Picton is committed to protecting your personal data and your rights in line with privacy legislation.
This Privacy Notice explains how personal information about you (for example, our occupiers, website visitors and members of the public) is used by us.
Picton Property Income Limited (‘Picton’, ‘we’ or ‘us’) is the Data Controller of the personal data that you (‘you’ means the person whose data is being processed) provide to us.
WHAT INFORMATION WE COLLECT
We may process your personal information (information that identifies you as an individual and relates to you) in order to provide the service you have asked for.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data - includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
- Contact Data - includes address, email address and telephone numbers
- Financial Data – includes bank account details
- Technical Data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser
- Plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Usage Data - includes information about how you use our website and services and from CCTV and access controls in our properties
- Marketing and Communication Data - includes your preferences in receiving marketing from us and our service providers and your communication preferences
HOW DO WE COLLECT YOUR PERSONAL INFORMATION
Picton collects information from individuals through use of our website, website sign ups (for example, registering for email alerts) and when individuals contact us directly.
We use different methods to collect data from and about you including:
- Direct interactions. You may give us your identity, Contact and Marketing and Communications Data by registering on our website or by
- Corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Request information to be sent to you;
- Register for alerts; or
- Gives us some feedback or other information
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Cookies are used us to improve your experience when using our website and to track usage (for example what pages are being viewed) to help us understand how the site is being used. We do not use personal information in the cookies and do not track you personally, only the computer you are using. These can be session cookies which are deleted when you close your browser and/or persistent cookies which remain on your computer for a longer period of time.
To delete or stop cookies being placed on your computer refer to the help menu on your internet browser. In a few cases blocking cookies may reduce the functionality of our sites or prevent access to them depending on your chosen browser options.
We do not process any special categories of personal information (for example, data relating to health, race, ethnicity, politics, trade union membership, sex life, sexual orientation, genetics, biometrics).
HOW WE USE YOUR DATA
We only process your information where it is fair and lawful to do so. We use your personal information for several purposes and we have defined the legal grounds for doing so:
- Legitimate interests – such as to communicate with you; for web analytics so we can provide, improve and tailor services directly to you; to provide appropriate technical support and security for our websites; or for fraud protection;
- With your consent – such as agreeing to receive email alerts:
- To perform our obligations under contract with you – such as invoicing;
- To comply with a legal obligation – such as health and safety legislation, or for taxation purposes
- When in someone’s vital interests – such as preventing someone being seriously harmed;
If we need to use your personal information for a different, unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.
We use Google Analytics to collect internet log information and the behaviour patterns of visitors to the website, to monitor which parts of the website get visited. This information is processed in a way that does not identify you or anyone else.
For information on the reasons and the conditions for processing, please contact the Data Protection Officer at firstname.lastname@example.org.
WHO DO WE SHARE DATA WITH
We may share your personal information with third party organisations which includes members of Group. We may also disclose your personal information to other third parties, such as;
- Third party service providers who act for us – for example, the processors that manages websites; send out email alerts; or manage our IT network. Where we share your information, it is always carried out under our instructions as detailed in writing, or as required by law, and is never for any marketing approaches by them. We ensure that they store the data securely and delete it when it is no longer needed.
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Picton or substantially all of its assets are acquired by a third party, in which case personal data held by it about its occupiers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
Our websites may, from time to time, contain links to and from the websites of our partners and affiliates, such as property agents. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
TRANSFER OF DATA
The personal information you provide to us may be transferred and stored outside of the EEA. Third parties will only process your personal information on our instructions and subject to an agreement that the information is kept secure and confidential.
Any personal information transferred will receive an adequate level of protection as required by the Data Protection laws. We will ensure that appropriate safeguards are in place prior to any transfer of your data.
HOW WE KEEP YOUR DATA SECURE
We understand the importance of protecting your privacy and we will ensure your personal information, both on- and off-line, is safeguarded and held securely in accordance with our obligations under the Data Protection laws. Appropriate technical and organisational measures have been implemented to ensure personal information is protected and to prevent your personal data from being lost, used, accessed in an unauthorised way, altered or disclosed.
However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Personal data will be retained for no longer than is necessary to comply with statutory guidance or to provide services to you as required.
YOUR RIGHTS AND ACCESS TO YOUR DATA
Under data protection legislation, you have the right to request access to information about you that we hold (this is called a Data Subject Access Request or DSAR). To make a request for your personal information, contact the Data Protection Officer.
You also have the right to:
- Ask us to correct your information if it is incorrect;
- Ask us to delete the information that we hold about you in certain circumstances, for example, where we no longer need the information;
- Opt-out of us processing your personal information for marketing purposes’
- Ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer;
- Restrict certain processing of your information, for example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy;
If you wish to discuss any of these rights, to make any changes to the personal information we process about you, or, if have a concern about the way we are collecting or using your personal data, please speak to the Data Protection Officer.
CHANGES TO THIS POLICY
If you are in any way dissatisfied about how we process your personal information, you have a right to make a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. This can be done at https://ico.org.uk/concerns/