1 PROMOTER AND DATA CONTROLLER
The data controller of personal data collected through this website is: Shaftesbury Soho LTD, registered company number 05291606. We are registered as a data controller with the Information Commissioner’s Office. We and other Shaftesbury wholly owned companies are all subsidiaries of Shaftesbury PLC (together ‘the group’) and that is why this Group is referenced on this Privacy Page. We are registered as a data controller with the Information Commissioner’s Office, registration number Z286647X. We are committed to protecting your personal data and complying with the Data Protection Act 1998 and associated legislation. This Privacy Page outlines the type of information that is collected by us on this website, and how we use and protect it. This Statement also outlines your rights regarding data protection, and tells you how to contact us. This Statement applies only to this website. For example, it does not apply to banners, advertisements or promotions we may sponsor or participate in on websites owned by third parties. Other websites linking to or from this website may have different policies and we are not responsible for the privacy practices of such other sites. You should read any other applicable privacy policies carefully before using other websites.
This Privacy Page is effective from October 2015. We may change it from time to time by updating this page so please revisit and reread it periodically.
2 PERSONAL DATA AND ITS USES
(a) What we collect and why
TYPICAL PURPOSES ARE AS FOLLOWS:
(i) Answering your queries
Where you send us personal data in the context of asking us a question or query (for example, about the company, or its services) we shall use the data you provide in order to respond to your question. In some cases, and where permitted by data protection law, it may be necessary to share your details with other members of Shaftesbury Group, or with other third party data processors, in order to respond to your question or for limited other purposes as required (see “Data Processors and Data Disclosures” below).
(ii) Entering a promotion
We may use personal data submitted in an entry form for a promotion for the purpose of administering the promotion in accordance with its stated rules and, with your consent where necessary, for direct marketing purposes (see “Future direct marketing” below). Such rules may include obtaining consent from participants who are winners to the publication of abbreviated winners' identity details, and may obtain consent from winners to participate in future publicity. The promotion may be administered by third party agencies on our behalf, who may have access to the data you submit (see “Data Processors and Data Disclosures” below).
(iii) Future direct marketing
With your consent where necessary, we will from time to time send you information about special offers, events, launches and other promotions within the Shaftesbury Group (this means the Shaftesbury Villages i.e. five areas in central London in which Shaftesbury has extensive property holdings in - Carnaby, Chinatown, Berwick Street, Seven Dials, Opera Quarter) about products or services of other companies in the Shaftesbury Group and those of carefully selected third parties which we believe may be of interest to you. If you agree, we may also share your data with or pass it to other companies in the Shaftesbury Group for the purposes of their sending you information about other offers and events which they may be running which may be of interest to you but we will not pass your details on to third parties outside the Shaftesbury Group for their own marketing. All of this marketing may be sent by email, SMS, or other electronic means, depending on the contact details you give us when you agree to receive that marketing. At any time, however, you may unsubscribe from ("opt out" of) such future contact by following the instructions in the marketing communication itself.
(iv) For other purposes permitted or required by data protection law
This may include, for example, use of personal data where necessary as part of any restructuring relating to us and our business or assets, or as part of a sale of our company or its assets. It may also include responding to governmental or law enforcement agency requests for information about visitors to our website or to the Villages.
3 DATA PROCESSORS AND DATA DISCLOSURES
At times we may retain third parties to process or analyse data we collect on our websites, including your personal data. For example, the website may be maintained or hosted by a specialist IT services agency, and any promotions may be administered by a sales promotion agency. These suppliers and other third parties are contractually obliged not to use your personal data in any way other than that which we have specified.
We may also share your personal data with third party businesses based in the Shaftesbury Villages to the extent needed for proper management of the Villages and with third party businesses who advertise on this website or who wish to send their own marketing to you (see “Personal data and its Uses”).
WE MAY ALSO DISCLOSE YOUR PERSONAL DATA:
(i) In response to a court order, or a request for cooperation from a law enforcement or other government agency or if disclosure is otherwise required by search warrant or law;
(ii) To establish or exercise legal rights, defend legal claims, or for responsible corporate governance;
(iii) To buyers where necessary as part of any restructuring relating to us and our business or assets, or as part of a sale of our company; and
(iv) As may otherwise be permitted or required by data protection law.
4 DATA TRANSFERS
Your personal data may be transferred to countries or territories outside the European Economic Area (this includes all countries in the European Union together with Norway, Iceland, Liechtenstein) which do not have data protection laws as protective as those applicable in the UK. For example, the data processors mentioned above may be based outside the EEA. We will seek to ensure the protection applied to your personal data as processed in those other countries or territories is adequate and in accordance with data protection law.
We take all reasonable precautions to seek to keep your personal data secure, and to require third party data processors to do likewise, in accordance with our obligations under data protection law. All personally identifiable information is subject to restricted access to prevent unauthorised access, modification or misuse. Please note, however, as indicated above, that we may release your personal data if required to do so by law, or by search warrant, or court order. Like all website operators, we cannot guarantee that all data transmitted over the Internet or through this website will be secure. Please do not provide us with your personal information through this website unless you accept the security implications of dealing online.
6 COOKIES AND WEB BEACONS
7 IP ADDRESSES
8 DATA ANONYMISATION AND AGGREGATION
9 HOW TO OBTAIN COPIES OF YOUR PERSONAL DATA AND HOW TO UPDATE IT
If you believe that any personal data we have about you is incorrect or incomplete, please contact us through the “Contact” tab on our website as soon as possible. We will seek to correct or update your personal data promptly.
You are entitled to obtain copies of your personal data from us subject to exemptions and limitations under Subject Access Rights under the Data Protection Act 1988. We may charge a small statutory fee (currently £10) in relation to that. Please contact us for further details at email@example.com or Sister London, 46a Carnaby Street, London, W1F 9PS. Requests for copies of your personal data must be made in writing i.e. by post or by email.
10 EXTERNAL LINKS
Please note that Shaftesbury Soho LTD does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site. Any external site that you visit by clicking through a link on this site that is outside the control of Shaftesbury Soho LTD you visit entirely at your own risk. Please read their terms and conditions. Should you find that a link which has directed you either to or from this website contains unethical material, please inform us using the ‘Contact Us’ section of our website and we will do our best to ensure that such link is removed. Should you find our website advertised and / or linked on a website you believe to be unethical or inappropriate, we would be grateful if you could inform us as soon as is reasonably practical via the ‘Contact Us’ section of our website.
A cookie is a small piece of data sent by our server to your computer or to the other device you are using to access our website e.g. smartphone, so that information can be recalled. A cookie is stored by your web browser in a text file on your computer or other device. Each time your web browser requests content from a server that has previously interacted with your machine or other device, the cookie’s message is sent back to our server.
Cookies relating to this website are passive and just used for collecting and transferring that anonymous information. By this we mean that no cookie set while on this site will capture any personal data about you (or be used in any malicious fashion whatsoever). Personal data is referred to in more detail in our Privacy Statement.
Two types of cookies may be used on this website; "session cookies", which are temporary cookies that remain in the cookie file of your browser until you leave the site, and “persistent cookies", which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). These are referred to in more detail in the table below.
To learn more about cookies please visit http://www.allaboutcookies.org/
To learn how to adjust your browser settings so that cookies aren’t accepted or to delete or block cookies at any time please visit http://www.aboutcookies.org/default.aspx?page=1
The purpose for which we use analytical/performance cookies is as follows. We use them to collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. Identifying how visitors arrive at our site and the path they take through it to help us to improve our service to you. We use third party tools to monitor and analyse traffic to, from and within our website. In addition, we use strictly necessary cookies in order for the website to function properly.
Below is a summary of the types of cookie that may be set or read while your machine or other device is used to access this site, their function, and the issuer setting this cookie: