Privacy and Cookies
Palace Capital plc is committed to protecting your privacy and related rights in line with current data protection legislation.
This Privacy Notice explains how personal information about you is used by us, how we protect it, and your rights in relation to this information.
Palace Capital plc (‘we’ or ‘us’) is the ‘Data Controller’ of the personal data that you (‘you’ means the person whose data is being processed) provide to us. Our company registration number is 05332938 and our registered address is 25 Bury Street, St James’s, London, SW1Y 6AL.
What personal information we use
We will process personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us) and information we collect about you from other sources, for example, property agents, referral agents, list brokers and credit reference agencies.
The kind of information we may process about you will vary depending on your relationship with us. Initially we may collect your name, contact number and email address, and information about the nature of your enquiry. If you are a tenant of ours, a visitor, supplier, shareholder or member of the public we may collect and process the following:
- Personal details: such as your name, address, phone number, email address, and other information that you may provide in any correspondence between us and in respect of our shareholders provided to our registrars, to enable them to manage our register of shareholders and support other regulatory functions on our behalf;
- Information in relation to a tenancy: such as financial and business information, contact details and bank account details and information relevant to health and safety matters at the building. This enables us to assess your suitability to be a tenant, allow you to pay the sums due under your lease and manage our buildings;
- CCTV and systems which control access to our buildings: which will include images, name, occupation, employer and contact details for the purposes of public safety, crime prevention and prosecution, insurance, property management and marketing and advertising;
- General correspondence, through letters, email or phone calls and messages to manage our relationship with you; and
We do not process any special categories of personal information (for example, data relating to health, race, ethnicity, politics, trade union membership, sex life, sexual orientation, genetics, biometrics).
Our website may contain links to other third-party websites. If you follow a link to any of those third-party websites, they will have their own privacy policies. Please check these policies before you submit any personal data.
A ‘cookie’ is a small text file that websites place on your computer or smartphone. When you visit www.palacecapitalplc.com (the “Site”), the browser on your computer or smartphone automatically downloads the webpage you were seeking and may also download our cookies (depending on how your browser is configured).
Cookies remember your computer or smartphone browser when you next visit, what pages you’ve viewed and any account preferences. We analyse this information to help us understand how people use the Site and how we can improve it. This is undertaken via Google Analytics a web analytics service provided by Google, Inc. (‘Google’). Google will use this information to evaluate website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
You have the right to choose whether or not to accept cookies used for certain purposes, by using your browser settings. However, cookies are an important part of how our Site operates, and if you choose to refuse or remove cookies, this could affect the availability and functionality of the Site.
How we use your personal information and our legal basis
We will only process your personal information where we have a lawful basis to do so. In most cases we will process your personal data because it is necessary for the performance of a contract with you (or to take steps to entering into a contract with you) i.e. entering into a tenancy agreement or renewing your lease.
We may also process your personal data where it is necessary to comply with our legal obligations or for the purposes of our legitimate interests.
We have expanded upon these legal bases below:
- to perform our obligations under our contract with you – such as lease renewals, billing and property management;
- legitimate interests – such as to communicate with you; address your enquiries or requests; improve our services; manage your shareholding in the Company and exercise your rights as a shareholder; for web analytics so we can provide, improve and tailor services directly to you; to provide appropriate technical support and security for our websites; or for fraud protection;
- to comply with a legal obligation – such as health & safety purposes or for taxation purposes;
- when it is in someone’s vital interests – such as preventing someone being seriously harmed;
- with your consent – such as agreeing to receive email alerts.
We will only keep your personal data as long as it is necessary to support our relationship with you, to meet our legal obligations and support the purposes set out above. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
People who may process your personal information in support of our business
Your personal information will be received and processed by our own employees, agents and other members of our Group. We may also disclose your personal information to other third parties, such as:
- third party service providers who act for us – for example, our property and managing agents, our registrar who manages our share register, the processors that manages our websites; send out email alerts; or manage our IT network;
- prospective vendors or purchasers of our properties, or the companies with which we own a property;
- our legal advisors, insurers and auditors; and
- law enforcement agencies and other regulators or third parties where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
When we share your personal information with other parties, we will ensure contracts are in place that impose strict data sharing requirements.
In the event that we make changes to our Group structure, for example a re-organisation, sale or merger we may transfer your personal data to certain parties involved in that process.
Transfers outside the European Economic Area
In limited circumstances, your personal data may be accessed, transferred, and/or stored, outside the European Economic Area (EEA). Third parties will only process your personal information on our instructions and subject to an agreement that any personal information transferred will receive an adequate level of protection as required by UK data protection law.
We will ensure that appropriate safeguards are in place prior to any transfer of your data.
Keeping your personal information secure
We have a range of technical and organisational measures to help ensure your personal information is used responsibly and to help keep it safe and secure. We also take steps to ensure any third party that provides services to us also take steps to protect any personal information they process on our behalf.
Your rights and access to your personal information
You have certain rights regarding your personal information, these include the right to:
- access your personal information
- rectify the information we hold about you
- erase your personal information (in certain circumstances)
- restrict our use of your personal information (in certain circumstances)
- object to our use of your personal information (in certain circumstances)
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
- lodge a complaint with the UK data protection authority – the Information Commissioner’s Office (the “ICO”).
If we rely on your consent to process your personal information – such as for marketing communications – you have the right to withdraw your consent at any time.
If you have any questions about your rights or would like to exercise any of them, please email firstname.lastname@example.org.
We may modify or update this Privacy Notice from time to time.
Effective: October 2019