GENERAL

Spectra Real Estate Limited (“Spectra”), together with any group companies (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, weare the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully.

VISITORS TO OUR WEBSITE

• We may collect and process personal data about you in the following circumstances:
  • whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
  • details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (see section 2.2.2 on Cookies below); and
  • whenever you disclose your information to us, or we collect information from you in any other way, through our Site.
• We may collect and process personal data about you in the following circumstances:

IP Address

We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

• Cookies
  Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

• We may use your personal data for our legitimate interests in order to:
  • provide you with information or services that you requested from us;
  • ensure that content from our Site is presented in the most effective manner for you and for your device;
• improve our Site and services;
  • process and deal with any complaints or enquiries made by you; and
  • contact you for marketing purposes where you have signed up for these (see section 6 for further details).

CLIENTS

• In order to provide our services to you we need to collect your personal information such as your name, contact details, address and financial information. We will use this information in order to fulfil our contractual obligations, comply with legal obligations or for our legitimate business interests.
• In order to perform our contact with you, we may also need to share personal data with third parties. Please see section 9 below for more details.
• We will retain your information as long as we require this to provide you with our services and then for an appropriate period of time thereafter. The subsequent period of time will be determined by the nature of the services we provide to you and our legal obligations in this regard. In any event we will retain your personal information for a minimum period of seven years.

SUPPLIERS

We will collect details such as key contacts names, email address and telephone in order to contact you about goods or services we’ve ordered from you, to place further orders and to pay you for the goods or services you’ve supplied. We will keep the personal data for a minimum period of seven years further to being provided with the goods or services.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

MONITORING AND RECORDING

We monitor and record communications with you(such as telephone communications and emails) for the purpose of fraudprevention and compliance with our legal or regulatory obligations. We retainsuch information for a period of seven (7) years.

AUTOMATED PROCESSING

We do not undertake automated decision making with your personal data.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• or performance of a contract we enter into with you;
• where necessary for compliance with a legal orregulatory obligation we are subject to; and
• for our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.

DISCLOSURE OF PERSONAL DATA to third parties

• In addition to thethird parties mentioned above, we may disclose your information to third parties for our legitimate interests as follows:
  • to staff members in order to facilitate the provision of services to you;
  • to our affiliated entities to support internal administration;
  • outsourced service providers, including by not limited to payroll and pensions services;
  • IT software providers that host our website and store data on our behalf;
  • Professional advisers including consultants, lawyers, bankers and insurers who provide uswith consultancy, banking, legal, insurance and accounting services; and
  • HM Revenue and Customs, the Financial Conduct Authority and other relevant regulators and authorities who require reporting of processing activities in certain circumstances.
• We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our
  website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• We will not sellor distribute personal data to other organisations without your approval.

DATA SECURITY

• Unfortunately, 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 information transmitted to our Site; any transmission is at your own risk.
• Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

ACCESS TO, UPDATING, DELETING AND RESTRICTINGUSE OF PERSONAL DATA

• It is important that the personal data we hold about you is accurate and current.  Please keep us informed if the personal data we hold about you changes.  
• Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing ofyour personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to enquires@spectras.co.uk. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
• You can also ask us to undertake the following:
  • update or amend your personal data if you feel this is inaccurate;
  • remove your personal data from our database entirely;
    • send you copies of your personal data in a commonly used format and transfer your information to another entity; or
    • restrict the use of your personal data.
  • We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or requireus to refuse to provide you with access to some or all the personal data thatwe hold about you or to comply with any requests made in accordance with you rrights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
  • Please send any requests relating to the above to our Data Lead, Julia Summersat jsummers@spectras.co.uk, telephone (0044) (0)20 7255 6961 specifying your name and the action you would like us to undertake.

RIGHT TO WITHDRAW CONSENT

Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us at enquiries@spectras.co.uk.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. Please check periodically for any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

CONTACT US

We have appointed a Data Lead to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Lead at jsummers@spectras.co.uk, telephone (0044) (0)20 7255 6961. This is in addition to your right tocontact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/.