This Privacy Notice sets out how Grosvenor Asia Pacific Limited and its direct or indirect subsidiaries, associated companies, holding companies or any of its holding companies’ direct and indirect subsidiaries and associated companies (‘we’, ‘us’ and ‘our’) may obtain, use and disclose personal information relating to our personnel, contractors and business partners (‘you’) for our electronic document signature portal (currently provided by Docusign).
What information do we process about you?
We may collect the following personal information about you:
- Name and email address;
- Electronic signature (including time/stamp and other logs);
- IP Address, system IDs, cookie information and other digital logs collected automatically when you use our document signature portal; and
- Personal information which may be contained in document for signature (including, for example, physical signature, job title, physical address, phone number, date of birth, human resources information (such as bank account number, health and diversity information).
Why do we process information about you?
We process your personal information for the following purposes:
- Agreement and execution of contracts and other documents
- Providing a document signature portal, including verifying your login information, remembering your portal activity and preferences to personalise your experience if you return to the portal from the same computer or mobile device and taking reasonable steps to secure the portal and other users from misuse;
- Exercising legal rights, in connection with any dispute or litigation, complying with demands or requests made by government and law enforcement authorities, and complying with court orders (or equivalent);
- 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; and
- Any activities connected with any sale, merger, acquisition, disposal, reorganisation or similar change of our business.
Do we share your personal information?
We may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described above:
- Other Grosvenor Estate entities, particularly our parent companies / entities, who may need to understand and review documents we have signed;
- Our service providers, including third parties providing the document signature portal, 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).
Storing and transferring your personal information
Our document management portal is hosted in the United Kingdom. Your personal information contained in signature documents and relating to your use of our document signature portal will generally be retained for 90 days in accordance with our document retention procedures.
Documents and information in our portal may be accessed from anywhere in the world by us or any other third parties described in Section 3. Where personal information is transferred across borders, we require the transfer and/or the recipient to be subject to such protections as required by applicable privacy and data protection laws (such as contractual clauses approved by the relevant national or regional privacy or data protection authority or equivalent).
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 processors (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.
Your privacy rights
Depending on the type of personal information, why it is being processed, your location and which of our companies you are dealing with, you may have rights under applicable data protection and privacy laws. 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 a copy of your personal information we hold about you.
- A right to correct inaccurate or incomplete personal information we hold about 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 about you once it is no longer necessary for the purposes 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.
If you are not satisfied with our response, please note that you may also be able to complain to your local government agency which regulates the protection of personal information:
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.