Privacy Notice for Direct Marketing in relation to The Jenners Building
1. Important information and who we are
This privacy notice sets out how 15.08.2017 Opco Limited (Company Registration Number SC815416) (referred to as ‘’the Company’’, ‘’we’’, ‘’us’’, or ‘’our’’ in this privacy notice) collects, uses and protects your personal data through your use of this website, when you visit our website and sign up to receive marketing communications from us and from other companies within the Heartland AS Group of companies in connection with The Jenners Building 48 Princess Street, Edinburgh, EH2 2YJ (‘’Building’’).
This privacy notice relates to the personal data we collect through this website; operators within the Building (‘’Tenants’’) are separate organisations and will have their own privacy notices in relation to any personal data they collect from you directly.
The Company is part of the Heartland AS group of companies ("Group"). References in this privacy notice to marketing and promotional communications from "us" include marketing communications sent by other Group companies in connection with the Building. Please note, the companies forming part of the Group may change from time to time.
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data – this includes your name, title, marital status, date of birth and gender.
Contact Data – this includes your email address and telephone number.
Technical Data – this includes your internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, cookie identifiers, and other technology on the devices you use to access this website.
Usage Data – this includes information about how you interact with and use our website, such as pages visited and session duration.
Marketing and Communications Data – this includes your preferences in receiving marketing from us and from other entities within the Group and your communication preferences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
(i) Your interactions with us. You may give us your personal data by signing up to receive updates or through our website or by corresponding with us by email or otherwise. This includes personal data you provide when you:
sign up to our mailing list to receive marketing communications from the Company and other Group companies about the Building;
register your interest in the Building or a specific Tenant offering;
enter a competition, promotion or survey; or
give us feedback or contact us.
(ii) Automated technologies or interactions, and cookies. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data through server logs, cookies and similar technologies, including cookies that are necessary for the operation, security and functionality of the website, performance and analytics cookies, and advertising cookies. Performance and analytics, and advertising cookies are only placed with your consent. You can manage your cookie preferences through the cookie settings on our website. Our website is hosted by a third-party platform provider, Squarespace, which may collect this data on our behalf as part of the standard operation of the platform.
4. How we use your personal data
4.1. Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you sign up to receive news and updates.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so.
Purpose/Use
To send you marketing communications from the Company and other Group companies in connection with the Building (including news, events, offers, and updates relating to the Building).
Type of data
(a) Identity
(b) Contact
(c) Marketing Communications
Legal basis (and retention period)
Consent – having obtained your prior opt-in consent to receiving these communications.
Purpose/Use
To register you on our mailing list and manage your sign-up preferences.
Type of data
(a) Identity
(b) Contact
(c) Marketing Communications
Legal basis (and retention period)
Consent – you will have actively opted into receiving marketing communications from us and other Group companies in connection with the Building.
Purpose/Use
To send you marketing communications about our Tenants' products, services, offers and promotions (e.g. an offer from an operator within the Building) on behalf of those Tenants.
Type of data
(a) Identity
(b) Contact
(c) Marketing Communications
Legal basis (and retention period)
Consent – having obtained your prior opt-in consent to receiving these communications.
Purpose/Use
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.
Type of data
(a) Technical
(b) Usage
Legal basis (and retention period)
Legitimate interests – necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
4.2. Direct marketing
When you sign up via our website, you will be asked to provide your consent to receive direct marketing communications from the Company and from other Group companies, in each case in connection with the Building. This will include:
news and updates about the Building, including;
promotional offers, events, and information about products and services available at the Building, including those offered by Tenants; and
invitations to competitions, surveys, and other promotional activities.
We may also analyse your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
4.3. Third-party marketing
We will only share your personal data with a specific Tenant for their own direct marketing purposes where you have expressly consented to this.
4.4. Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.
5. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Other companies within the Group, for the purpose of sending you marketing communications in connection with the Building, where you have consented to receiving such communications.
Service providers who assist us in operating our website, managing our mailing list, and sending marketing communications on our behalf (e.g. email-marketing platforms and IT service providers).
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not share your personal data with our Tenants for their own marketing purposes unless you have given your consent to that. Where we promote a Tenant's products or services to you, we do so ourselves. If a Tenant wishes to collect your personal data directly (for example, through their own website or in-store), that will be subject to the Tenant's own privacy notice and is separate from the data we hold.
6. International transfers
Your personal data may be shared with other companies within the Group that are located outside the UK. Where we transfer your personal data outside the UK, we ensure that appropriate safeguards are in place. Transfers to countries within the European Economic Area (EEA) are protected by the UK's adequacy regulations, which recognise EEA countries as providing an adequate level of data protection.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For marketing data, we will retain your personal data for as long as you remain subscribed to our mailing list. If you unsubscribe, we will delete or anonymise your personal data within a reasonable period, save for a suppression record to ensure we do not contact you again.
In some circumstances you can ask us to delete your data: see section 9 below for further information.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. In certain circumstances you can ask us to delete or remove your personal data.
Object to processing of your personal data. In certain circumstances, you can ask us to stop processing your personal data.
Request restriction of processing of your personal data. In certain circumstances you can ask us to suspend the processing of your personal data.
Withdraw consent at any time where we are relying on consent to process your personal data.
10. Contact details
If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact enquiries@thejennersbuilding.com.
11. Complaints
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can do this by contacting enquiries@thejennersbuilding.com.
12. Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review and may update it from time to time.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example if you have a new email address.