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General Data Protection Regulation



Baynards Green Management Limited & Baynards Freehold Limited – Privacy policy
Who we are – Baynards Green Management Limited & Baynards Freehold Limited who we refer to as BGML and BFL hereafter.
We, BGML and BFL act to ensure your privacy is protected and this document aims to describe how, when and what personal data is collected and how we may use this information.

Outline information
Use of your personal data will be in accordance with this privacy policy and we, BGML & BFL, are the controller for the collection and use of this personal information. We aim to ensure this information is treated as confidential, held and used in accordance with current General Data Protection Regulations (GDPR) and only shared as described in this policy. This policy may change from time to time to ensure compliance with all relevant legislation.
• What personal information is
• How we collect your personal information
• The types of personal information we collect
• How we use your personal information
• The legal basis for processing your personal information
• How we share your personal information
• How long we keep your personal information
• How we keep your personal information secure
• Your rights in relation to your personal information
• How to make complaints and how to contact us
• If there are any changes to the way in which your personal information is used, this Privacy Policy will be updated.

Personal Information
This is any information that identifies you, personally e.g. Your name, address, contact details (phone, email etc.) that would enable anyone to identify you personally.

There are other types of information considered to be ‘Special Data’ e.g. Ethnic origin, religious beliefs, sexual orientation. BGML & BFL does not collect or store any data in this category.

Information we collect and receive
We will regularly collect your full name and contact details (such as phone number, email address and postal address) usually from the point of first contact with us. If you are a client and we are providing a service to you, we may legally be required to collect information relating to your identity, which will be at least one form of photographic identification (such as a passport) and documentation with proof of your place of residence (such as a recent utility bill).
Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;

How we use this information
Customer Data will be used by BGML & BFL in accordance with Customer’s instructions, including any applicable terms in the Client Agreement and as required by applicable law. BGML & BFL is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
BGML & BFL uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business.
More specifically, BGML & BFL uses Other Information:
• To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorized User’s request.
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
• To develop and provide search, learning and productivity tools and additional features. BGML & BFL tries to make the Services as useful as possible for Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about BGML & BFL. These are marketing messages, so you can control whether you receive them.
• For billing, account management and other administrative matters. BGML & BFL may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.
• If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, BGML & BFL may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Other uses of your personal information
If we sell any part of our business your details may be disclosed to our advisers and to our prospective purchasers and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes Control Esc – IT systems providers and IT contractors as well as third party referencing agencies for the purposes of the prevention and detection of crime and protection of our client(s) interests. This currently includes Microsoft for the purpose of email services and WordPress for website provision.

We may share your personal information with any person working with BGML & BFL on a need to know basis to ensure we are able to perform our obligations to you. We will hold your personal information on our client management systems.

Keeping your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
Our client files are stored on our secure client management systems (currently Control Esc). Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes. Data is stored on Control Esc’s cloud based servers located within the EU.
Hard copy documentation is stored in places which are locked outside of usual business hours.
All data is hosted in EU datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.

How long do we keep your personal information?
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim. Also, where we have legitimate business interest in marketing our services to potential future clients, your data will be retained unless you choose to opt out of receiving such marketing.

Your rights
You have a number of rights in relation to your personal information, these include the right to:
• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information in the following circumstances:
– If BGML & BFL is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
– If BGML & BFL is relying on consent as the legal basis for processing and you withdraw consent
– If BGML & BFL is relying on legitimate business interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
– If the personal information has been processed unlawfully (i.e. in breach of the requirements of prevailing data protection legislation)
– If it is necessary to delete the personal information to comply with a legal obligation
• Ask us to restrict our data processing activities where you consider that:
– personal information is inaccurate
– our processing of your personal information is unlawful
– where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
– where you have raised an objection to our use of your personal information
• Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
• Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and if you would like to exercise any of your rights please contact [email protected]

Complaints and who to contact
If you have any complaints about the way we use your personal information please contact the Data Protection Officer at [email protected] who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting [email protected]

Contact details
If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by sending an email to [email protected] or writing to the Data Protection Officer, Baynards Green Management Limited & Baynards Freehold Limited, Estate Office, 1 Chepstow Place, London, W2 4TE