1. Introduction
1.1 We are committed to safeguarding the privacy of the individuals with whom we work.
1.2 This policy applies to the following categories of person:
(a) our website visitors;
(b) the personnel of our clients and our prospective clients, and the personnel of other landlords and tenants with whom we interact;
(c) the personnel of our suppliers and services providers; and
(d) the personnel of our business partners (for these purposes, “business partners” includes serviced office operators, real estate brokers, real estate service firms, business rates surveyors, building surveyors, project management companies, and design and fit-out contractors).
1.3 This policy applies where we are acting as a data controller with respect to the personal data of these persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Situu Limited. For more information about us, see Section 15.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not (or may not) obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you for marketing purposes (“marketing data”). The marketing data may include your name, business email address, business telephone number, business fax number and/or business postal address. The source of the marketing data is you and/or your employer. In addition, we may obtain marketing data from our business partners.
2.3 We may process information relating to our client relationships, prospective client relationships, supplier relationships, services provider relationships and other business relationships (“client and business partner data”). The client and business partner data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our CRM system, transaction-related data, contract-related data and information contained in or relating to communications between us and you, or between us and your employer. The source of the client and business partner data is you and/or your employer. Again, we may sometimes obtain client and business partner data from our business partners.
2.4 We may process information relating to tenants with respect to whose tenancies we provide services (“tenant data”). The tenant data may include contact names and contact details. The source of the transaction data is you and/or the relevant landlord.
2.5 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of negotiating and entering into contracts, providing our services, purchasing goods and services, managing our business (including management of suppliers, services providers, contractors, agents and consultants), publishing testimonials on our website, generating invoices, bills and other payment-related documentation and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our services and business.
3.3 Relationships and communications – We may process marketing data, client and business partner data and/or tenant data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, and complaint handling. The legal basis for this processing is our legitimate interests, namely business communications with our website visitors, clients and prospective clients, and tenants, and the maintenance of our business relationships generally.
3.4 Direct marketing – We may process marketing data and client and business partner data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is either: (i) consent; or (ii) if we have not asked for your consent, our legitimate interests, namely promoting our business and communicating marketing messages to our clients and prospective clients.
3.5 Research and analysis – We may process usage data and client and business partner data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our services and business generally.
3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data may be stored and processed by our suppliers and services providers in the following categories:
(a) hosting services providers;
(b) communications, marketing and customer relationship management system services providers; and
(c) productivity application services providers.
Details of our current suppliers and services providers are set out on our website.
4.3 We may provide your marketing data, client and business partner data and/or tenant data to our business partners. Our business partners will usually act as independent controllers with respect to your personal data and may in some circumstances disclose your personal data further, in accordance with their own privacy policies and practices.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 Our analytics services provider, Google, Inc, is a multinational company with facilities situated around the world. We will ensure that where required by applicable law international transfers of data to Google, Inc are protected by appropriate safeguards. These may include the use of the standard clauses approved by the competent data protection authorities.
5.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) marketing data will be retained for a minimum period of 6 years following the date of the most recent marketing communication sent by us to you, and for a maximum period of 7 years following that date;
(b) client and business partner data will be retained for a minimum period of 6 years and for a maximum period of 7 years following the later of: (i) the end relevant client or business partner relationship; and (ii) the end of a tenancy with which the relevant data is associated;
(c) tenant data will be retained for a minimum period of 6 years following the end of the relevant tenancy, and for a maximum of 7 years following that date; and
(d) usage data will be retained for 3 years following the date of collection.
6.4 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 6 in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 6, that personal data will be retained for a minimum period of 6 years and a maximum period of 7 years following the date that publication ceases.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Updating information
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10. About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
11.1 We use cookies for the following purposes:
(a) analysis – we use cookies to help us to analyse the use and performance of our website and services; and
(b) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
12.Services provider cookies
12.1 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.
12.2 We may use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
12.3 We may use a LinkedIn Insight Tag (pixel) on our website. Using the Insight Tag, LinkedIn collects information about the users and the use of our website. The information is used to personalise LinkedIn advertisements and to analyse the use of our website. To find out more about the LinkedIn Insight Tag and about LinkedIn’s use of personal data generally, see the LinkedIn cookie policy at https://www.linkedin.com/legal/cookie-policy and the LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy. The LinkedIn cookie policy includes information about controlling LinkedIn’s use of cookies to show you advertisements.
13. Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block cookies, you will not be able to use all the features on our website.
14. Amendments
14.1 We may update this policy from time to time by publishing a new version on our website.
14.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
15. Our details
15.1 This website is owned and operated by Situu Limited.
15.2 We are registered in England and Wales under registration number 12292515, and our registered office is at Bourne House Queen Street, Gomshall, Guildford, Surrey, United Kingdom, GU5 9LY.
15.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
