1. PURPOSE OF THIS NOTICE
This privacy notice describes how we collect and process personal information about you, in accordance with the General Data Protection Regulation 2016 (the “GDPR”), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (the “Data Protection Legislation”).
2. ABOUT US
TS West End Plaza S.à.r.l. (“TS West End Plaza”, “we”, “us”, “our”, and “ours” ) is registered in Luxembourg under company number B199168 and our registered office is at 34-38, Avenue de la Liberté, L - 1930 Luxembourg.
As the data controller under the Data Protection Legislation, we control how we obtain, use and disseminate your personal information. This information is set out in the privacy notice.
3. PERSONAL INFORMATION
We may collect personal information from you from various sources, including through your use of our website and information that we collect from you directly (for example, when you contact us).
By law, we may be required to collect personal information about you, for example, in relation to a contractual relationship we may have with you. In some circumstances, failure to provide such information may delay or prevent us from fulfilling our obligations. At the time your information is collected, we shall inform you whether collection of certain types of data is compulsory or not. Further, where applicable, we shall outline the likely consequences of failing to provide such information.
4. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
The information that we may process includes:
Information that you provide to us when you contact us by email, telephone, post and social media including:
- Basic information such as your name, physical address, email address and phone number;
- Information setting out communications and correspondence with you; and
- Information detailing any enquiries or complaints that you have submitted to us.
- If we send you any emails, we may or may not review if you have opened these and further, if you have clicked through on any embedded or attached links.
- If you fill out any forms, for example, a “Contact us” form, we will collect personal information such as your name, email address and contact number. Mandatory fields will be clearly marked for your reference.
- If you visit our website, the web server may collect basic information including your browser type and IP address. Our website may use certain tools to monitor and report on website usage to help us improve it. To achieve this, these tools may place small text files on your device known as “cookies” which collect analytical information such as the number of visitors and length of time spent on the website. This information may be aggregated as such, including in such a way as to be anonymous.
5. BASES FOR USING YOUR PERSONAL INFORMATION
We process your personal information on any of the following legal bases:
- To fulfil our contractual obligations towards you, for example to provide you with information that you have requested;
- To comply with our legal obligations towards you; and
- To meet our legitimate business interests.
6. WHAT WE USE YOUR PERSONAL INFORMATION FOR
We may use your personal information to:
- Address your requests and enquiries;
- Provide and tailor our services;
- Fulfil our obligations under any agreements between you or your employer or other relevant organisation and us (for example an engagement for the provision of services by you or us);
- Notify you about any changes to our services;
- Comply with our legal obligations;
- Contact you in certain circumstances with marketing in relation to the services and products we or other members of our group offer. You can opt out of marketing or we may otherwise be prevented from doing so by law;
- Contact you for research purposes (subject to your consent) primarily to help us improve our website experience;
- Maintain and improve the quality and content of our websites by analysing the use of our websites to inform our processes;
- Enhance the customer journey and experience in relation to our property.
We may also process your personal information without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We may share your personal information with certain of our affiliates, and trusted third parties in accordance with contractual arrangements in place with them.
Personal information may, where necessary, also be shared with regulatory authorities, courts, tribunals, law enforcement agencies and government agencies. Although unlikely, we may be asked to disclose your personal information to fulfil our legal and regulatory obligations. In such instances, unless we are legally restricted from doing so, we will endeavor to notify you before we disclose such information.
In the event that we reorganise our business or transfer in part or in whole to a third party, we may be obliged to transfer your personal information to such parties in accordance with our contractual obligations.
We do not rent, sell or otherwise make personal information commercially available to any third party, except with your prior permission.
8. PROTECTING YOUR PERSONAL DATA
We implement various technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction. Such measures are aimed at ensuring the on-going integrity and confidentiality of personal information. Access to your personal information is limited to a business need-to-know basis and will only be disseminated to such employees, contractors, agents and third parties as are deemed necessary and appropriate. Additionally, they will only process your personal information according to our instructions and are subject to the duty of confidentiality.
There are procedures in place to address and respond to any suspected or actual data security breach. In the event that there is a suspected data breach of your personal information, we will implement rigorous investigative procedures, and where necessary and appropriate, notify you.
9. DATA RETENTION
Your personal information will only be retained for as long as is necessary to fulfil the purpose for which it has been collected. Our assessment of retention periods will take account of the following:
- Our business and service-led requirements;
- The purposes for which the personal information was initially collected;
- The lawful grounds of processing;
- The categories and types of personal information;
- The volume of personal information; and
- If the purpose of processing can be adequately fulfilled by alternative means.
10. YOUR RIGHTS
As a data subject, you have certain rights under the Data Protection Legislation.
You can request details regarding the personal information we hold about you and how we process such personal information. Further, you may have the right to have such personal information rectified or deleted, to restrict processing of such information, to stop unauthorised transfer of your personal information to third parties and in certain instances, to have your personal information transferred to another organisation. You may also have the right to lodge a complaint against with a local supervisory authority us in relation to our processing of your personal information.
In accordance with our legal obligations, in the event that you object to the processing of your personal information or withdraw your consent at a later date, we will respect your choice and act accordingly.
11. TRANSFER OF INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA (THE “EEA”)
Your personal information may be transferred to, stored and processed in a country outside of the EEA. Where such a country does not ordinarily provide an adequate level of protection of personal information in line with European Union law or the European Commission, we shall ensure that there are adequate safeguards in place to protect your personal information.
12. CHANGES TO OUR PRIVACY NOTICE
13. CONTACT DETAILS
If you have questions or requests about the processing of your personal information, or need additional information, please contact us by email at firstname.lastname@example.org or in writing to:
TS West End Plaza c/o Tishman Speyer Properties UK Limited
10 Bressenden Place
London SW1E 5DU