Privacy Policy

Greenland (United Kingdom) Investment Limited Privacy Policy

Introduction

This Privacy Policy informs you of who we are, how information is collected about you, how we store that information, what that information is utilised for, with whom your information is shared, and whether it may be transferred outside the European Economic Area (‘EEA’).

We are committed to protecting your personal data.

For the purposes of this privacy policy and all personal data, you are the Data Subject, and Greenland (United Kingdom) Investment Limited are the Data Controller.

Who are we

Greenland (United Kingdom) Investment Limited is the parent company of a number of companies, such as Greenland RAM (London) Limited and Greenland Hertsmere (London) Limited.

The full list can be found below, along with their associated websites.

Greenland (United Kingdom) Investment Limited is the data controller for all the organisations within the group. This means that Greenland (United Kingdom) Investment Limited determines what data is collected by each company within the group, how this data is going to be used and how this data is protected.

Associated companies

• Company: Greenland (United Kingdom) Investment Limited
• Trading Name: Greenland Group
• ICO Registration: ZA273740
• Company: Greenland RAM (London) Limited
• Website: https://www.theramquarter.com
• Trading Name: The Ram Quarter
• ICO Registration: ZA274247
• Company: Greenland Hertsmere (London) Limited
• Website: https://spirelondon.com
• Trading Name: Spire London
• ICO Registration: ZA274249

It includes personal data that is collected through our websites, by telephone and through any related social media applications.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below in the Contact Us section.

How we collect your personal data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.

Automated technologies or interactions. As you interact with our Websites, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• (a) analytics providers [such as Google based outside the EU];
• (b) advertising networks [such as [NAME] based [inside OR outside] the EU]; and
• (c) search information providers [such as [NAME] based [inside OR outside] the EU].

We collect personal data from you for one or more of the following purposes:

To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;

To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;

To fulfil a contract that we have entered into with you or with the entity that you represent;

To ensure the security and safe operation of our websites and underlying business infrastructure, and

To manage any communication between you and us.

Use of cookies

We use Cookies on our websites. Please find our cookie policy here

• Purpose: To Provide you with information
• Information category: Subject matter information
• Data collected: Name, Company name, Telephone Number, Geographic location, email address
• Purpose: To provide information on the services you have requested
• Lawful base of processing: Consent
• Data shared with: Internally
• Retention period: 7 Years from the date the information is collected,6 months if marketing
• email is left unopened.
• Purpose: Purchase of a Property (LEASEHOLD)
• Information category: Subject matter information
• Data collected: Name, Address, Email, Telephone Number, Financial Information
• Purpose: To fulfil a contractual requirement
• Lawful base of processing: Contractual Obligation
• Data shared with: Internally
• Retention period: 999 Years
• Purpose: Purchase of a Property (FREEHOLD)
• Information category: Subject matter information
• Data collected: Name, Address, Email, Telephone Number, Financial Information
• Purpose: To fulfil a contractual requirement
• Lawful base of processing: Contractual Obligation
• Data shared with: Internally
• Retention period: 12 Years
• Purpose: Rental of Property
• Information category: Subject matter information
• Data collected: Name, Address, Email, Telephone Number, Financial Information
• Purpose: To fulfil a contractual requirement
• Lawful base of processing: Contractual Obligation
• Data shared with: Internally
• Retention period: 7 years after the last contract ends.
• Purpose: Marketing
• Information category: Subject Matter Information
• Data collected: Names, Telephone Numbers, Geographical Locations, Email Addresses
• Purpose: General Mailing Information
• Lawful base of processing: Consent / Legitimate Interest
• Retention period: 6 months if unread.
• Purpose: Communication
• Information category: Contact Information
• Information category: Subject Matter Information
• Data collected: Names, contact details, identification details
• Purpose: To communicate any issue that may arise or which follows interaction with us
• Lawful base of processing: Legitimate Interest
• Retention period: Internally / Professional Advisors

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.

International transfers

Some of our third party providers are businesses outside of the European Economic Area (EEA) in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place, which give your personal data the same protection it has within the EEA and this privacy policy. If we are not able to do so, we will request your explicit consent to the transfer, and you can withdraw this consent at any time.

In particular, any transfer of your personal data made by us to a location outside of the EEA will be governed by the relevant set of model contract clauses approved by the European Commission, which we will make available to you on request.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share your password with anyone.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the EEA.

Data sharing

We may have to share your personal data within our group companies. We may also have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including lawyers, bankers, auditors and insurers, (iii) HMRC and other regulatory authorities.

We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.

Data security

We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out above.

Your rights as a data subject

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are set out in more detail below. You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

The right to be informed

We are obliged to provide clear and transparent information about our data processing activities. This information is provided within this privacy policy.

The right of access

You may request a copy of the personal data we hold about you. Once we have verified your identity, and if relevant, any authority or third party requester, we will provide access to the personal data we hold about you.

The right to complete and accurate data

When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data including by providing a supplementary statement to us. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

The right to be forgotten (erasure)

If there is no legal basis or legitimate reason continues to exist for processing your personal data, you may request that we delete your personal data. If we are not able to comply with your request to delete your personal data, we will normally tell you the reasons at the time of your request.

The right to object

You have the right to object to our processing of your data.

Based on our legitimate interests. If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and

For direct marketing purposes. If you ask us to stop processing your personal data on this basis, we will stop.

The right to restrict processing

You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

• The accuracy of the personal data is contested;
• Processing of personal data is unlawful;
• We no longer need the personal data for processing, but the personal data is required for part of a legal process;
• The right to object has been exercised, and processing is restricted pending a decision on the status of the processing.

The right to request transfer of your data

You may request that we transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

The right to withdraw your consent

Where we rely on your consent to process your personal data, you may withdraw this at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Changes to this privacy policy

Any changes we make to our privacy policy in the future will be posted on this page, where appropriate, notified to you by email. Please check back frequently for any updates or changes to our privacy policy.

Contact us

Any comments or suggestions about this privacy policy should be emailed to: Privacy@ldjt.co.uk

Alternatively, you can contact us on the below details:

Address:

Greenland (UK) Investment Limited

Old Brewer’s House

76 Wandsworth High Street

London SW18 4LB

Telephone: 020 3713 0170

Complaints

Should you wish to discuss a complaint, please feel free to contact us using the ‘contact us’ information above. All complaints will be treated with the utmost confidentiality.