WEBSITE PRIVACY NOTICE
Longmartin is committed to protecting the privacy and security of your personal data.
This privacy notice (“Notice”) describes how we collect and use personal data in accordance with the General
Data Protection Regulation (“GDPR”).
1. SCOPE
This Notice is given by Longmartin Properties Limited on behalf of itself and its subsidiaries. We act as a data
controller for the personal data we collect during the course of our engagement with you.
This means that we determine the purposes for and manner in which we (or our processors) process your
personal data.
Our registered office at Regal House, 14 James Street, London, WC2E 8BU. We can be contacted by post at
this address or by email at feedback@shaftesburycapital.com. Please mark any correspondence for the
attention of the Company Secretary.
2. AUDIENCE
This Notice relates to range of data processing activities undertaken by Longmartin. To help you navigate this
Notice we have extracted the key information applicable to you depending on the nature of your relationship
with us. Please click on the below tabs to access the relevant summary. Full details of our processing are set
out in the rest of the Notice.
If you are residential tenant (either on the basis of an AST or long lease), or a guarantor of any such
residential tenancy, please refer to the standalone privacy notice specific to your situation. You will have
been provided with a copy of the privacy notice relevant to you via your letting agent or Longmartin contact,
but if you’d like another copy of the Residential Tenant Privacy Notice then please contact the relevant
letting agent, or Longmartin contact.
A. Business and general correspondents
We may collect your personal data if you contact Longmartin by email, post, telephone or otherwise in
connection with any business or general matter, in order to maintain a general business relationship with
you.
The information we collect
We will only collect the information you provide to us directly, such as your name and contact details or
other details you might provide when corresponding with us.
Who we share the information with
Depending on the correspondence we have with you, we may share your information with businesses that
provide us with services necessary in relation to what you have requested.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We have a legitimate interest to process your personal data in order to maintain normal business operations
and to fulfil the request you’ve made through your correspondence with us.
Automated decisions we make about you
We do not make any automated decisions using this information.
B. Website visitors
As a visitor to our website, we will collect information related to you as required for our website to operate,
as well as giving you the opportunity to subscribe for our newsletters or alerts.
The information we collect
If you chose to sign up for the newsletters, or alerts from our websites, we will collect and store your name,
email address and ask you to confirm if you are aged over 18. We use this information to provide the service
you requested.
You are able to unsubscribe from the news and information service at any time and/or “opt out” of receiving
communications by clicking the unsubscribe link in any email you are sent from us. If you unsubscribe from
the services, we will not retain the data you submitted when you subscribed for the service and will cease
sending you news and information. Further, you can contact info@theyardscoventgarden.co.uk at any time.
We collect your personal data to respond to any requests which you have submitted via our website and to
deal with ongoing matters relating to such requests.
Technical Information
We use cookies on our website to gather and record on our servers certain information about all users who
visit the website, including without limitation, IP address, time zone setting and location, interaction with our
website browser type and version, browser plug-in types and versions, operating system and platform and
other technology on the devices you use to access this website. We may also receive technical data about
you from analytics providers such as Google (for example, standard internet log information and details of
visitor behaviour patterns). We do this to find out such things as the number of visitors to the various parts of
the site. This information is only processed in a way that does not directly identify anyone. We do not make,
and do not allow Google to make, any attempt to find out the identities of those visiting our website.
At any time, you can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of this website may
become inaccessible or not function properly. For further information on this, please see our Cookie Policy.
The information we collect about your use of the website will be used to report on visitor numbers,
administer and protect our business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data) to improve our website, services, and consumer
experiences.
We also collect, use and share aggregated data such as statistical or demographic data (Aggregated Data) for
limited purposes. For example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this privacy notice.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform
their services to us. This will be our website providers.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party websites and we are not responsible for their privacy statements. When you leave our
website, we encourage you to read the privacy notice of every website you visit.
Please note that Longmartin does not warrant, represent, endorse or hold responsibility over any external
sites that may be linked to and from this site.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
Where you have agreed to provide us with your data to receive the email alerts and newsletters, then you
have consented to us processing that information.
We have a legitimate interest in administering, protecting and improving our website.
Our use of cookies is subject to consent – please see our Cookie Policy.
Automated decisions we make about you
We do not make any automated decisions using this information.
C. Visitors to our buildings or properties
We store and use your information for the purposes of managing and operating our buildings.
The information we collect
If you are visiting either our head office, or our office at 22 Ganton Street, Carnaby, W1F 7FD, we may collect
personal data where necessary for security, administration and safety purposes – this may include collecting
personal and contact details, as well as dietary, health or accident information. Further, we have a guest WiFi
network for visitors to access, however no personal data is collected by us in relation to this.
When visiting our properties, we operate CCTV for the purposes of detecting and preventing crime and
general estate management. We may also receive information from law enforcement agencies if criminal
activity is alleged or suspected in the publicly accessible areas of our portfolio. Our CCTV feeds provide a 24/7
live feed, which is retained for 31 days, unless we are aware of a particular incident, where the footage may
be kept for longer to share with law enforcement agencies (see section 8 for further information on why we
might share your personal data).
We may also take photographs or videos of within a property or public space, in which case we may capture
the image of visitors. Where we take specific or close up images of individuals (for example, as part of our
social media or website images), we will always seek your consent.
As part of the management of our portfolio, we also collect aggregated footfall and visitation data across our
portfolio. No personal data is collected through this.
Who we share the information with
We share the information we collect with the following third parties:
– Our suppliers to the extent necessary to perform their services to us;
– Where access control information or fire evacuation information is required to be shared with an
occupier;
– Where the information relates to health and safety incidents, security events or any matter giving
rise to an insurance claim or relevant to our insurance coverage, our lawyers, insurance brokers and
other professional advisors; and
– When requested to do so by relevant authorities such as the police, in the event of criminal conduct.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
We have a legitimate interest in wishing to interact with you in order to manage and operate effectively our
buildings and our portfolio and ensure that these are safe and secure. The processing we undertake is limited
and concentrates on the use of the building.
In some instances, for example health and safety, we are required by law to hold certain records to comply
with this obligation.
Automated decisions we make about you
We do not make any automated decisions using this information.
D. Social media followers and competition entrants
We have active social media accounts for The Yards, including on Facebook, Instagram and Twitter. These
social media accounts are used to answer any enquiries received from followers, reshare photos tagged to
our account and to promote our portfolio.
These social media accounts may periodically run competitions.
The information we collect
By contacting or interacting with us through our social media accounts, you share with us your details on
your social media account, which can include your social media username/handle, public profile, public posts,
and any personal information included as part of your enquiry such as your name, email address, place of
work and job title.
Where you have entered into a competition or prize draw, terms and conditions will apply for an entrant to
sign up to, and in some cases we may also require proof that you are over the age of 21.
If you are successful in a competition or prize draw, we will contact you directly on social media to engage
with you on how to collect or redeem your prize. In this instance, we may require your mobile number or
home address.
We retain your information for as long as needed for you to claim or redeem your prize, after which it is
deleted.
Who we share the information with
We only share the information we collect with our suppliers to the extent necessary for them to perform
their services to us. In this instance the main suppliers will be our marketing agents.
Please see section 8 below for additional circumstances where we may disclose your data.
Legal basis for processing
When you enter into the competition, you are accepting our competition terms and conditions, meaning that
we are under a contractual obligation with you to process your data for the duration of the competition.
When you contact us through our social media channels, we have a legitimate interest in responding to your
query.
Automated decisions we make about you
We may sometimes make automated decisions in relation to specific competitions that you enter – for
example, to automatically select a winner. Where this is the case, further detail in relation to automated
decision marking will be set out in the information provided to you when you sign up for the relevant
competition.
3. WHAT THIS PRIVACY NOTICE COVERS
3.1. This Notice covers:
a) what personal data we collect about you;
b) how we collect personal data;
c) why we process personal data;
d) the transfer of any personal data outside the UK and/or the EEA;
e) when we may disclose your personal data;
f) protecting your personal data;
g) your rights in connection with the personal data we collect;
h) how long we hold your personal data for;
i) how we update or change this notice; and
j) how you can contact us.
3.2. We issue other privacy notices (alongside this Notice) which relate to specific situations relationships –
please refer to the following notices where applicable:
a) Residential Tenant Privacy Notice – please see reference above
4. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
4.1. The types of personal data which we collect about you will vary according to the nature of your
relationship with us. Please see the relevant section at part 2 of this notice. We may also process other
categories of personal data from time to time, as specifically notified or as may reasonably be
anticipated as part of the operation of our business and the management of our property portfolio.
4.2. Under the GDPR certain types of information are considered to be more sensitive and so in need of
more protection. These “special categories of personal data” are information about your race, ethnic
origin, political opinions, religion, trade union membership, genetics, biometrics (where used for ID
purposes), health, sex life, or sexual orientation, and may also include information relating to criminal
convictions and allegations. Where you provide us with this information, we are required to establish
an additional lawful basis for holding this information, which will usually be your explicit consent or our
compliance with a legal or regulatory obligation. We may process such information in the following
circumstances:
a) As a visitor to our premises, we may process health related information such dietary
requirements and accident details.
b) In very rare instances we will process special categories of personal data in order to prevent or
detect unlawful acts in connection with a tenancy or on publicly accessible areas of our
portfolio (e.g. fraud or antisocial behaviour), which in some circumstances will involve
disclosures to the police or other regulatory/legal authorities.
4.3. 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 the course of your tenancy.
5. HOW WE COLLECT YOUR PERSONAL DATA
5.1. The way in which we collect your personal data will vary according to the nature of your relationship
with us. Please see the relevant section at part 2 of this notice. We may also collect personal data from
other sources from time to time, as specifically notified or as may reasonably be anticipated as part of
the operation of our business and the management of our property portfolio.
6. WHY WE PROCESS PERSONAL DATA
6.1. The personal data we collect and process will vary according to the nature of your relationship with us.
Please see the relevant section at part 2 of this notice.
6.2. We may also process personal data for the following purposes:
a) internal business and regulatory requirements, including valuation of the property portfolio in
line with accounting standards, undertaking audits, archiving etc;
b) exercising and/or defending our legal rights,
c) We may also process personal data for other purposes from time to time, as specifically notified
or as may reasonably be anticipated as part of the operation of our business and the
management of our property portfolio.
6.3. Whenever we process your personal data we do so on the basis of a lawful condition of processing. The
applicable legal basis will vary according to the nature of your relationship with us. Please see the
relevant section at part 2 of this notice. In addition, we may also undertake processing: where
necessary for compliance with a legal obligation to which Longmartin is subject (for example,
undertaking mandatory background checks or to comply with court orders); where you provide your
consent to the processing of your personal data for certain specific purposes, including where based on additional information made available at the time consent is provided; where we need to protect the
vital interests for you or someone else, or where it is necessary to do so in the public interest; and in
other circumstances where necessary for our legitimate interests (or those of a third party).
6.4. Where we process your personal data as necessary for our legitimate interests (or those of a third
party), we do so only provided it is always carried out in a way that is proportionate and respects your
privacy rights.
6.5. The special categories of personal data that may be processed by Longmartin are set out in paragraph
4.2 of this Data Privacy Notice. Where we process special categories of data it will be justified by a
condition set out at paragraph 5.2 above and also by one of the following additional conditions:
a) based on your explicit consent;
b) in accordance with paragraph 10 of Schedule 1 of the UK’s Data Protection Act 2018 – for
example where we seek to prevent or detect unlawful acts (e.g. fraud or antisocial behaviour);
c) where necessary to protect the vital interests for you or someone else where you are physically
or legally incapable of giving consent (for example in exceptional emergency situations, such as
a medical emergency) , or where it is necessary to do in the public interest; or
d) the processing is otherwise permitted by law, such as in relation to legal claims.
6.6. We will only use your personal data for the purpose for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
6.7. Please note that we may process your personal data without your knowledge, in compliance with the
above rules, where this is required or permitted by law.
7. TRANSFERS OUTSIDE OF THE UK OR THE EEA
7.1. Several of our external third parties are based outside the UK and/or the European Economic Area
(“EEA”) so their processing of your personal data will involve a transfer of data outside the UK and/or
EEA.
7.2. Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of
protection is afforded to it by ensuring appropriate safeguards have been implemented. If you would
like further information on the specific safeguards used by us when transferring your personal data
out of the UK and/or EEA, please contact the Company Secretary.
8. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
8.1. The ways in which we disclose your personal data will vary according to the nature of your relationship
with us. Please see the relevant section at part 2 of this notice. In addition, we may also disclose your
personal data to the following recipients:
a) to service providers, agents and advisors appointed by us (e.g. such as our managing agents,
letting agents, solicitors, auditors, credit reference agencies, IT providers and other processors);
b) to a prospective buyer in the event of a sale, merger or restructuring of any part of our
business;
c) to any company within the Longmartin group of companies; or
d) to any regulatory agency or enforcement body or court where we reasonably believe that we
are required to do so by applicable law or regulation or by any court order or at their request
where it is legal to do so.
9. PROTECTING YOUR PERSONAL DATA
9.1. We have put in place technical and organisational measures to protect the security of your
information. Third parties will only process your personal data on our instructions and where they have
agreed to treat the information confidentially and to keep it secure.
9.2. 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.
10. YOUR RIGHTS IN CONNECTION WITH THE PERSONAL DATA WE COLLECT
10.1. Under certain circumstances, you have rights under data protection laws in relation to your personal
data. The rights available to you depend on our reason for processing your information.
10.2. You have the right to request from us access to and rectification or erasure of personal data or to
restriction of processing concerning you or to object to our processing of the data as well as the right
to data portability.
10.3. If we are relying on your consent to process data (for example you have requested further information
from us or marketing materials), you may withdraw your consent at any time by notice to us.
10.4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with the request in these circumstances.
10.5. We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your request to speed up our
response.
10.6. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than
a month if your request is particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.
11. HOW LONG WE HOLD YOUR PERSONAL DATA FOR
11.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements including applicable statutory
limitation periods.
11.2. In some circumstances we may anonymise your personal data so that it can no longer be associated
with you, in which case we may use such information without further notice to you. Once you are no
longer a tenant, we will retain and securely destroy your personal data in accordance with our data
retention policy, although we will retain the signed original agreement and supporting documentation
indefinitely.
12. HOW WE UPDATE OR CHANGE THIS NOTICE
12.1. We reserve the right to update this privacy notice at any time and we will make the revised privacy
notice publicly available. We may also notify you in other ways from time to time about the processing
of your personal data.
12.2. This notice was last updated on 6 March 2023.
13. HOW YOU CAN CONTACT US
13.1. If you want to review, verify, correct or request erasure of your personal data, object to the processing
of your personal data, or request that we transfer a copy of your personal data to another party, please
contact the Company Secretary.
13.2. If you have any questions about this privacy notice, please contact the Company Secretary, either by
post at Longmartin Properties Limited, Regal House, 14 James Street, London, WC2E 8BU or by email at
feedback@shaftesburycapital.com
13.3. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the
UK supervisory authority for data protection issues.
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We are Longmartin Properties Ltd (for further details about us please see our Privacy Statement). We take the privacy of visitors to this website very seriously. The purpose of this cookie policy is to inform you about the types of cookies we use on this website. This cookie policy is effective from October 2015. We may change it from time to time by updating this page so please revisit and reread it periodically. This site uses cookies in order to perform certain functions. On your first visit to our home page a banner appeared to make it clear that this website uses cookies and to direct you towards this cookie policy. It was explained to you on that first visit that by continuing to browse the site you would be agreeing to our use of cookies. This means that by using our website, you are deemed to be giving your consent to our use of the cookies described in this cookie policy for the purposes described. You can refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. You can also delete or block cookies at any time by altering the browser settings on your machine or other device. Further details below. A cookie is a small piece of data sent by our server to your computer or to the other device you are using to access our website e.g. smartphone, so that information can be recalled. A cookie is stored by your web browser in a text file on your computer or other device. Each time your web browser requests content from a server that has previously interacted with your machine or other device, the cookie’s message is sent back to our server. Cookies relating to this website are passive and just used for collecting and transferring that anonymous information. By this we mean that no cookie set while on this site will capture any personal data about you (or be used in any malicious fashion whatsoever). Personal data is referred to in more detail in our Privacy Statement. Two types of cookies may be used on this website; “session cookies”, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and “persistent cookies”, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). These are referred to in more detail in the table below. To learn more about cookies please visit http://www.allaboutcookies.org/ The purpose for which we use analytical/performance cookies is as follows. We use them to collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. Identifying how visitors arrive at our site and the path they take through it to help us to improve our service to you. We use third party tools to monitor and analyse traffic to, from and within our website. In addition, we use strictly necessary cookies in order for the website to function properly. Below is a summary of the types of cookie that may be set or read while your machine or other device is used to access this site, their function, and the issuer setting this cookie:
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