This notice applies to you if we process your personal information and you are not an employee or worker of ours, a prospective candidate employee or worker or supplier an individual to whom we have provided a specific privacy notice. You may be, for example, be an individual that works at a supplier or customer or another organisation that we deal with, an attendee at one of our marketing events, a user of our website, someone who contacts us or someone who is affected by our activities.
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice also explains how we comply with the law on data protection and what your rights are.
We have appointed a Data Protection Officer to oversee our compliance with data protection laws for the following parts of the Calthorpe Estates group, namely Edgbaston Estates Security Limited , and they have overall responsibility for data protection compliance in this organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws for other parts of the Calthorpe Estates group as we are not required to do so, but our Head of Legal has overall responsibility for data protection compliance in the rest of our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
For the purposes of data protection, the part of the Calthorpe Estates group (being all those companies and entities listed in Appendix A attached) which is processing your personal information will be the controller of your personal information. References to we, our or us in this privacy notice are to the relevant part of the Calthorpe Estates group.
1. Personal information we collect
We may collect the following types of personal information about you:
- Contact details: information that allows us to identify and contact you directly such as your name, address email address, telephone numbers and addresses.
- Identification information: passport and other official identification details, home address, information from a third party money laundering check provider (which may include politically exposed persons checks on family, friends and contacts of yours and adverse media checks), Companies House information.
- Details of your work history: this includes may include positions, roles and responsibilities.
- Personal history and information: this includes hobbies, interests, marital status, family details and dietary requirements and health matters.
- Advisors appointed by you: including mortgage brokers, lawyers, financial advisors, surveyors and property advisors;
- Business information: including property owned by you, transactions, amounts paid or owed
- Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
- Creditworthiness: We may undertake investigations into your creditworthiness, via Red Flag or other system, in order to establish whether to enter into or continue a business relationship with you.
- Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
- How you use our website: we collect information about the pages you look at and how you use them (via cookies), usernames and passwords.
- Videos, audio and photograph: which you or other people take and provide to us or we take ourselves or by third party photographers or videographers appointed by ourselves.
- Details of the correspondence (including e-mail correspondence) you send and receive from us: this includes faxes, letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
- Communications: including enquiries, complaints and other issues raised by you or us.
- Subscription information: for example when you subscribe to one of our blogs or other materials such as newsletters.
- IP address information: your computer’s IP address allows us to track your usage of our website.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION AND CRIMINAL RECORDS INFORMATION
We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:
- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
- information about your trade union memberships;
- information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
- biometric information about you, for example fingerprints, retina scans.
We will generally not collect, store and use any special category personal information in relation to you except to the extent we need to do so to comply with a legal obligation or you have given your consent or it relates to a dispute.
Also we do not generally collect, store and use any criminal records history relating to you except to the extent we are legally required to do so or you have given your consent.
3. Sources we collect your personal information from
We will collect personal information from a number of sources. These may include the following:
- Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us in some other way or provide information to us directly in some other way.
- Your landlord: such as a housing association or commercial landlord.
- Third parties authorised by you; a family member, managing agents, letting agents or someone else authorised by you.
- From referrals and recommendations: usually given by other people who know you or have a working relationship with you.
- Our website: provides us with information about how you use it and the devices that you use to connect to our website.
- Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn Facebook and other web or social media platforms.
- Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.
- Your employer or the organisation you work for: they may provide us with your name, position, contact details , background and other information about you.
- Our professional advisors: such as lawyers, accountants, planning consultants and surveyors and other consultants and advisors.
- The Government, local authorities, planning authorities or relevant regulators: to assist with investigations, for example the Information Commissioner’s Office or planning applications to the local planning authority.
We will also collect additional personal information throughout the period of your or the organisation you work for dealings and activities with us.
4. uses made of your personal information
The table below describes the main purposes for which we process your personal information, the main categories of your personal information involved and our main lawful basis for being able to do this. Not all of these may apply to you depending upon the nature of your dealings with us. Other lawful basis for processing your personal information may also apply in particular circumstances.
| Purpose | Personal information used | Lawful basis |
| Identity and money laundering checks, anti-facilitation of tax checks and passing details of our money laundering checks to third parties and to carry out credit checks | Name, personal contact details and other identifiers, and identification documents, money laundering check information, financial information |
We may have a legal obligation to undertake identification and money laundering checks and to provide those details to third parties We, or our agents, also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid |
| Enter into, manage and perform contracts, where we may be supplying products/services to you or your organisation and/or you or your organisation may be supplying products/services to us or we may be involved in similar arrangements with third parties | All the personal information we collect |
To enter into and perform contracts with either yourself or the organisation that you represent We have a legitimate interest to properly perform contracts with third parties |
| Deal with your queries or complaints or parking fines or raise queries or complaints with you or the organisation you represent | All the personal information we collect |
This may be necessary to perform a contract with you or the organisation that you represent We have a legitimate interest to improve the services and/or products we provide and to ensure we operate efficiently and to be able to deal with your communications. |
| Maintain and improve our services and/or products | All the personal information we collect | We have a legitimate interest to improve the services and/or products we provide |
| Data analytics and statistical analysis to help us improve our online services | How you use our website or email campaign | We have a legitimate interest to improve the online services we provide and user experience |
| Determine services and/or products that may be of interest to you | All personal information we collect | We have a legitimate interest to improve the services and/or products we provide and to determine which products and/or services you may be interested in |
| Direct marketing and to provide you with any requested information | Contact details and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has enquired about and/or purchased in the past |
We may ask for your consent to process your data for this purpose, you may revoke your consent at any point Alternatively if you or your organisation has enquired about or purchased similar services or products from us previously we may market similar products or services as a legitimate interest in developing our business. You have the right to opt out from such marketing at any time We have a legitimate interest in marketing and expanding our business To comply with any request made by you or the organisation that you represent |
| Holding events | Your contact details, details of attendance, your comments in response forms and dietary requirements |
We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements |
| To comply with our legal and regulatory obligations | All the personal information we collect plus any special category personal information or criminal records information we may obtain about you |
To comply with any legal and regulatory obligation or requirement Where we process special category personal information or criminal records information we will do so to comply with our legal obligations or where you have provided your consent |
| Providing to you portal and/or website access and for the purposes of ensuring the security of our systems and our information including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution | All the personal information we collect about you |
We have a legitimate business in ensuring our premises and systems are secure To be able to manage and perform any contract with you regarding and we have a legitimate interest to do this with your organisation |
| Fraud, crime prevention and debt collection | All the personal information we collect | We have a legitimate interest to detect and prevent crime and to collect debts |
| To manage our relationship with you and/or the organisation you represent and to manage and operate our business and internal reporting | All the personal information we collect |
We have a legitimate interest to operate our business in an efficient way and to manage our business properly To enter into and perform contracts with either yourself or the organisation that you represent |
| Dealing with and managing enquiries, defect rectification, complaints and other communications from you or your organisation or a third party and dealing with legal disputes and warranty claims involving you or your organisation or a third party | All the personal information we collect about you plus in some circumstances any special category personal information we may obtain about you |
We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications We have a legitimate interest to ensure that all legal claims are managed effectively To be able to manage and perform our contract with you regarding your property rental/purchase and fixtures and fittings options and we have a legitimate interest to do this with your organisation We may process special category personal information to assess, defend or bring legal claims |
| Creating and storing records relating to you or the organisation you represent and also records relating to our business | All the personal information we collect | To be able to perform any contract with you or the organisation you represent, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records |
| To ensure prevention of unauthorised access to our property | CCTV footage and other information obtained through electronic and manual means such as signing in records; | We have a legitimate interest in ensuring our buildings and systems are secure |
For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with our legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide or carry out certain activities.
We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.
5. Who we share your personal information with
We may share personal information with the following parties:
- Companies in the same group of companies as us: in relation to joint events for the purpose of providing a service to you or your organisation or you or your organisation providing products or services to us.
- Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain.
- Credit reference and other identification agencies: so that we can assess your or your organisation’s creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
- Third parties who ask for or want referrals: we may provide your details to a third party seeking services/products which are the same or similar to those that you provide.
- Marketing and public relations companies: to help us to develop, carry out and assess marketing, PR and digital campaigns
- Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
- Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
- Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business in part or whole.
- The Government, local authorities, planning authorities or relevant regulators: where we are required to do so by law or to assist with their investigations, for example the Information Commissioner’s Office.
- Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.
We also use analytics which sets cookies to collect information about how visitors use our website and other digital platforms such as email. We use the information to compile reports and to help us improve the website. The website cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout or to opt out of emailings and digital marketing click the unsubscribe button on the emailer.
We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.
We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally entitled to do so. We do not sell, rent or trade your data.
6. Direct Marketing
Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products or services or events we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously.
You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at [email protected] or by using the details set out in the “Contacting us” section below. You can also unsubscribe from our electronic marketing by clicking on the unsubscribe link in any written electronic marketing messages we send to you.
7. Transferring your personal information internationally
The personal information we collect is not transferred to and stored in countries outside of the UK and the European Economic Area.
Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Economic Area if they are on holiday abroad outside of the UK or European Economic Area. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.
In limited circumstances the people to whom we may disclose personal information as mentioned in the section “Who we share your personal information with” above may be located outside of the UK and European Economic Area. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.
If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.
8. How long do we keep personal information for
We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:
- For individual contacts at customers and suppliers generally this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 6 years afterwards.
- For marketing contacts it will generally be a period of 6 years after we were last in contact with you.
- For website users it will generally be a period of 6 years after you used our website.
- For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years.
- For individuals attending an event it will generally be a period of 6 years after the event.
It is important to ensure that the personal information we hold about you or the organisation you represent is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address, you can contact us by using the details set out in the “Contacting us” section below.
9. Security
We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.
10. Your rights in relation to your personal information
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information;
- the right to withdraw any consent given by you in relation to processing your personal information;
- the right to request that we transfer elements of your data either to you or another service provider; and
- the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.
For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.
We are here to help and encourage you to contact us in the first place to resolve your complaint. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator.
11. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
12. CONTACTING US
In the event of any query or complaint in connection with the information that Edgbaston Estates Security Limited may hold about you, please email the Data Protection Officer at [email protected] or write to the Data Protection Officer at Calthorpe Estates, 76 Hagley Road, Edgbaston, Birmingham B16 8LU
In the event of any query or complaint in connection with the information about any other part of the Calthorpe Estates holds about you, please email [email protected] or write to us at Head of Legal at Calthorpe Estates, 76 Hagley Road, Edgbaston, Birmingham B16 8LU.
APPENDIX A
Calthorpe Estates Group Companies & Entities
The Niall Anstruther-Gough-Calthorpe 1959 Discretionary Settlement
The Sir Euan Anstruther-Gough-Calthorpe Bt. 1994 Continuation Fund
Balrach Limited
Calthorpe Developments Limited
Calthorpe Edgbaston Mill Limited
Calthorpe Estates Limited
Calthorpe Estates CF Nominee No 1 Limited
Calthorpe Estates CF Nominee No 2 Limited
Calthorpe Estates DS Nominee No 1 Limited
Calthorpe Estates DS Nominee No 2 Limited
Calthorpe Group Management Limited
Calthorpe Properties Limited
Calthorpe Property Company Limited
Edgbaston Estates Security Limited
Pebble Mill Investments Limited