Privacy Policy and Cookie Policy
Background:
Vastint UK Services Ltd, its parent company Vastint UK B.V. and its subsidiary Vastint UK Residential Ltd all understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our Site and will only collect and use information in a manner consistent with your rights and our obligations under the law.
This Policy applies to our use of any and all data collected by us in relation to your use of our Site. Please read this Privacy Policy and Cookie Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy and Cookie Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy and Cookie Policy, you must stop using our Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie”
means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 10, below;
“Site”
means this website, www.sugarhouseisland.com and websites which automatically forward to it, which include www.sugarhouseisland.london, www.sugarhouseisland.co.uk, www.sugarhouseisland.uk and www.sugarhouse.london.
“UK and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended; and
“we/us/our”
means (1) Vastint UK Services Limited, a limited company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB; (2) Vastint UK Residential Limited, a company registered in England under company number 12413617, of the same registered address as (1); and (3) 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.
2. Information About Us
Our Site is owned and operated by (1) Vastint UK Services Limited, a limited company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB and whose VAT number is GB102 3822 62. Our Site is also operated on behalf of, and contains content belonging to: (2) our subsidiary Vastint UK Residential Limited, a company registered in England under company number 12413617, whose registered address is 135 High Street, London E15 2RB; and (3) our parent company 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.
3. Scope – What Does This Policy Cover?
This Policy applies only to your use of our Site. It does not extend to any websites that are linked to from our Site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Our Site also contains contact details for third parties that we use to provide services in relation to our development, such as sales and lettings agents (as listed on the Contact Us page), so that you can directly contact those third parties if you would like to. If you choose to contact those third parties directly and in doing so provide them with any personal data, the use of your data by those third parties will be determined by their own privacy policies, details of which they should supply to you. This Policy does not apply to any data you choose to supply direct to any third parties.
4. What Data Do We Collect?
Some data will be collected automatically by our Site (for further details, please see section 10 on our use of Cookies), other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5, for example, when signing up for our newsletter. Depending upon your use of our Site, we or others (via a third party Cookie – see section 10) may collect some or all of the following data:
4.1 your email address;
4.2 your first name and last name;
4.3 your phone number;
4.4 other personal information you have chosen to give us in an email you have sent to us or other communication you have had with us;
4.5 IP Address (automatically collected);
4.6 Screen size (automatically collected);
4.7 Geo location (automatically collected);
4.8 Language (automatically collected);
4.9 Device type (automatically collected);
4.10 Operating system (automatically collected);
4.11 Browser (automatically collected);
4.11 Pages visited (automatically collected); and/or
4.12 Referring websites and other websites visited (automatically collected).
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and other relevant legislation in the UK including the Data Protection Act 2018 (DPA) (together, the Data Protection Legislation). For more details on security see section 6, below.
5.2 We use your data to provide the best possible service to you. This includes:
5.2.1 Responding to communications from you and supplying you with information you have requested;
5.2.2 Supplying you with information by email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the link given in the email); and
5.2.3 Collecting information about how visitors use our Site. We use the information to compile reports and to help us improve our Site.
5.3 If you give us your consent to do so, we and/or our agents may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on our development.
5.4 We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Legislation and relevant legislation on marketing by email or phone. If you choose to subscribe to a particular service, such as a newsletter, we will only use your data to provide that service and will not use your data to send more general marketing communications.
5.5 Under the Data Protection Legislation we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one lawful basis applies.
The bases we currently use to process personal data are as follows:
(a) In relation to data which is collected automatically when you access the Site, processing is necessary for the purposes of the legitimate interests pursued by us i.e. to maintain, secure and optimise the Site;
(b) In relation to data collected via Cookies, your consent is given to processing that data via the Cookie pop-up which appears when you access the Site (unless you do not accept Cookies when prompted); and
(c) In relation to data you give by filling out our website contact form, your consent is given to processing that data by ticking the relevant box in the contact form.
How and Where Do We Store Your Data?
6.1 We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
6.2 Some or all of your data may be stored or transferred outside of the UK or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein), where it is transferred to third parties based outside the EEA, as described in section 7. If we do store or transfer data outside the UK and/or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and/or EEA and under the Data Protection Legislation.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Site.
6.4 Steps we take to secure and protect your data include:
6.4.1 Limiting access to your data strictly to those personnel who need to use it for the purposes of their role;
6.4.2 Using password protected access to systems where your data may be held;
6.4.3 Limiting or preventing use of printed or other insecure copies (e.g. copies on USB sticks) of documents containing personal data; and
6.4.4 Ensuring any third parties who have access to your data are contractually obliged to have secure systems and processes in place and to comply with their legal obligations in relation to personal data (see section 7 for further information.)
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in our group. This includes our holding company, Vastint Holding B.V., and its subsidiaries.
7.2 We may from time to time contract with third parties to supply services to you on our behalf. These may include search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. Some of these third parties are based outside the UK and/or EEA. In these cases, we will act as described in section 6.2 above.
7.3 As at the date of this Policy, we contract with The Rocket Science Group LLP (also known as “MailChimp”) which provides an email distribution service to our subscribers. When you submit your email address and/or phone number via our Site, your details are shared with MailChimp. MailChimp is based outside the EEA. Further details of how MailChimp complies with its obligations under the GDPR are available here: https://mailchimp.com/legal/privacy/
7.4 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, referring sites and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates and partners. Data will only be shared and used within the bounds of the law.
7.5 In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
8. What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the data for the purposes for which it was originally collected by us.
9. Understanding, Controlling and Accessing Your Data
Summary of your rights under the Data Protection Legislation
Under the Data Protection Legislation, you have:
9.1 the right to request access to, deletion of or correction of, your personal data held by us;
9.2 the right to complain to a supervisory authority;
9.3 the right to be informed of what data processing is taking place;
9.4 the right to restrict processing;
9.5 the right to data portability;
9.6 the right to object to processing of your personal data;
9.7 rights with respect to automated decision-making and profiling (these are not applicable to our use of your personal data – see section 11 below).
To enforce any of the foregoing rights or if you have any other questions about our Site or this Policy, please contact us using the details set out in section 12 below.
Controlling your data
9.8 We aim to give you strong controls on our use of your data. This includes the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails. You may also contact us to make corrections if you believe any of the data we hold about you is inaccurate. Our contact details are set out in section 12.
9.9 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given
9.10 Some data is collected automatically when you visit our Site. You may be able to restrict collection of some data by restricting your internet browser’s use of Cookies. For more information, see section 10.
9.11 You may withdraw your consent for us to use your personal data as set out in section 5 at any time by contacting us using the details set out in section 12, and we will delete your data from our systems.
Accessing Your Data
9.12 You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us using the contact details below in section 12.
10. What Cookies Do We Use and What For?
10.1 We use “analytics” cookies which, in conjunction with our web server’s log files, allow us to analyse information such as the number of people visiting our Site, which parts of our Site are most popular and which sites visitors go to before and after our Site. This helps us gather feedback so that we can improve our Site and our services and use more carefully targeted advertising.
10.2 We also use “social media” cookies to personalise your interaction with third party social media platforms such as Twitter and Facebook where our Site uses such features. Such cookies recognise users of these social media sites when you view social media content on our Site. They also allow you to quickly share content across media, through the use of “sharing” buttons. They also track and analyse your usage of our Site and other sites and use this data to provide targeted advertising that is relevant to your interests.
10.3 We also use third parties to distribute newsletters and email campaigns to subscribers (MailChimp) and to provide embedded video content on our Site (Vimeo). These third parties use cookies to track and analyse how you are using their services and to provide targeted advertising that is relevant to your interests.
10.4 You can find more information about the individual cookies we use and the purposes for which we (or the relevant third parties) use them in the table below:
Cookie owner / Purpose / Further Information
Google Analytics
To store and analyse information such as the time you visit our Site, whether you have visited before and the websites that you visit prior to and after visiting our Site.
https://support.google.com/analytics/answer/6004245
For user authentication, security, customisation of services and features, targeted advertising, analytics and research.
https://help.twitter.com/en/rules-and-policies/twitter-cookies#
For user authentication, security, customisation of services and features, targeted advertising, analytics and research.
https://www.facebook.com/policies/cookies/
For user authentication, security, customisation of services and features, targeted advertising, analytics and research.
https://www.instagram.com/legal/cookies/
MailChimp
Tracking and analysis of email campaigns sent to subscribers, targeted advertising
https://mailchimp.com/legal/cookies/
Vimeo
In relation to any video content on our Site – user authentication, customisation of features, and targeted advertising
https://vimeo.com/cookie_policy
Google Maps
Providing, maintaining, improving and developing new services, providing customised content including adverts, analysing and measuring performance, maintaining safety and reliability of services.
https://policies.google.com/privacy?hl=en-US
10.5 All Cookies used by and on our Site are used in accordance with current UK and EU Cookie Law.
10.6 Before Cookies are placed on your computer or device, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. You can choose to enable or disable Cookies in your internet browser. Limited data may be collected automatically even if you enable or disable Cookies.
10.7 Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. Some third party cookies can also be individually disabled by following the instructions given in the relevant link in the table in 10.4 above.
10.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. Automated Decision-Making and Profiling
We do not currently use personal data for the purposes of automated decision-making or for profiling. If this changes, we will let you know.
12. Contacting Us
If you have any questions about our use of your data or this Policy, please contact us by email at dataprotection@sugarhouseisland.com, by telephone on 020 3384 7900, or by post at Vastint UK Services Ltd, 135 High Street, London E15 2RB marked for the attention of the Legal Counsel. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
13. Changes to Our Policy
We may change this Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Policy on your first use of our Site following the alterations. If you have submitted your contact details to us, we will notify you of any significant changes to this Policy which may affect how your data is used or which may otherwise have a significant impact on you. We will not notify you directly of minor changes but we recommend that you check this page regularly to keep up-to-date.
This Policy was last updated in August 2020.
