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PRIVACY POLICY

  • 1. PRIVACY POLICY

    1.1

    This Privacy Policy (the “Policy”) sets out how we, Howard de Walden Estates Limited, headquartered at 23 Queen Anne Street, London, W1G 9DL under company number 00781024 and ICO registration number ZA166463, (further referred to as “HdWE” “our” or “we”) process the personal data of our website visitors and customers (each a “User”).

    1.2

    If you have any questions about this Policy, please contact our data protection officer (“DPO”) Peter Griffith at peter.griffith@hdwe.co.uk.

    2. WHAT IS PERSONAL DATA?

    2.1

    Personal data means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, IP address, location data, banking details (if applicable) and other personal data (further referred to as “Personal Data”)

    3. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

    3.1

    HdWE will only process your Personal Data, in accordance with applicable law, for the following purposes:

    3.1.1

    offering our goods and providing our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker;

    3.1.2

    answering your queries relating to any of our services, publications or properties;

    3.1.3

    administering promotions that you may have participated in;

    3.1.4

    enabling our suppliers and service providers to carry out certain functions on our behalf, including verification, technical, logistical or other functions;

    3.1.5

    sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;

    3.1.6

    serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of "cookies" placed on your devices. Please see our Cookie Statement below;

    3.1.7

    ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;

    3.1.8

    developing and improving our products and services,for example, by reviewing visits to our website and its various subpages, demand for specific goods and services and User comments; and

    3.1.9

    to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

    3.2

    The legal basis for us processing your Personal Data for the purposes described above will typically be because you have provided us with your consent. However, we may also rely on other legal grounds, for example, where the processing is necessary:

    3.2.1

    to fulfil a contract that we have in place with you;

    3.2.2

    for HdWE’s legitimate business interests; or

    3.2.3

    for compliance with a legal obligation to which HdWE is subject.

    4. COOKIE STATEMENT

    What exactly are cookies?

    4.1

    In order to collect the information as described in this Privacy Policy, we may use cookies and similar technology on our website.

    4.2

    A cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive, mobile phone or other device

    4.3

    You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through websites may not function properly if your cookies are disabled.

    4.4

    Cookies can be first party or third party cookies.

    First party cookies - cookies that the website you are visiting places on your computer.

    Third party cookies - cookies placed on your computer through the website but by third parties, such as, Google.

    The cookies placed on our site

    4.5

    We use the following cookies on our website:

    Strictly necessary cookies
    hese cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.

    Performance cookies
    These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it and the approximate regions that they are visiting from. These are first party cookies.

    Functionality cookies
    These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.

    Targeting or advertising cookies
    These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our Site and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

    Social Media cookies
    These cookies allow you to connect with social media networks such as LinkedIn and youtube. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

    4.6

    We may combine information from these types of cookies and technologies with information about you from any other source.

    Cookie consent and opting out

    4.7

    We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another User of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites, platforms and services.

    4.8

    When you arrive on our Site a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another User of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.

    5. DISCLOSURE OF CUSTOMER INFORMATION

    5.1

    There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:

    5.1.1

    to our subsidiaries, branches or associated offices;

    5.1.2

    to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, webhosting provider through which your Personal Data may be collected, identity verification partners in order to verify your identity against public databases;

    5.1.3

    to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;

    5.1.4

    subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by clicking here;

    5.1.5

    to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;

    5.1.6

    to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;

    5.1.7

    to public authorities where we are required by law to do so; and

    5.1.8

    to any other third party where you have provided your consent.

    6. INTERNATIONAL TRANSFER OF PERSONAL DATA

    6.1

    We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 3 above. In particular, your Personal Data may be transferred to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact the DPO for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.

    7. RETENTION OF PERSONAL DATA

    Your Personal Data will be retained until as long is reasonably necessary for the purposes listed above or as required by applicable local law. Please contact the DPO for further details of applicable retention periods.

    8. DATA SUBJECT RIGHTS

    8.1

    Data protection law provides individuals in certain countries with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data.

    8.2

    If you have a complaint about how we have processed your Personal Data, please contact us in the first instance and we will do our best to resolve any issues you may have. However, you do have the right to contact the Information Commissioner’s Office directly. Please visit the ICO website for instructions.

    9. CHILDREN

    Please note that this website is not intended for minors under the age of 16.

    10. LINKED WEBSITES

    Please note that any websites that may be linked to our websites are subject to their own privacy policy.

    11. GOVERNING LAW

    This privacy policy is governed by the laws of England and Wales.

1. PRIVACY POLICY

1.1

This Privacy Policy (the “Policy”) sets out how we, Howard de Walden Estates Limited, headquartered at 23 Queen Anne Street, London, W1G 9DL under company number 00781024 and ICO registration number ZA166463, (further referred to as “HdWE” “our” or “we”) process the personal data of our website visitors and customers (each a “User”).

1.2

If you have any questions about this Policy, please contact our data protection officer (“DPO”) Peter Griffith at peter.griffith@hdwe.co.uk.

2. WHAT IS PERSONAL DATA?

2.1

Personal data means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, IP address, location data, banking details (if applicable) and other personal data (further referred to as “Personal Data”)

3. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

3.1

HdWE will only process your Personal Data, in accordance with applicable law, for the following purposes:

3.1.1

offering our goods and providing our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker;

3.1.2

answering your queries relating to any of our services, publications or properties;

3.1.3

administering promotions that you may have participated in;

3.1.4

enabling our suppliers and service providers to carry out certain functions on our behalf, including verification, technical, logistical or other functions;

3.1.5

sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;

3.1.6

serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of "cookies" placed on your devices. Please see our Cookie Statement below;

3.1.7

ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;

3.1.8

developing and improving our products and services,for example, by reviewing visits to our website and its various subpages, demand for specific goods and services and User comments; and

3.1.9

to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

3.2

The legal basis for us processing your Personal Data for the purposes described above will typically be because you have provided us with your consent. However, we may also rely on other legal grounds, for example, where the processing is necessary:

3.2.1

to fulfil a contract that we have in place with you;

3.2.2

for HdWE’s legitimate business interests; or

3.2.3

for compliance with a legal obligation to which HdWE is subject.

4. COOKIE STATEMENT

What exactly are cookies?

4.1

In order to collect the information as described in this Privacy Policy, we may use cookies and similar technology on our website.

4.2

A cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive, mobile phone or other device

4.3

You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through websites may not function properly if your cookies are disabled.

4.4

Cookies can be first party or third party cookies.

First party cookies - cookies that the website you are visiting places on your computer.

Third party cookies - cookies placed on your computer through the website but by third parties, such as, Google.

The cookies placed on our site

4.5

We use the following cookies on our website:

Strictly necessary cookies
hese cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.

Performance cookies
These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it and the approximate regions that they are visiting from. These are first party cookies.

Functionality cookies
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.

Targeting or advertising cookies
These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our Site and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

Social Media cookies
These cookies allow you to connect with social media networks such as LinkedIn and youtube. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

4.6

We may combine information from these types of cookies and technologies with information about you from any other source.

Cookie consent and opting out

4.7

We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another User of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites, platforms and services.

4.8

When you arrive on our Site a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another User of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.

5. DISCLOSURE OF CUSTOMER INFORMATION

5.1

There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:

5.1.1

to our subsidiaries, branches or associated offices;

5.1.2

to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, webhosting provider through which your Personal Data may be collected, identity verification partners in order to verify your identity against public databases;

5.1.3

to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;

5.1.4

subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by clicking here;

5.1.5

to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;

5.1.6

to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;

5.1.7

to public authorities where we are required by law to do so; and

5.1.8

to any other third party where you have provided your consent.

6. INTERNATIONAL TRANSFER OF PERSONAL DATA

6.1

We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 3 above. In particular, your Personal Data may be transferred to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact the DPO for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.

7. RETENTION OF PERSONAL DATA

Your Personal Data will be retained until as long is reasonably necessary for the purposes listed above or as required by applicable local law. Please contact the DPO for further details of applicable retention periods.

8. DATA SUBJECT RIGHTS

8.1

Data protection law provides individuals in certain countries with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data.

8.2

If you have a complaint about how we have processed your Personal Data, please contact us in the first instance and we will do our best to resolve any issues you may have. However, you do have the right to contact the Information Commissioner’s Office directly. Please visit the ICO website for instructions.

9. CHILDREN

Please note that this website is not intended for minors under the age of 16.

10. LINKED WEBSITES

Please note that any websites that may be linked to our websites are subject to their own privacy policy.

11. GOVERNING LAW

This privacy policy is governed by the laws of England and Wales.