Privacy Policy

This website is operated and provided by Langham Estate Management Limited, “we“, “us“, “our“) having its registered office at London House, 9A Margaret Street, London, W1W 8RJ. We are a data controller for the purpose of Data Protection Legislation (as defined below).

In this Privacy Policy, references to “You” and “Your” are references to a user of our website, a user of our services, our contacts, suppliers and/or other external parties; and, where You are a corporation, “You” and “Your” includes any of your employees, officers, directors, agents, contractors or consultants or other relevant individuals (“Personnel“).

Introduction

We are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.

This policy (“Privacy Policy“) explains what information we collect from You, or that You provide to us, what we will use it for and with whom we share that information. The policy also sets out Your rights and who You can contact for more information. Please read this policy carefully to understand our practices regarding Your personal data and how we will treat it.

Before providing us with any information you are responsible for ensuring that your Personnel or other relevant individuals are aware of this Privacy Policy and the provisions of such Privacy Policy are clearly communicated to them.

In this Privacy Policy, Your information is sometimes called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing Your personal data as “processing” such personal data.

In this Privacy Policy the term “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.

What information we collect about You

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Privacy Policy.

The personal data we collect and process may include:

Your name;
Your contact information such as Your email address and telephone number (or any telephone number used to call our customer services);
Your IP address, Your browser type and language;
Your payment details / financial data i.e. Your bank name, account number and sort code;
Your image (via CCTV);
information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page;
information we obtain from the services we provide You with or (where You are our supplier) You provide us with, including details of the services we or You receive as applicable; and
information we collect when You, your Personnel or other relevant individuals communicate with us, or when each of we or You apply to receive products or services from the other, or any other time You or your Personnel contact us.

In relation to any processing of special categories of personal information such as information about your health, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

How we collect information about You

Information You give to us when You use our services. If You use our services, including renting office space or meeting rooms, You will need to provide certain information including Your name, address and card number.
Information You give to us when You visit our premises. If You visit our premises, You will need to provide information, including Your name. Your image may also be captured on our CCTV.
Other information You give to us. This is information about You that You give us by filling in forms on our site https://www.langhamestate.com/(“our site“) (e.g. the contact us section) or by corresponding or doing business with us by phone, e-mail or otherwise. It includes information You provide when You register on the site for us to contact You, when You report a problem with our site or when You do business with us. The information You give us may include Your name and e-mail.
Information we collect about You.
Like most websites, we use “cookies” to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They’re small text files that sites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. There are more details in our section on Cookies below.
In addition, with regard to each of Your visits to our site we will automatically collect certain information e.g. Your IP address used to connect Your computer to the Internet.

How we use Your information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience, to provide the services You have requested or to receive services from You. We may also use the information that You have provided to ensure that the content on our website is presented in the most effective manner for You and Your computer.

We use Your information for the following specific purposes:

to administer your account and carry out our obligations arising from any contracts entered into between You (or Your employer) and us and to provide You with the information and services that You request from us;
for our reasonable commercial purposes (including quality control and administration, assisting us to develop new and improved products and services, and administering goods and services provided to us);
to comply with any regulatory or legal requirement on us;
to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to enforce or apply our terms with You and/or any other agreement and to protect our (or others’) property or rights;
to notify You about changes to our service;
to respond to Your queries;
to ensure that content from our site is presented in the most effective manner for You and for Your computer;
to send You information about our offers and other services that may be of interest to You, we may send You newsletters and contact You to let You know about any new services;
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our premises safe and secure; and
to make suggestions and recommendations to You and other users of our site about services that may interest You or them.

Legal grounds for using Your personal information

The law permits us to process Your personal data in the way that we do because the processing is:

necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations to store and disclose information where necessary and to evaluate, develop and improve our services; and/or
necessary for the performance of our agreement to provide You with the services that You require and/or
necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) you have made the data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

Sharing Your information

The following categories of recipients may receive Your personal information and process it for the purposes outlined in this Privacy Policy:

We may disclose data to provide our services or receive services from You, to respond to legal requirements, enforce our policies, and protect our rights and property.
The personal information You provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide You with our services or receive services from You, respond to Your enquiries or for any other related purposes.
We may also share Your personal information with:

- other companies we have instructed to provide services for us;
- other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
- any successor in interest, in the event of a liquidation or administration of Langham Estate Management Limited.

Sharing third party information with us

If any information which You, your Personnel or other relevant individuals provide to us relates to any third party, by providing us with such information You or they confirm that You or they have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with this Privacy Policy, or are otherwise permitted to give us this information on their behalf.

Links to Other Websites

Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once You link to another website from our website You are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before You submit any data to these websites.

How we protect Your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect Your personal details from unauthorised access.

Unfortunately, the transmission of information via the internet (including by email) 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.

How long we keep Your information

We will keep the information we collect about You for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

We may send You direct marketing communications, and retain Your contact information necessary for this purpose, (provided that You have consented to receiving them) for as long as You do not unsubscribe from receiving the same from us.

Transferring data outside of the EEA

Data that You submit via our website is sent to and stored on secure servers owned by or operated for us. Data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our website or to assist in our security activities.

When we, or our permitted third parties, transfer Your information outside the EEA, we or they will impose obligations on the recipients of that data to protect Your information to the standard required in the EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. When we transfer Your data, we will put in place appropriate safeguards to ensure that Your information remains adequately protected.

We do not generally rely on Your consent as the legal basis for transferring Your personal data to outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on Your consent as the legal basis for such processing. Where we do, You may withdraw Your consent at any time in the manner described below.

Opting out

Where required by Data Protection Legislation, You will be given a choice when You provide us with Your personal information to opt into certain uses we may intend to make of that information, such as sending You information or offers containing updated information about us, our services and promotions. You may also be asked if You would like to receive marketing from third party organisations. You will be able to indicate Your consent to each specific proposed use by checking the relevant box to opt in. We will not send You direct marketing, or pass Your details to third parties for the purpose of them sending You direct marketing, without Your consent.

You also have the option of “unsubscribing” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to You.

Details of how to unsubscribe from direct marketing will be included on each electronic mailing we send You. Alternatively, just send an email to enq@langhamestate.com with “URGENT – UNSUBSCRIBE REQUEST” in the subject line and the email address that You wish to be removed within the email.

We will action any opt out request from You without delay, and in any event within one month.

Your rights

At any time, You have the right:

to request access to or a copy of any personal data which we hold about You;
to rectification of Your personal data, if You consider that it is inaccurate;
to ask us to delete Your personal data, if You consider that we do not have the right to hold it;
to withdraw consent to our processing of Your personal data (to the extent such processing is based on previously obtained consent);
to ask us to stop or start sending You marketing messages at any time as described above in the “Opting out” section;
to restrict processing of Your personal data;
to data portability (moving some of Your personal data elsewhere) in certain circumstances;
to object to Your personal data being processed in certain circumstances; and
to not be subject to a decision based on automated processing and to have safeguards put in place if You are being profiled based on Your personal data.

Any request for access to or a copy of Your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards Your rights as a data subject.

We will correct any incorrect or information and will stop processing Your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about You is accurate at all times. To assist us in ensuring that Your information is up to date, do let us know if any of Your personal details change.

Cookies

Our use of cookies

We set and access cookies and similar technology on your device to obtain information about how you access and use our website. This helps us to provide you with a good experience and allows us to improve the website. Unless you have adjusted your browser settings so that it will refuse cookies, the website will set cookies when you load and navigate them.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the website and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.

Cookies can be categorised in accordance with the categories found in the ICC UK cookie guide as set out below:

Strictly necessary cookies – these cookies are essential in order to enable you to move around a website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
Performance cookies – these cookies collect information about how visitors use a website (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
Functionality cookies – these cookies allow a website to remember the choices a user makes, such as a user name or language preference.
Targeting or advertising cookies – these cookies collect information about a user’s browsing habits and are usually placed by advertising networks with the website operator’s permission.

Cookies can also be categorised in accordance with how long they are saved on your device: “session cookies” are short-term cookies that are only saved on the device’s memory for the duration of a user’s visit to the website, whereas “persistent cookies” remain saved in the device’s memory for a set period of time, even after the browser session has ended.

Refusing or restricting cookies

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the website.

Changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to You by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to enquiries@langhamestate.com. You may also use these contact details if You wish to make a complaint to us relating to Your privacy.

If You have any concerns about our use of Your information, You also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

Version: 4^th September 2018