Privacy Notice

The Ethical Property Company PLC: Privacy Notice

Our contact details

The Ethical Property Company PLC
The Old Music Hall, 106–108 Cowley Road, Oxford, OX4 1JE
Tel: 01865 207810

The type of personal information we collect

We currently collect and process the following information:

Identity data, such as title, name and user ID.
Contact data, such as your address, billing address, email address and telephone numbers.
Financial data, such as bank and payment card details.
Transactional data, such as payments made by and to you, and details of services provided to you.
Technical data, including your IP address, login information, browser type and version, time zone setting and location, browser plug-ins and other technology on the devices used to access our website.
Profile data, including your purchases or orders, your interests and preferences, and any feedback or survey responses you provide to us.
Usage data, including how you use our website, products and services.
Marketing and communications data, including your preferences in relation to marketing from us and from any third parties, and your preferences for methods of communication.
Special categories of personal data: owing to the products and services that we offer, The Ethical Property Company PLC sometimes needs to process sensitive personal information (known as ‘special category data’) to ensure your health and safety, e.g. information on allergens. Where we collect such information, we will only request and process the minimum data necessary for the specified purpose and will identify a compliant legal basis for doing so.
CCTV images are used for the prevention, detection and investigation of criminal activity and to keep our guests and staff safe. It is our policy not to disclose images to anyone other than the police.

Personal data of third parties

If you act on behalf of or book a viewing for another person, we will also collect their data for the purposes outlined in this Notice.

Failure to provide personal data

In some cases we may need to collect your personal data by law, or in order to perform our side of a contract we have entered into with you, or with a view to entering into such a contract. If you fail to provide the requested data, we may not be able to perform under the contract we have with you, or to enter into the contract with you. In such circumstances we may have to cancel the contract, or be unable to fulfil the contract, which means we would not be able to provide the product or service to you. If that is the case, we will notify you of this at the time.

Collection of personal information via cookies

A cookie is information sent by a web server to a web browser, which enables the server to collect information from the browser. Find more about cookies at www.allaboutcookies.org

Personal data is collected regarding a user’s journey through our website, and the placement of cookies throughout our site allows us to enhance the user journey. This data is held for use in Google Analytics to enable us to better understand customer behaviour and to better deliver our products or services.

The information generated by these cookies (including your truncated IP address) is transmitted to and stored by Google on servers in the US. Google uses this information for the purpose of evaluating your and others’ use of our website, compiling reports for us on website activity, and providing other services relating to website activity and Internet usage.

Please note that Google only receives your truncated IP address. This is sufficient for Google to identify the country from which you are visiting our site, but is not sufficient to identify you, or your computer or mobile device, individually.

The law states that we can store cookies on your device if they are strictly necessary for the operation of our website. For all other types of cookies, we need your permission. We will therefore ask for your permission when you enter our website and give you the option to choose which cookies you wish to be activated.

Once consent is obtained, it is not necessary for us to obtain it again for the same user each time the same cookie is used in the future. Users may change their preferences at any time via the cookie tab on our website.

Our website uses different types of cookies. Some cookies are placed by third party services that appear on our pages. If you come to our website from another website, we may receive personal information about you from the other website. You should read the privacy policy of the website you came from to find out more about this.

Third party advertising

We may use third party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use our online service, other websites or online services. To serve such advertisements, these companies place or recognise a unique cookie on your browser (including through use of pixel tags – see below).

We collect data from pixel tags, which are primarily used to track the actions of users of our online services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of our online services.

We may receive personal data relating to you from third parties or public sources inside or outside the UK and European Economic Area (‘EEA’), including (though not limited to):

Analytics providers (Google based outside the EEA)
Advertising networks (e.g. Google, Bing, Facebook, Instagram, Linkedin).

If you would like more information about this practice and to learn about your choices in relation to it, please visit www.allaboutcookies.org

We use these cookies to help ensure that our share advertisements and other communications are relevant to users and to measure how our visitors are interacting with our marketing and advertising materials. These cookies may be set by The Ethical Property Company PLC or by our advertising partners. They may be used to build a profile to show you relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet devices.

You can opt out of seeing online interest-based advertisements from Facebook and other participating companies through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Interactive Digital Advertising Alliance in Europe. You can also opt out through your mobile device settings, where available, using Android, iOS 13, or an earlier version of iOS. Please note that ad blockers and tools that restrict our cookie use may interfere with these controls.

How we collect personal information and why we have it

We collect your personal data in a number of ways. For example, we collect data from and about you when you visit our website, book a viewing, contact us, make a booking, rent space from us, visit our centres or use our internal and online systems such as Tenants Resources. Data is collected through:

Direct interactions – you may provide personal data to us (e.g. identity, contact details, financial data) when you complete forms or correspond with us by post, phone, email or other methods. This could include providing personal data when you:

Make an enquiry to receive our services or products
Subscribe to our services or publications
Request marketing material to be sent to you
Enter a promotion or complete a survey
Provide feedback to us.

Automated technologies or interactions – when you interact with our website, we may collect some technical data relating to you, including details about your devices or browsing patterns. This data may be collected using cookies (see above) or other similar technologies.

Third parties or publicly available sources – we may receive personal data relating to you from third parties or public sources inside or outside the UK and European Economic Area (‘EEA’), including (though not limited to):

Analytics providers (Google based outside the EEA)
Advertising networks (e.g. Google, Bing, Facebook, Instagram, Linkedin).

Purpose for which we will use your personal data

The table below sets out all the ways we intend to use your personal data and the legal basis we will rely upon to do so (the ‘lawful purpose for processing’), including where gathering this data is a legitimate interest.

Please note that we may process your personal data for more than one lawful purpose, depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of data	Lawful purpose for processing
To process your enquiry, set up a new customer account/profile.	Identity Contact Profile	Consent (if required) Entry into or performance of a contract to which you are party Legitimate interest
To process a booking/viewing, whether made directly with us or via an external agency.	Identity Contact Financial Transactional Profile Marketing and communications Special categories of personal data	Entry into or performance of a contract to which you are party Required for our legitimate interest to ensure your safety while on our premises Consent (if required) Vital interest
To process payment and to invoice	Financial Transactional	Performance of a contract to which you are party
Under UK legislation we are legally obliged to collect specific information from you to verify your identity, e.g. for setting up contracts and renting space.	Identity Contact	Legal obligation Legitimate interest
The Ethical Property Company PLC will store your personal details on our databases: To comply with data retention obligations To allow us to contact you in relation to any enquiry you have made.	Identity Contact Profile Transactional Marketing and communications	Legal obligation Legitimate interest Performance of a contract to which you are party
Where applicable, if you park in one of our carparks we will collect your car registration number.	Profile Transactional	Legitimate interest
The Ethical Property Company PLC at all times aims to keep the data we store secure on our premises and on our IT systems and platforms. We do this by means of encryption, passwords, access controls, physical security, company policies and IT support. Personal data may be processed in this context by The Ethical Property Company PLC and its third party vendors.	Identity Contact Financial	Performance of a contract to which you are party Legitimate interest
The Ethical Property Company PLC will collect (meta) data on your use of our Wi-Fi services for security and anti-piracy purposes. For example: IP address, connections made, location etc.	Technical	Consent (if required) Legitimate interest Public interest
The Ethical Property Company PLC will track and record your use of our online services, either through cookies or via other means. Cookies enable us and others to monitor your browsing behaviour.	Technical Usage	Legitimate interest
The Ethical Property Company PLC collects automatically generated information for statistical (research) purposes to tell us how well our services are working. This information may be provided to third parties, but only if permitted by law or if this information cannot be traced back to you.	Usage	Legitimate interest
The Ethical Property Company PLC aims to keep its assets, staff, guests and tenants secure and safe at all times and to prevent our premises being used for illegal purposes. Through CCTV surveillance, The Ethical Property Company PLC and/or third party vendors may process personal data by way of images and footage.	CCTV images	Legitimate interest Public interest
The Ethical Property Company PLC is required to comply with legal obligations, requests for information or instructions from public authorities and third party claims or access to our data, e.g. in the event of a criminal investigation, fire or terrorist attack, that involve processing personal data.	Identity Contact Technical CCTV images	Legitimate interest Public interest Vital interest Legal obligation

Third party marketing

We will obtain your express opt-in consent before we share your personal data with any company outside The Ethical Property Company PLC for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at marketing@ethicalproperty.co.uk

When you opt out of receiving marketing messages, this will not apply to personal data provided to us because of a product/service purchase, warranty registration, product/service experience or other transactions.

Disclosure of your information to third parties

The personal data you provide to us may be accessed by or given to third parties, some of whom may be located inside or outside the UK and European Economic Area (‘EEA’), who act for us for the purposes set out in this Notice or for other purposes approved by you. Those parties process information, fulfil and deliver orders, process credit card payments and provide support services on our behalf.

We may also pass aggregated information on the usage of our website to third parties, but this will not include information that can be used to identify you, either directly or indirectly.

Where you have specifically consented when providing us with your details, we may also allow carefully selected third parties to contact you occasionally about products and services which may be of interest to you. They may contact you by email. You can withdraw your consent to this at any time. If you change your mind about being contacted by these companies in the future, please let us know at marketing@ethicalproperty.co.uk

If our business enters into a joint venture with or is merged with or sold to another business entity, your information may be disclosed to our new business partners or owners. Countries outside the UK and EEA do not always have strong data protection laws.

We will take steps to ensure that your data is used by third parties in accordance with this Notice. Unless required or permitted by law to do so, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

International data transfer

Some of the third parties that we may disclose your personal data to are based outside the UK and EEA, so their processing of your personal data will involve a transfer of your personal data outside the UK and EEA. Whenever we transfer your personal data outside the UK and EEA, we will ensure that it is afforded a similar degree of protection by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
Where we use certain service providers, we may use specific contracts or UK model clauses.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the UK and the US.

Please contact us if you wish to receive further information about the specific mechanism used by us when transferring your personal data outside the UK.

Information retention

We will retain your personal data for as long as we need it for the purposes for which we collected it, or if we are legally required to do so.

The Ethical Property Company PLC only retains personal data for as long as is necessary, and we have strict review and retention policies in place to meet these obligations. Generally, where we have a contractual relationship with you, we will retain your data for a period of seven (7) years from the date our contractual relationship ends unless we are legally required to retain it for a longer period.

Where you have consented to us using your details for direct marketing, we will keep such data for 36 months from the date of your latest consent or until you notify us otherwise and withdraw your consent.

Data security

The Ethical Property Company PLC takes all appropriate technical and organisational measures, in accordance with local law requirements, to protect your personally identifiable information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access. To this end, we have implemented technical measures such as firewalls and operational measures such as login requirements, efficient passwords and physical protection.

Your rights as a data subject

As an individual, as a data subject under Data Protection Law in relation to the processing of your personal data, you have the right to:

Be informed about how The Ethical Property Company PLC collects and processes your personal data, as explained in this Privacy Notice.
Request access to your personal data (a ‘data subject access request’), which enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request amendments to the personal data that we hold about you, to have any incomplete or inaccurate information corrected.
Request erasure of your personal data, such that we delete or remove personal data where there is no good and lawful reason for us to continue to process it (although in some cases we can refuse this request, where we can claim exemptions as a data controller).
Object to the processing of your personal data where we are processing this data for direct marketing or where we are relying on a legitimate interest (of The Ethical Property Company PLC or of a third party) and there is something specific to your situation which gives rise to your objection.
Request the restriction of processing of your personal data through the suspension of our processing, e.g. where you want us to establish its accuracy or the reasons for processing.
Request the transfer of your personal data to another party.
Withdraw consent at any time where we are relying on consent to process your personal data (although this will not affect the lawfulness of any processing carried out before the withdrawal of consent).
Where processing is required under a contract or by consent, request that a decision made using automated processing of your personal data, which significantly affects you, be reviewed by an individual to whom you may make representations and contest the decision.

We do not usually charge individuals for any requests made regarding the collection of information. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We will need you to identify yourself formally prior to responding to your request. As such, we may request a valid form of identification such as a current driver’s licence, identity card or passport.

Changes to our Privacy Notice

The Privacy Notice was last updated on 01/02/2022. To assist us in keeping the personal data we process about you accurate and up to date for the duration of your relationship with us, it is important that you inform us of any change to your personal data that you have provided to us as soon as possible, by contacting us at data.protection@ethicalproperty.co.uk. We keep our Privacy Notice under regular review, and we will place any updates on our website.

Concerns or complaints

The Ethical Property Company PLC processes your personal information in compliance with this Privacy Notice and in accordance with the relevant data protection law. If you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority, the UK Information Commissioner’s Office (ICO). The website of the UK ICO’s office contains details of how to make a complaint: https://ico.org.uk/

The Ethical Property Company PLC, 1 February 2022