We use data for various purposes, including to market to you, manage our relationship with you, to protect our business and to ensure that we comply with any legal requirements. We would particularly like to highlight the following activities:

1. Your data may be used to send you online targeted advertisements. Based on the data collected by Google through the cookies and similar technologies used on our website, a profile of you may be developed to market to you more effectively when you browse online. Read more about the cookies used on our website in our Cookie Policy accessible here.

2. Your data may be used so that we can better understand our customer base. When you submit an enquiry form to us, we ask you to confirm your location. We will use this information to analyse where our customers tend to be based, so that we know where best to focus our marketing. You have rights in relation to the processing of your personal data, which are summarised at section 10 below.

This privacy policy describes how we look after your personal data collected directly when you engage with us including when you (i) visit our website; and (ii) contact us, including through making an enquiry through our website.

We collect different categories of information which we have grouped together as follows:

1. Identity Data: name, title, country of residence
2. Contact Data: email address and telephone number
3. Profile Data: Your interests when you submit an enquiry form on our website.
4. Technical and Usage Data: information about how you use our website (including your IP address and details about the devices you use to access our website). Please review the Cookie Policy on the website for further information on this.
5. Anonymised Data: we also collect, use and share data such as demographic or statistical data, which is not reasonably likely to reveal your identity (directly or indirectly). For example, we track numbers of enquiries from different jurisdictions. If we combine or connect anonymised Data with other data so that it can directly or indirectly identify you, the combined data is personal data, which will be used in accordance with this privacy policy.

We do not generally collect or process sensitive personal data.

Under data protection laws, we must have a lawful basis under which we process your personal data – as defined in section 5 below. If you provide us with your consent to processing, you can withdraw it at any time, and we will stop the processing activities that were based on consent as a lawful basis. We may still process the data if we have another lawful basis for processing (in most instances, this will be for more limited purposes e.g. back-up storage or to record a withdrawal). Where we need to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products/services). We will notify you of this at the time.

1. TYPES OF DATA:

a. Identity Data
b. Contact Data
c. Profile Data

PURPOSE/PROCESSING ACTIVITY OF COLLECTING YOUR DATA: to respond to your enquiries, and for other customer service purposes.
LAWFUL BASIS FOR COLLECTING YOUR DATA: our legitimate interests to respond to enquiries from those interested in our facilities.
RETENTION PERIOD FOR COLLECTING YOUR DATA: 15 months from our last engagement with you.

2. (a) Identity Data and
(b) Contact Data

PURPOSE/PROCESSING ACTIVITY: to market to you through our newsletter when you sign-up to it through our website.
LAWFUL BASIS: your consent (where required by law); or our legitimate interest in sharing promotions or special offers we think will interest you, subject to your right to opt-out at any time.
RETENTION PERIOD: until you withdraw consent or object to this processing activity (as described in section 10), as appropriate.

3. (a) Identity Data,
(b) Contact Data,
(c) Profile Data and
(d) Technical and Usage Data

PURPOSE/PROCESSING ACTIVITY: to manage, protect against and investigate fraud, risk exposure, claims and other liabilities.
LAWFUL BASIS: our legitimate interest in preventing and detecting fraud, and other threats to the integrity or security of our website.
RETENTION PERIOD: six years from the end of the calendar year that our engagement with you has ended.

4. (a) Identity Data,
(b) Contact Data,
(c) Profile Data and
(d) Technical and Usage Data

PURPOSE/PROCESSING ACTIVITY: to comply with applicable laws and regulations.
LAWFUL BASIS: to comply with applicable laws.
RETENTION PERIOD: in line with retention periods dictated by law.

5.(a) Identity Data,
(b) Contact Data,
(c) Profile Data and
(d) Technical and Usage Data

PURPOSE/PROCESSING ACTIVITY: to the extent we deem it necessary or appropriate, to enforce or apply our rights and/or protect the property rights or safety of Westminster Residences and others.
LAWFUL BASIS: our legitimate interest in establishing, exercising, or defending legal rights and claims.
RETENTION PERIOD: Six years from the end of the calendar year that our engagement with you has ended.

Marketing

We will only send you direct marketing by email or other electronic means where you have given your consent, or where you are an existing customer to whom we are marketing our own similar products or services, you were given a clear opportunity to opt out when we collected your details, and you have not since opted out (the “soft opt-in” permitted by the Privacy and Electronic Communications Regulations 2003). You can withdraw your consent or opt out at any time using the “unsubscribe” link in any marketing message or by emailing [email protected].

You may also receive indirect marketing from us by way of online advertisements or general marketing communications.

Profiling

We will monitor your engagement with us, combined with the other personal data we have collected about you, to inform our marketing activities. When you visit our website, you can use the cookie banner to accept or reject non-essential cookies, including advertising cookies. If you accept them, these cookies will record information about how you interact with our website and this information will then be used to serve you with relevant adverts on other sites based on the content that you have clicked on or interacted with. We may use information collected via cookies when you visit our website and aggregate this with information gathered via the relevant websites to understand your preferences/interests and ensure marketing/remarketing is relevant.

Please see our Cookie Policy for more detail on this and how to control your preferences. Please note that whilst we carry out the profiling activities described here, we do not carry out any automated decision-making processes which could have a legal or significant impact on you.

We may have to share your personal data with the parties set out below:

• Internal third parties – we are part of the Hinduja Group. We may share your personal data with other companies in the Hinduja Group (see section 8 for information on the protections we put in place where these companies are based outside of the UK/EEA), including Whitehall Hotel Limited and Westminster Development Services Limited;
• External third parties – we share your personal data with external third parties which include:
  
  1. IT and system administration service providers (including data storage providers, data management platform providers and the agency we use to run our website);
  2. regulators, local authorities and government bodies, including the Police and HMRC, to comply with any legal or regulatory requirements or formal/informal investigations;
  3. courts, parties to litigation and professional advisers where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims;
  4. Commercial partners: We, unless you specify otherwise to us, we will be sharing certain personal information with our preferred commercial partners. In this case, a trusted third party may cross-check, analyse and combine your data. This data processing will allow us and its privileged contractual partners to determine your interests and customer profile to allow us to send you personalized offers.
  5. All data gathered through the website and marketing campaigns is shared with Luxx Property. Luxx Property is a representative of The OWO and the data will only be used for the purposes to follow up on your enquiry and internal marketing analysis. The data will not be shared with any 3rd parties and will only be used for exclusive marketing purposes for The OWO.

Some of the recipients listed in section 7 above may be based outside the EEA/UK. Whenever we transfer your personal data outside the United Kingdom, we make sure at least one of the following safeguards applies: (a) the country or organisation is covered by UK adequacy regulations; (b) for transfers to the United States, the recipient is certified under the UK Extension to the EU–US Data Privacy Framework; or (c) we use a transfer agreement approved for use in the UK — the International Data Transfer Agreement (IDTA), or the EU Standard Contractual Clauses together with the UK Addendum — supported by a transfer risk assessment where required. If you would like a copy of the specific safeguard we rely on, please contact us at [email protected].

Your personal data is securely stored. We will keep your personal data for the retention periods outlined in section 5 and will then dispose of your information through regular back up/over-writing of data through our cloud-based systems, in addition a system will be in place to automatically delete data once the retention periods in section 5 have been met, if not requested to do so earlier by the owner of the personal data.

Under data protection laws, you have various rights which are set out below. The rights available to you depend on our reason for processing your personal data. You are not required to pay any charge for exercising your rights, although we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We have one month to respond to you (unless you have made a number of requests or your request is complex, in which case we may take up to an extra two months to respond).

Please note that, where we ask you for proof of identification, the one-month time limit does not begin until we have received this. If we require any clarification and/or further information on the scope of the request, the one-month deadline is paused until we receive that information.

1. Right of access: you can ask us for copies of your personal data. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this here.
2. Right to rectification: you can ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this here.
3. Right to erasure: you can ask us to erase your personal data in certain circumstances. You can read more about this here.
4. Right to restrict processing: you can ask us to restrict the processing of your information in certain circumstances.
5. Right to object to processing. You can object to processing of your personal data where we are relying on a legitimate interest or conducting direct marketing. You can read more about this here.
6. Right to withdraw consent. Where we are relying on consent to process your personal data, you can withdraw it at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
7. Right to data portability. This only applies to information you have given us. You can ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent. You can read more about this here. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You have the right to ask us to explain decisions we make through automated decision-making or profiling, if the decision has a material impact on your rights and interests, as well as the right to refuse the making of decisions by us solely by means of automated decision-making.

Their address is:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113

ICO website: Https://www.ico.org.uk

We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details at the start of this privacy policy.