Privacy Notice

1. WHO ARE WE?

We are PIC Arbour Limited Partnership, 14 Cornhill, London, EC3V 3ND. We are the owner of Arbour, Milton Keynes (“the Property”). This website is provided by Siren Design Limited (“Siren”) on our behalf for marketing and enquiries in relation to this Property.

2. WHAT IS THIS NOTICE?

When you interact with this website, you may provide Personal Data, meaning any data which can be used to identify you as an individual. The individual who can be identified from the Personal Data is known as the Data Subject. In respect of any such Personal Data, PIC Arbour Limited Partnership are acting as a Controller (which is the business responsible for making the decision to collect the Personal Data in the first place, and deciding what to collect and how to use it).

To help us to connect with you, we use a marketing agency. Currently we use a company called Siren Design Limited (“Siren”) to manage our marketing services for this Property. This means that Siren may handle Personal Data as a Processor (which is a business acting on our behalf and authorised to use the Personal Data in accordance with our instructions). This notice deals with this marketing activity and sets out what Personal Data we collect from you when you interact with our marketing agency through this website. If you have any questions about how we use personal data relating to you, please contact us at the address above or by email at dataprotection@pensioncorporation.com.

3. WHAT INFORMATION DO WE COLLECT AND STORE?

We may collect and process the following Personal Data:
INFORMATION WHICH YOU PROVIDE US WITH WHEN YOU MAKE AN ENQUIRY THROUGH THIS WEBSITE, INCLUDING WHERE YOU CONTACT US TO ARRANGE A VIEWING:
Contact details, including your name and email address, this information is stored in a 3rd party contact management system (Intuit Mailchimp)

INFORMATION WHICH IS AUTOMATICALLY COLLECTED WHEN YOU USE OUR WEBSITE:
For example, cookies and other web traffic information collected from users of this website. For these purposes, this website utilises anonymous Google analytics Cookies which may be temporarily stored on the device used to visit this website. Please refer to Section 4 ‘STATISTICAL ANALYSIS’.

4. HOW DO WE USE THE DATA WE COLLECT ABOUT YOU AND WHAT’S OUR LEGAL BASIS?

We may use the data we collect about you in the following ways:

TO MANAGE OUR RELATIONSHIP WITH YOU:
for example, to respond to enquiries you submit via this website. if you request a viewing, we will use the Personal Data provided in your request to arrange this. In doing so, Personal Data may be transferred to the relevant Property manager (see section 5 below). In such cases, this Personal Data processing is necessary for performance of (or steps at your request prior to entering into) a contract.

INTERNAL BUSINESS REQUIREMENTS: we may use your Personal Data in accordance with our internal business requirements. For example we may need to retain back-up copies of data to make sure we have adequate safeguards in place to prevent loss of the data we hold; we may need to use your data to resolve disputes. In this instance, we are relying on the fact that such use is essential to protect a legitimate interest to enable us to run our business successfully. Any copies of the data held will be held securely and no further use shall be made of such data save as set out herein. We believe that such use would be generally anticipated by data subjects and is highly unlikely to cause any damage to or be considered by data subjects to be invasive of their privacy.

STATISTICAL ANALYSIS: Information relating to how you arrived on this website and your use of the information held therein is collected by Cookies designed by Google. While such Cookies are considered to be Personal Data, no information which could identify you is obtained and any information relating to your device (smartphone or computer) such as the IP address is anonymised in this processing.

5. WILL PERSONAL DATA ABOUT YOU BE DISCLOSED TO ANYONE ELSE?

We will not pass Personal Data about you to third parties for marketing purposes unless you have expressly consented to it.

We may disclose your Personal Data in the following circumstances :

• Our Property Manager (Savills) for arranging and providing viewings of the Property. If you decide to make an application for the Property, further Personal Data will be required and an appropriate privacy notice will be provided prior to you providing this.
• Our licensors, and third parties who are contracted to provide services to help us to carry out our business. Any employees and/or data processors (including Siren) contracted by us will be subject to strict contractual requirements only to use your personal data in accordance with our instructions.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the operation of our website, or the rights, Property, or safety of us, our residents or website visitors, or others.
• If we sell or buy any business or assets and the nature of that transaction requires your Personal Data to be involved. We will never sell Personal Data as a sole asset.

6. WHAT SECURITY PROCEDURES DO WE HAVE IN PLACE?

We take information and system security very seriously and we strive to comply with our obligations at all times. Any Personal Data which is collected, recorded or used in any way, by us or any service provider on our behalf, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Personal Data is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of Personal Data.

7. WHERE DO WE STORE THE PERSONAL DATA WE COLLECT?

We (and our service providers) may store and process Personal Data in countries outside the UK or the EEA. Where this is the case, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties with ongoing oversight to ensure they meet these obligations.

Both Google (to understand user interaction and site usability) and MailChimp (to store the provided contact information for arranging viewings) data is processed via the United States.

8. FOR HOW LONG DO WE STORE PERSONAL DATA ABOUT YOU?

We (and our service providers) will only retain Personal Data for as long as is necessary to fulfil the purposes stated in this Privacy Notice, e.g. enabling our Property Manager to respond to your enquiry about the Property, or to fulfil any applicable legal obligation. Your rights in respect of any Personal Data we hold about you are detailed in this Privacy Notice and you have the right to request deletion of any Personal Data.

9. WHAT RIGHTS DO YOU HAVE IN RESPECT OF ANY PERSONAL DATA WE HOLD ABOUT YOU?

Data Subjects have the following rights in respect of Personal Data relating to them which can be enforced against the Controller:

Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it’s used.

Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:

• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long it will be stored
• If data wasn’t collected directly from the Data Subject, information about the source.

Right of rectification: the right to require the Controller to correct any Personal Data held about the Data Subject which is inaccurate or incomplete.

Right to be forgotten: in certain circumstances, the right to have the Personal Data held about the Data Subject erased from the Controller’s records.

Right to restriction of processing: the right to request the Controller to restrict the processing carried out in respect of Personal Data relating to the Data Subject. You might want to do this, for instance, if you think the data held by the Controller is inaccurate and you would like to restrict processing the data has been reviewed and updated if necessary.

Right of portability: the right to have the Personal Data held by the Controller about the Data Subject transferred to another organisation, to the extent it was provided in a structured, commonly used and machine-readable format.

Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose).

Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on the Data Subject.

We may need to ask you for further information and identification to help us to comply with such requests.

10. WHO DO YOU COMPLAIN TO IF YOU’RE NOT HAPPY WITH HOW WE PROCESS YOUR PERSONAL DATA?

If you have any questions about our use of Personal Data, please contact us:

Data Protection Officer
PIC Arbour Limited Partnership
14 Cornhill
London EC3V 3ND

OR dataprotection@pensioncorporation.com

While we hope that we can resolve any complaints for you, you do have the option to complain to your local data protection authority (e.g. the ICO in the UK). This is available to you whether or not you have exhausted our complaints procedure.
https://ico.org.uk/concerns/.