Last updated: 22nd September 2023
1. Introduction
This Privacy Notice outlines the processing of Personal Data on the sugarhouseisland.com website (the “Website”) and applies to our Website visitors, suppliers, customers, partners and newsletter subscribers. We also have a separate Privacy Notice for our UK residential tenants, which is available here: https://sugarhouseisland.com/tenant-privacy-policy/
This Privacy Notice describes our policies and practices regarding our collection and use of your Personal Data and sets out your right to privacy. We recognize that privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new Personal Data practices or adopt new privacy policies.
Personal Data will be processed in compliance with UK data protection legislation, including the Data Protection Act 2018 and any applicable parts of the EU General Data Protection Regulation (Regulation (EU) 2016/679), and any other UK or EU legislation which implements or supplements the foregoing). “Personal Data”, “Controller” and “Processor” have the meanings given in the applicable data protection laws.
2. Who is the Controller for the processing of your Personal Data?
The entity responsible for your Personal Data depends on the products and services you interact with when using the Website.
Vastint UK Services Ltd (a limited company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB) is the owner of the Website and will usually be the Controller of the Personal Data collected via the Website.
The Website is also operated on behalf of, and contains content belonging to the following companies in the same group as Vastint UK Services Ltd: Vastint UK Residential Limited (a company registered in England under company number 12413617, whose registered address is 135 High Street, London E15 2RB); and Vastint UK B.V. (a company registered in the Netherlands with trade register number 34363982, whose registered address is Hettenheuvelweg 51, 1101 BM Amsterdam, The Netherlands). These other companies may from time to time act as Controller and/or Processor of your Personal Data. These companies will be referred to hereafter as “Vastint”, “us” or “we” or “our”.
3. Which categories of Personal Data do we process?
We collect the following types of Personal Data when you visit and use the Website:
- Information you provide to us: We collect Personal Data that you choose to provide to us when filling out a contact form on this Website, including when subscribing to e-mail notifications, when corresponding with us on this Website, and when entering into business with us as partner or supplier. Such Personal Data may include: your first name and surname, email address, telephone number, information about your preferences and interests (such as types and locations of properties you are interested in), (where applicable) information about your business (such as your work telephone number, your work e-mail address, your position within the business, education and training etc.), financial information (if required for the performance of the service and/or invoicing) and any other Personal Data you provide to us when corresponding with us.
- Information automatically collected by us: When you visit or interact with this Website, we may collect Personal Data about you and your visit. Such information may include: your IP address and other unique identifiers for the computer, mobile or other device you use to access this Website, your user behaviour and any referring Website, the date, time and duration of your visit, your browser type and your operating system and your cookie consent preferences. We gather such information through cookies and other web technologies. More information on the use of cookies can be found in our Cookie Notice.
4. Why and under which lawful basis do we process your Personal Data?
We process your Personal Data when you visit the Website for the following purposes and based on one of the following lawful bases:
- When you provide your consent, and where permitted by applicable law: to inform you and to promote our (new) products and services (for instance via direct marketing communications); to place cookies on your device (please refer to our Cookie Notice for more information).
- To perform our contract with you or enter into such contract with you, where applicable.
- For our legitimate (business or legal) interests: to answer your queries and further maintain contact with you, if necessary; for our internal management; for the handling of complaints and disputes; to provide, maintain, secure and optimize our Website and compile user statistics for improvement of the Website to ensure we can provide you with a well-functioning website (please refer to our Cookie Notice for more information).
- For compliance with our legal obligations when required under applicable UK law.
5. When and how we share your information with others
These include:
- Our Service Providers: Your Personal Data may be disclosed to our service providers who perform services on our behalf. These may include in particular:
- Service providers who provide hosting, maintenance and content management of this Website;
- Email distribution service providers, in relation to any newsletters or other marketing communications that you sign up for via this Website;
- Lettings agents, where you have consented to be contacted in relation to lettings via this Website.
Our service providers are subject to contractual obligations to safeguard your Personal Data and to only process the Personal Data as instructed.
- Other third parties (anonymized data only): We may provide anonymized data that we have collected about the use of this Website such as user numbers, patterns, referring websites and so on to third parties such as prospective investors or purchasers, affiliates and partners. This would not include any personally identifying data.
- Other third parties when necessary pursuant to regulatory obligations: We may disclose your Personal Data with third parties to comply with court orders or other legal obligations (such as with other organizations for fraud prevention and detection).
We do not sell Personal Data to anyone and only share it with third parties in accordance with all applicable laws.
6. Transfers outside the European Economic Area
The Personal Data transferred may also be processed in a country outside the UK and the European Economic Area (the “EEA”), which covers the EU Member States, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of Personal Data protection as EEA countries.
If your Personal Data is transferred outside the EEA, we will put suitable safeguards in place to ensure that such transfers are carried out in compliance with the applicable data protection rules. These include, for instance, relying on adequacy decisions or standard contractual clauses issued by the European Commission together with binding and enforceable commitments by the recipient.
You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.
7. Data subject rights
Subject to applicable laws, you are entitled to a number of rights over the processing of your Personal Data. You may exercise these rights at any point by contacting us by email at dataprotection@sugarhouseisland.com or by post to Vastint UK Services Ltd, 135 High Street, London E15 2RB, marked for the attention of the Legal Counsel.
We will consider all such requests and, in accordance with the applicable laws, will provide our response within a reasonable period, or within the period prescribed by law. We may request you to provide us with information necessary to confirm your identity before responding to any request you make.
You have the following rights:
- The right to access: subject to exceptions, you have the right to request access to the Personal Data we hold about you;
- The right to rectification: if the Personal Data we hold is inaccurate you are entitled to have it updated or rectified;
- The right to deletion: subject to exceptions, you can ask us to delete your Personal Data. Please note that if you ask us not to contact you by email at a certain email address, we will retain a copy of that email address on our “master do not send” list in order to comply with your no-contact request;
- The right to object: under certain circumstances, you have the right to ask us to stop processing your Personal Data. For example, you may object to processing for direct marketing activities (for example, by clicking on the unsubscribe link in our emails), and where we are relying on ours or a third party’s legitimate interests to process the Personal Data (unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data);
- The right to withdraw consent: where we rely on your consent to process Personal Data, you have the right to withdraw consent at any time;
- The right to restriction of processing: under certain circumstances you have the right to restrict the processing of your Personal Data such as if you believe (i) the Personal Data we have about you is accurate; (ii) the Personal Data is not being processed lawfully, but instead of deleting the Personal Data, you would prefer us to restrict processing instead; or (iii) we no longer need your Personal Data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims;
- The right to data portability: under certain circumstances you have the right to obtain Personal Data you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice; and
- The right to lodge a complaint with a supervisory authority: you also have the right to file a complaint with the Information Commissioner’s Office in the UK. Their contact details are given below in section 11.
We will consider and act upon any request based on the abovementioned rights in accordance the applicable data protection rules. In response to a request, we may ask you to verify your identity by, for instance, providing additional information. Whenever reasonably possible and required under applicable laws, we will strive to respond to your requests within one month. If we do not comply with your request within such time frame, we will explain why.
8. How do we protect Personal Data?
We have implemented adequate technical and organizational measures to safeguard the Personal Data we process. We update and test our security technology on an ongoing basis. In addition, we restrict access to your Personal Data to employees on a need-to-know basis and train all staff about the importance of confidentiality and maintaining the privacy and security of your information.
9. How long do we keep and store your Personal Data?
We will not retain your Personal Data longer than necessary in relation to the purposes for which the data are processed. In principle, we will retain your data for a maximum of two years after the end of your customer relationship with us, unless we are required by statutory obligations to retain your Personal Data for a longer period of time. We may retain your Personal Data for a longer period in the event of complaints or disputes to the extent that this is necessary to protect our interests and/or the interests.
10. Changes to this Privacy Notice
We may change this Privacy Notice from time to time by posting the updated version of the Privacy Notice on our Website. The “effective date” at the top of this Privacy Notice indicates when it was last updated. We encourage you to visit frequently to stay informed about how we use your Personal Data.
11. Questions, concerns or complaints
To ask questions or comment about our Privacy Notice and our privacy practices, you can contact us at dataprotection@sugarhouseisland.com. You can also contact our Group Data Protection Officer, Johan Martens, at johan.martens@vastint.eu.
You also have the right to raise a complaint with the UK Information Commissioner’s Office. Their contact details are:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
12. Cookie Notice
Please refer to our Cookie Notice for more information on our use of cookies with this Website.