PRIVACY & COOKIES POLICY
We, 20 Fenchurch Street (GP) Limited, are committed to protecting the privacy of anyone who visits our website (the “Website”) or registers to use our services. As part of our commitment, we have thus adopted certain measures in relation to the collection, use, retention, disclosure, transfer, security and accessibility of your personal data in order to comply with the requirements laid down in the European Data Protection Legislation and the UK Data Protection Act 2018.
Whilst we make every effort to protect your personal data, no security measures can guarantee that your personal data and information will not be subject to interference, misuse or hacking and we shall not be responsible for any loss, misuse or alteration arising as a result of such incidents.
1. Your Use of this Website
Use of this Website constitutes your agreement to the terms of this Policy and the application of any applicable laws and regulations. Whenever you submit Personal Data and any other information via this Website, you acknowledge that data and information will be collected, used and disclosed in accordance with this Policy.
2. Data Protection Legislation
It is our policy to comply with the UK Data Protection Act 2018 and the European Data Protection Legislation as described below to the extent it applies to the Personal Data we process about you (the UK Data Protection Act 2018 and the European Data Protection Legislation jointly referred to as the “Data Protection Legislation“).
For the purposes of this Policy, “European Data Protection Legislation” means all applicable legislation relating to data protection in the European Economic Area (“EEA”), including the EU General Data Protection Regulation 2016/679 (“GDPR”) and all legislation implementing or made under or pursuant to or replacing or superseding the GDPR. Where this Policy uses terms which are defined in the GDPR, the definitions set out in the GDPR will apply.
“Personal Data” is data relating to you from which you can be reasonably identified. Examples of Personal Data include your full name, email address, postal address, telephone number, job title or the company you work for. We recognise that your Personal Data is valuable and we process it in accordance applicable law, and to the extent that it applies to your Personal Data, with European Data Protection Legislation.
3. Data controller
We are responsible as data controller for the processing of your Personal Data collected on the Website under the European Data Protection Legislation (to the extent that it applies to Personal Data collected about you) and other applicable law.
4. Types of Personal Information We Collect
When we need to collect personal data from you to provide you with our service, we will ask you to voluntarily supply us with the information we need. The information collected includes but is not limited to:
- Email address
- Mobile/contact phone number
5. Purpose of Personal Data Collection
You acknowledge and agree that such personal data will be used by us for the following purposes:
- The provision of the services offered by us, including general administration and record keeping. In these circumstances, we will use your Personal Data to perform an agreement with you because we would be unable to provide those services without that information;
- To respond to requests for information and services. We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests about the services and facilities you require and to develop the relationship between us in the context of your use of our services and facilities.
- To facilitate direct marketing, promotional and customer management purposes, including sending you information about our services, promotional communications or special offers, if you have consented to receive them as further described under Section 9 (Direct Marketing).
6. Information we collect from you browser and your device
When you visit the Website, we may automatically collect information about your interaction with the Website such as your IP address, traffic data, clickstream information, time stamp, location data, web logs, other communication data and the resources that you access . We automatically collect this data using various technologies such as cookies ,web logs and beacons as described below. This data is primarily used for delivering and optimising services offered by us, such as:
(a) authenticating your identity and remembering certain data for the purposes described in “Purposes of Personal Data Collection” above;
(b) providing you with relevant, personalised content in order to help us focus on what you are most interested in; and
(c) improving our services, whereby we may occasionally display different versions of content to you and measure your usage of our Website pages. To the extent this information constitutes Personal Data, we use it to ensure that content from the Website is presented in the most effective manner for you and your device because it is in our legitimate interest to improve our customers’ online experience in relation to the Website.
Microsoft Internet Explorer
choose the “tools” menu then “Internet Options”;
click on the “privacy” tab; and
select the appropriate setting.
choose the “tools” menu then “Options”;
click on the “privacy” menu then “Options”;
click on the “privacy” icon; and
find the “cookie” menu and select the relevant options.
7. Disclosure and Transfer
We do not sell, rent or lease your Personal Data to third parties without your consent. However, we will share Personal Data to further our business operations and as described below. By visiting the Website, you agree to disclosures to the following third parties:
- advertisers, which may collect aggregated statistics from the Website;
- other companies and individuals which we employ to provide certain services such as email marketing services (e.g. analysing customer lists, deliverability statistics, opens and clicks), marketing assistance or consulting services. These third parties may have access to information needed to perform their function but cannot use that information for any other purpose;
- our service providers and sub-contractors for the performance of any contract we enter into with them or you;
- our business partners, but only to the extent you have purchased or expressed an interest in a product or service of such business partner or interacted with or otherwise authorised the sharing of your Personal Information with such business partner;
- our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information;
- a purchaser or successor entity in the event of a sale or other corporate transaction involving some or all of our business or as needed to affect the sale or transfer of business assets, or as needed for external audit, compliance or corporate governance related matters;
- any of the affiliates and the parent company of 20 Fenchurch Street (GP) Limited, and any company in which the same has a direct or indirect interest or with which it is in joint venture or co-operation with or their respective successors and assigns;
- any actual or proposed assignee or transferee of 20 Fenchurch Street (GP) Limited; and
- any other person under a duty of confidentiality to 20 Fenchurch Street (GP) Limited.
We reserve the right to disclose any personal data and information we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations.
In addition, we may make certain disclosures in answering your query or providing you with our services.
8. Storage and transfer of your Personal Data to Other Countries
If you provide Personal Data to us, it may be transferred to, processed in, stored at or accessible from a destination outside the European Economic Area (“EEA”), such as any country in which we, our affiliates or our service providers maintain facilities. All practical steps are taken to ensure that all data is treated confidentially, kept secure and protected against unauthorised or accidental access, processing, erasure or other use and is maintained and kept no longer that is necessary for the purpose for which it is intended.
Where we pass your Personal Data from a location inside the EEA to parties located outside the EEA that do not offer adequate protection as determined by the European Commission, or post Brexit, from a location inside the UK to parties located outside the UK that do not offer adequate protection as determined by the UK’s Information Commissioner’s Office or any applicable legislation in the UK, and if these parties are not subscribed to an approved data protection framework, such as the EU-US Privacy Shield that permits us to transfer the Personal Data to them from the EEA, we will enter into agreements which enable us to transfer Personal Data to them and that enable you to exercise your rights in accordance with the Data Protection Legislation. A copy of these terms can be obtained by emailing us at firstname.lastname@example.org .
9. Direct marketing
When you opt-in to receive communications from us, you are giving your consent for your Personal Data to be used by us to contact you (depending on your selection) by email, direct mail and telephone and to deliver personalized Website experiences, to share information about relevant services, news and events and our offering, including but not limited to residential, offices, commercial and industrial buildings, shops, hotels, serviced apartments, shopping malls and the events, restaurants, bars, food & beverage promotion, banquet and conference services, membership programmes, surveys by e-mail or telephone on our service quality, educational, recruitment, charitable and non-profitable causes.
We may not use your Personal Data for direct marketing purpose unless we have received your consent. Your consent may also be communicated to us without charge by checking the opt-in / consent box in this Website or by writing to email@example.com or by post at 1 Poultry, London, EC2R 8EJ. When you enter your contact details for the purposes of receiving marketing communications and click “sign up”, you will be consenting to us contacting you for these purposes.
You may opt-out from receiving marketing communications at any time with no additional charges, by:
- Following the “opt-out” instructions contained in the communications;
- Contacting us by mail, email or phone20 Fenchurch Street Limited
a: 1 Poultry, London, EC2R 8EJ
(Please indicate “Opt-out from receiving marketing communications”)
Withdrawing your consent will not affect our use of the Personal Data prior to you withdrawing that consent but it will mean that we will not be able to contact you about the services we may be able to offer you or your business in the future. When your opt-out request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
We will let you know where you must provide us with Personal Data in order to perform an agreement with you or to comply with a legal obligation. If you do not provide us with the Personal Data in these circumstances, we will be unable to respond to your enquiry and/or engage in further communications with you.
10. Data Retention and Security
We will only retain Personal Data from you for as long as needed to fulfil the purposes for which we have initially collected it and to provide you with our services, unless otherwise required by law. All Personal Data will be retained only as necessary to comply with our legal obligations.
We will delete our copy of your Personal Data within 60 days from the end of our last contact with you although we may retain a record of the existence of the relationship, to the extent and for so long as we are required to do so by law. For example, if you have contacted us to ask us for the processing of your Personal Data to be erased, we will retain a record of your request in order to ensure we comply with your wishes.
To the extent that you have consented to receive marketing communications from us, we will retain your personal data for a full year starting from our last contact with you, unless you take any action to opt out of marketing communications in accordance with Section 9.
We will take all practicable steps to ensure the data held by us are protected against unauthorized or accidental access, process, erasure or other use.
11. Changes to the Policy
The Policy may be modified from time to time. Any changes to our Policy will become effective upon posting of the revised policy on the Website. We encourage you to periodically review our Policy so that you are always informed of the way we collect and use your personal data.
12. Your rights
With respect to the Personal Data that we collect about you from the Website, to the extent that you are located in the EEA, under the European Data Protection Legislation you have the right to:
a) request access to that Personal Data;
b) receive a copy of the Personal Data that you have provided to us in a structured, commonly used and machine readable format so that you can share it with others;
c) request the transfer of your Personal Data to another party;
d) ask that Personal Data be erased;
e) object to us possessing your Personal Data by asking for the processing of that Personal Data to be restricted or stopped. For example, if we use Personal Data for marketing purposes; and
f) make a complaint to a European data protection authority about the manner in which we process your Personal Data. The contact details for the European data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authori…
Please contact us in accordance with section 13 (Contact Information) to exercise these rights or for additional information.
13. Contact Information
If you wish to contact us about the privacy-related matters described above or find out more information about our privacy practices, please use the contact details below:
20 Fenchurch Street (GP) Limited
(Registered no. 07243935)
1 Poultry, London, England, EC2R 8EJ
Last updated: November 2019