal data in law as this data does not directly or indirectly reveal your identity. We may, for example, use your usage data to calculate the percentage of users accessing a specific website feature. If we combined or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

Sensitive personal data provided by you
We do not collect any sensitive personal data about you.

Personal information about other individuals
If you provide us with information about other individuals, for example if the purchase is to be in joint names, you confirm that you have informed the relevant individuals accordingly and have provided them with a copy of this Privacy Notice.

Personal information provided by third parties
Savills will carry out ID verification, credit and anti-money laundering checks in relation to you and your Purchase and will share the results with us. If you fail these checks we will not be able to proceed with the Purchase.

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Why do we process your personal data?   5. Why do we process your personal data?

We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (please see section 'How is processing your data lawful' for further detail).

We collect your information to:

  • Process and assist with your Reservation and Purchase;
  • After your Purchase, provide information to other companies which will provide services to you within the property that you have Purchased (please see section 'Who will have access to your personal data');
  • Fulfil our obligations to you as landlord by providing building management, waste collection, resident amenities etc;
  • Respond to your enquiries;
  • Improve our services offered to you by listening to any feedback or complaints you may have and analysing your interaction with us; and
  • Carry out ID, credit and anti-money laundering checks.
  • To manage our relationship with you; including notifying you about changes to our privacy policy.
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant website content, news and publications to you and to measure or understand the effectiveness of the communications we serve to you.
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
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How is processing your data lawful?   6. How is processing your data lawful?

We are allowed to process your personal data for the following reasons and on the following legal basis:

Contract
It is necessary for us to carry out our obligations under the terms and conditions of the Reservation with a view to progressing your Reservation to the Purchase and to undertake the Purchase itself.

After the Purchase has completed, we have contractual obligations as your landlord.

If you do not provide your personal data to us, we will not be able to administer your Reservation or complete the Purchase.

Consent
If you have provided us with your consent to enable us to send you marketing information about Barts Square. You can withdraw your consent to receive such information by unsubscribing at the bottom of marketing emails we send to you about Barts Square. You can also withdraw your consent by contacting us at any time, using the details included above.

Legitimate interests
We are permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in the interest of Barts Square First Limited. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. In that regard, we ask for your employment information for developing our marketing activities in the future.

We rely on legitimate interest to do the following:

  • manage our relationship with you;
  • to administer and protect our business and this website
  • to use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
  • to deliver relevant website content, news and publications to you (unless by direct marketing for which we rely on your consent); and
  • to measure and understand the effectiveness of the communications we serve to you.

Legal obligation
We are subject to legal obligations to process your data for the purposes of complying with applicable accounting and financial rules, complying with health and safety requirements and to make mandatory disclosures to law enforcement.

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Who will have access to your personal data?   7. Who will have access to your personal data?

We share your personal data with the following entities who act on our behalf. This list is comprehensive at the time of writing but in the future could include other Barts group companies; a person who takes over our business and assets, or relevant parts of them; other suppliers or sub-contractors for the performance of any contract we enter into with them.

Who information is shared with Personal Data
Savills UK Limited (‘Savills’), as our agents, who process your personal data in order that they can register you and administer your Reservation and Purchase. Information provided by you when making the Reservation.
Charles Russell Speechlys LLP, as our solicitors (and joint data controllers), who process your personal data in order that they can prepare documents in relation to your Reservation and Purchase. Information provided by you when making the Reservation.
Knight Frank LLP ('Knight Frank'), as our building management company, who process your personal data in order that they can provide building management services such as collecting ground rent and service charge, operating the concierge, cleaning and maintenance of the common areas, building management and maintenance, buildings insurance, waste collection and operation of the residents' amenities.

Knight Frank LLP will only receive your personal data upon completion of your Purchase.
Your name, contact details and property purchased.
BuildingLink.com, LLC who process your personal data in order to provide an online portal which provides services such as enabling you to report problems, book amenities and arrange for keyholding. All building related documentation will be stored on the portal and this will be the primary medium of communication between yourself and the building management team. We will share your personal data for Building Link to create an account for you.

If we do not share your personal data with Building Link, you will need to use manual processes and emails to communicate with the building management team, ask for access to documentation, book amenities etc. An account with Building Link, whilst it is not a requirement, allows for a single point of contact to manage your interaction with the building management team.

Building Link will only receive your personal data upon completion of your Purchase.

Please refer to http://www.buildinglink.com/Marketing/Public/privacy-policy for information on how Building Link processes your personal data.
Your name and contact details.
Our IT related service providers who process your personal data in order to host and maintain our systems. Some of our IT is provided by The Final Step Limited. Information provided by you when making the Reservation.
me&dave Limited who process your personal data to administer and protect this website and to deliver relevant website content, news and publications to you. Your technial usage and marketing and communication data.
Crimtan Holdings Limited who process your personal data to help use manage our relationship with you, this includes carrying out ‘profiling’ activities to ensure you receive relevant marketing information. Your marketing cookies (profile data –  your perceived interests ascertained through your use of the website)
You can withdraw your consent which is relied upon to process your technical marketing data at any time by contacting us or by amending the cookies settings used when you visit our website. See our cookies policy for more information.  
If you would like to know the names of all our service providers, please contact us using the details at the start of this Privacy Notice.  

In addition, we share your personal data with the following entity who act as a separate controller of your personal data:

Citigen (London) Limited in order to secure the supply of heat and cooling to the purchased property in time for first occupation.

If we do not share your personal data with Citigen, it will mean that your property will not have heating, hot water or cooling supply.

Citigen will only receive your personal data upon completion of your Purchase.
Please refer to https://www.eonenergy.com/privacy/use-of-your-personal-data for information on how Citigen processes your personal data.
Your name, contact details, property purchased and meter related information.

Please note that we are not be responsible for the processing of your personal data by Citigen (London) Limited as they are a separate controller. If you have any queries or complaints in relation to the processing of your personal data by them, please contact them separately using the contact information provided in their website.

Transfers of your personal data outside the EEA
We will not be transferring your personal data outside the EEA.

How we keep your data secure
We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.
If you have any particular concerns about your information, please contact us (see ‘How to contact us?’ above).

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When will we delete your data?   8. When will we delete your data?

We will delete the information that we hold about you when we no longer need it.

If your Purchase completes, we will retain all of your data for the duration of your leasehold and 10 years after you assign or sell your leasehold.

If your Purchase does not complete, we will retain all of your data for 10 years from the date that the Purchase process terminates.

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Your rights   9. Your rights

As a data subject, you have the following rights under the Data Protection Laws:

  • the right to object;
  • the right of access to personal data relating to you;
  • the right to correct any mistakes in your information;
  • the right to ask us to stop contacting you with direct marketing;
  • rights in relation to automated decision making; 
  • the right to restrict your personal data being processed;
  • the right to have your personal data ported to another data controller (e.g. if you decide to contract with a different service provider); and 
  • the right to erasure.

These rights are explained in more detail below, but if you have any comments, concerns or complaints about the use of your personal data by us, please contact us (please refer to section "How to contact us").

When you contact us to exercise your rights, you will need to let us have enough information to identify you (e.g. account number, date of birth).

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.

Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.

If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed "How is processing your personal data lawful".

Right to access personal data relating to you
You may ask to see what personal data we hold about you and be provided with:

  • a copy;
  • details of the purpose for which it is being or is to be processed;
  • details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
  • the period for which it is held (or the criteria we use to determine how long it is held);
  • any information available about the source of that data; and
  • whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.

To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.

Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:

  • email, call or write to us (see "How to contact us"); and
  • let us know the information that is incorrect and what it should be replaced with.

Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you with marketing materials at any time. If you would like to do this, please:

  • email, call or write to us (see "How to contact us"). Or you can also click on the ‘unsubscribe’ button at the bottom of any email. It may take up to a few business days for this to take place; and
  • provide us with details of your preferred method of contact (for example, you may be happy for us to contact you by email but not by telephone).

Rights in relation to automated decision making
We do not make any automated decisions about you so this right does not apply.

Right to restrict processing of personal data
You may request that we stop processing your personal data temporarily if:

  • you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
  • the processing is unlawful but you do not want us to erase your data;
  • we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
  • you have objected to processing because you believe that your interests should override our legitimate interests.

Copies of your personal data (data portability)
You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.

Right to erasure
You can ask us to erase your personal data where:

  • you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;
  • if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
  • you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
  • your data has been processed unlawfully or have not been erased when it should have been.

Complaints to the regulator
It is important that you ensure you have read this Privacy Notice - and if you do not think that we have processed your data in accordance with this notice - you should let us know as soon as possible. Similarly, you may complain to the Information Commissioner's Office. Information about how to do this is available on his website at www.ico.org.uk.

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