Grosvenor Britain and Ireland – Privacy Notice


Privacy Notice

1. Introduction

This Privacy Notice sets out how Grosvenor Britain and Ireland (“GBI”) obtains, uses and protects your personal information when carrying out its business activities. For the purpose of this Privacy Notice, ‘we’, ‘us’ and ‘our’ refers to one of the GBI data controllers (which are listed in the Annex) and ‘you’ refers to you (the data subject).

2. Privacy Notices

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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