Grosvenor Property UK – Privacy Notice

1. Introduction

This Privacy Notice sets out how Grosvenor Britain & 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. Our use of personal data

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?

We collect information about you either:

when it is provided directly by you (e.g. when you send it to us via email, submit information our apps or websites or when completing one of our paper or online forms or surveys); and/or
from other sources:
1. estate agents and/or legal advisers (who will pass to us information that you provided or they have obtained from public sources);
2. your employer (if you are a representative of a tenant);
3. public sources (including via our background / risk screening companies); and
4. automatically generated by our systems when you use our websites and applications

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:

Information provided directly by you

your name, date of birth, place of birth, gender and nationality;
your email address, postal address, telephone and mobile number;
your bank account details;
your passport, driving licence or other ID documents; and
personal and financial references
your marketing and other preferences and interests that you have expressed

Information from other sources

Public information / media reports regarding sanctions you may be subject to, your activities (for example, your corporate appointments, any financial difficulties and criminal or civil court cases) and any political exposure.
Information about your interaction with our websites, social media pages, applications and emails if you visit or receive them, including via cookies which may be set on your device. See our Cookie Notice for more information.

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 managing the termination or expiry of your lease;
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

In addition to the third parties described in the “Common Data Sharing” section below, we may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described above:

our service providers (for example, those who provide or help us to manage our properties, IT systems, background/risk screening, payments and debt collection).

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

2.1.5. Retention of your personal information

We will generally hold your personal information on our systems for the duration of your or your employer’s lease plus up to 6 years following termination or expiry (except for your passport, driving licence and other ID documents which we will only retain as long as needed to perform the check and for a reasonable period thereafter in case of issues). However, we may continue to hold your personal information for longer periods in accordance with our IT backup procedures or for legal, accounting or financial reasons.

2.2. If you let or use a property we manage on behalf of a third party

2.2.1. How do we collect personal information about you?

Where you let or use a property owned by a third-party landlord for whom we provide property management services, we may be provided with information by you or that landlord in order to carry out and charge for these services.

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 (including your job title if your use of the property is connected with your employment);
your bank account details (where we are responsible for collecting rent and/or other charges);
property management queries relating to you; and
your marketing and other 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 to comply with the landlord’s legal obligations;
carrying out our standard due diligence / Know Your Client background checks, including sanctions and risk 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

our service providers (for example, those who provide or help us to manage properties and our IT systems, background/risk screening, payments and debt collection); and
the third party landlord who owns the property you let or use (who may also use the information as explained in their privacy policy which they make available to you).

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

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 plus up to 6 years following termination or expiry of your lease or last use of the property. We may continue to hold your personal information for a longer period in accordance with our IT backup procedures or for legal, accounting or financial reasons.

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 and risk screening.

2.3.4. Who we may share your personal information with

our service providers (for example, those who provide or help us to manage our IT systems, trees/gardens, parking, events, background/risk screening, payments and debt collection).

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

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 plus up to 6 years following termination or expiry of your membership / use of our services. We may continue to hold your personal information for a longer period in accordance with our IT backup procedures or for legal, accounting or financial reasons.

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 when you submit your application to make alterations to your property.

We collect personal information that you provide to us directly or which is provided to us on your behalf by your advisors on the application form. We may also collect information from background / risk screening companies and public sources.

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; and
other details necessary to conduct background checks/risk screening (including sanctions and risk checks)

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 3^rd 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 use the information to carry out our standard due diligence / Know Your Client background checks, including sanctions screening.

2.4.4. Who we may share your personal information with

our service providers (for example, those who provide or help us to manage our IT systems, building surveying, background/risk screening, payments and debt collection).

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

2.4.5. Retention of your personal information

We will process your information while we process your request plus up to 6 years after completion of your request. We may continue to hold your personal information for a longer period in accordance with our IT backup procedures or for legal, accounting or financial reasons.

2.5. If you visit our websites or use our apps

2.5.1. What personal information is collected?

We collect and process the following personal information:

All visits: Details of access to our websites and applications including: time/date, traffic, and location data, technical data (such as browser or application version, device and operating system, internet service provider, IP addresses and cookie IDs) and details of the pages accessed and how you accessed them. Please read our Cookie Notice for more details.
If you ask us to contact you using our webform: First and last name, email address, telephone number and postcode and details of your correspondence with us.
If you request or consent to receive marketing from us: Details of preferences for marketing events or materials you wish to receive. See the section of this privacy notice titled “If you agree to receive email marketing from us” for more information.
If you choose to purchase goods or services from our websites or applications:
- Name, contact details, billing address and delivery address
- Account password (if you choose to save your details)
- Details of the products and/or services purchased
- Details of your payments (note that your credit/debit card details will be collected by our payment provider and are not processed by us).
- Details of any correspondence you may have with us regarding your purchase.

Our websites and apps include links to external websites / platforms provided by third parties, such as social networks (e.g. Facebook and Twitter) and shopping platforms (e.g. Shopify). It will be clear from the link or its URL which third party is providing the external website / platform. They may collect personal information if you choose to interact with those links, including via cookies. Please see their privacy and cookie notices for more information.

2.5.2. How is this personal information collected?

Details of access to our websites and apps are automatically collected as you use them (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 certain cookies via your web browser settings and other tools. Please read our Cookie Notice for more details.

Your other details are collected when you choose to provide them. For example, by using our web form or by making a purchase.

2.5.3. What we may process your personal information for

We may use the information we collect about you to:

Provide our websites and applications to you, and where applicable customising them to your preferences.
Respond to your queries and provide you with the information about our products and services that you request from us (including via email or SMS where such contact details have been provided);
Provide you with the products and/or services that you purchase;
Improve the content of our websites and applications to ensure that content is presented in the most effective manner for you and for your computer;
Notify you of any important information relating to our websites, applications or your purchases; and
Administer our websites and applications and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

2.5.4.When we may disclose your personal information

our service providers (for example, the companies providing our websites and analytic services and delivering purchased products to you); and
our payment partners (who handle your credit/debit card details when making a purchase; we do not process this data and they will handle it in accordance with their privacy policy which should be made available to you at the time of payment).

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 (unless otherwise required by law).

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, and to satisfy our legal obligations (such as requirements to retain details of commercial transactions).

Website / application analytics information is not generally accessible to us in a personalised form and in is held in accordance with our analytics provider’s retention practices. See our Cookie Notice for more details.

2.6. If you (or your organisation) engage with our community or development projects

2.6.1. How do we collect personal information about you?

We often engage with the communities in which our or our partner or client’s properties are located to help improve surrounding areas or inform our property developments. When doing so, we may collect information:

when you or an organisation you belong to provides it to us when communicating with us or attending one of our, our client or our partner’s events;
from public sources, such as from an organisation’s website or publications, news and social media and other publicly available sources; and
from third party online engagement platforms which we or our clients and partners use to display information about our development (the platform tends to control this information and share some or all of it with us as development company in accordance with their privacy policy).

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
Organisations and roles
News, opinions, preferences and feedback

2.6.3.Why we use your personal data

We may use the information we collect about you to:

Provide you with important information about our developments (where you are a tenant or another stakeholder)
Invite you to events which we think will be of interest to you (where you requested this or provided consent)
Ensure that we provide a consistent and effective contact with you and others
Inform and aid our projects and developments

2.6.4. Who we may share your personal information with

our service providers (for example, those who provide or help us to manage our PR, community engagement or IT systems)

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

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.

2.7. If you work for one of our business partners (e.g. an investor, supplier or a real estate vendor / purchaser)

2.7.1. How do we collect personal information about you?

We will collect information that you will provide to us in the course of business with the organisation(s) or person(s) you represent. This may include information provided during our supplier set up process or due diligence.

We may collect information from background or risk screening companies and public sources when conducting due diligence on executives, shareholders, beneficiaries and other key persons relating to our business partners and suppliers as part of our due diligence / KYC processes.

We may also access contact information that is in the public domain, such as from an organisation’s website or publications or other resources in which companies choose to publish their business contact information.

2.7.2. What personal information we may process about you

Contact information, role and organisation
Financial details (if you are a key person in the organisation)
Events you may have attended
Your preferences, and areas of interest
References
Professional profiles (LinkedIn, corporate biographies etc.)
Directorships, shareholdings
Adverse media reports, sanctions, political exposure

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 (where you have requested this, we are permitted by law or you have provided consent);
inform you about our range of services; and
Build 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

our service providers (for example, those who provide or help us to manage our IT systems, business communications and risk screening companies)

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required or permitted by law).

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. However, we may continue to hold your personal information for longer periods in accordance with our IT backup procedures or for legal, accounting or financial reasons.

2.8. If you visit our offices and other buildings

2.8.1. How do we collect personal information about you

We will collect personal data in a number of ways including:

Directly from visitors in advance of their visit to our buildings
Directly from visitors on arrival at one of our buildings
From employees in advance of visitors’ arrival to our building
CCTV cameras

In addition we may have additional checks as a result of Covid prevention. Please follow the link for further details. Grosvenor - COVID-19 and 70 Grosvenor Street

2.8.2 .What personal information we may process about you

We may collect the following types of personal information:

Name of visitor.
Email if provided by staff member on our room booking system
Contact phone number for each visitor,
Date of visit, arrival time and departure time
Name of staff member who had arranged the meeting
CCTV of all people passing and entering our premises
Any additional information required for Covid-19 purposes.

2.8.3. What we may process your personal information for

We are collecting personal information to ensure we know who is in our building in the event of an evacuation, such as a fire or fire drill and to assist with NHS Test and Trace in order to prevent the spread of coronavirus (COVID-19).

We process CCTV footage to:

prevent unauthorised access to our buildings
improve health and safety
protect your interests (or the interests of others) in the event of criminality such a theft, physical or verbal abuse or criminal damage.

2.8.4. Who we may share your information with

our service providers (for example, those who provide or help us to manage our IT, events and CCTV)

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

If we are informed that Covid 19 has been detected in our buildings by staff or visitors your personal details may be shared with other organisations where it is necessary or permitted for the protection of public health, including the NHS Test and Trace Service.

2.8.5. Retention of your personal information

Your personal information will be processed for the duration of your visit and for a reasonable period thereafter. CCTV data is wiped after 30 days unless a request has been made by a data subject or other authorised party to review the data. In that case, the data is retained until the query has been completed.

2.9. If you agree to receive email marketing from us

2.9.1.How do we collect personal information about you

We collect personal information when you provide it and also automatically when you interact with our marketing communications.

2.9.2. What personal information we may process about you

If you choose to receive email marketing from us:

We will collect information on the sign up form, which is usually your name and email address but you may also be asked for other details.
We may also collect an unsubscribe request if you choose to opt-out of marketing from us.
We may also collect information automatically via our marketing platform (Mailchimp) about whether emails are successfully delivered, opened and clicked on. You can learn more about this tracking in Mailchimp’s Privacy Notice and Cookie Statement which are linked to at the bottom of Mailchimp’s website.

2.9.3. What we may process your personal information for

We process your personal information to provide and improve our email marketing communications and manage your preferences.

2.9.4. Who we may share your information with

our service providers and software hosting service providers who assist us to provide email marketing

They will be under an obligation to protect the confidentiality and security of that personal information (unless otherwise required by law).

2.9.5.Retention of your personal information

We will retain your personal information until you choose to unsubscribe and for a reasonable period thereafter (we may also continue to retain some details as long as necessary to manage your unsubscribe request).

2.10.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. Common Data Sharing

In addition to the specific data sharing explained above, we (and our third party service providers) may share your personal information with any of the following recipients:

for the purposes explained above, other Grosvenor organisations and their respective employees;
for financial, audit and professional services: our banks, investors, insurers, auditors and advisors; and
for a legal, regulatory or law enforcement matters:
- local and foreign regulators, governments and law enforcement authorities; and
- local and foreign courts, tribunals and arbitrators, other judicial committees and enactments of laws.

4. 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 the Contact section below.

5. 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. In the case of direct marketing, you can also use the unsubscribe link in the footer of the email to opt-out of receiving that communication.

6. 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 terms approved by the Information Commission’s Office (or where permitted, the European Commission) unless an exemption applies under applicable data protection laws.

7. 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.

8. 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/).

November 2021

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
Barton Park Estate Management Company Ltd
Barton Oxford LLP

All of these companies have their registered office at 70 Grosvenor Street London W1K 3JP