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Privacy Policy

Please read this privacy policy carefully and re-visit this page from time to time to review any changes that may have been made. Golden Square Group is committed to protecting the privacy of the Personal Information you provide to us, either on signing a tenancy agreement, or through use of our website. By using the website, you consent to the collection and use of the information that you provide to us, in accordance with this privacy policy.

1. OVERVIEW

1.1.The Golden Square Group(“Golden Square Group”, “we” or “us”) may collect, store and use information in accordance with GDPR, which came into effect on 25 May 2018.

1.2. Some of the data we process will be personal information. By ‘personal information’ we mean all information that relates to, identifies or may identify you. For the purposes of GDPR, we are the data controller of any personal information we process about you. This policy sets out details of how we process data in relation to you.

1.3. This privacy policy applies to all personal information we gather or use in connection with your relationship with us. This includes when you use our website goldensquaregroup.co.uk. We will only use your personal information in accordance with this privacy policy.

1.4.By using our services and providing any personal information to us, you are consenting to our use of your personal information, as set out in this privacy policy. Please do not provide us with any personal information if you do not want that information to be used by us in this manner.

2. CONTACTING US

If you have any questions or comments on this policy, or if you wish to withdraw your consent for data processing, you can contact us by email at dpo@goldensquaregroup.co.uk.

3. PERSONAL INFORMATION

You acknowledge that Golden Square Group may collect, store and use information provided by you. This includes the following:

  • Contact details which you provide about you or others including address, telephone numbers, email address and proof of address (for example, bank statement and/or utility bill);

  • Biographical information which you provide about you or others including your title, name and gender;

  • Personal information, including banking details and passport number, which we require under the terms of your tenancy agreement;

  • Details of your visits to the Golden Square Group website, including traffic data and data in relation to the resources that you access on the website;

  • Information you provide when you visit the Golden Square Group website.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with relevant third parties for the operation of your contract with us, for example to enable us to provide maintenance and service facilities. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your data outside the European Economic Area.

7. DATA BREACH

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an un authorised 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

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 un authorised 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. By law we have to keep basic information about our leaseholder/client/occupiers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being leaseholder/client/occupiers.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see these within the glossary below.

If you wish to exercise any of the rights set out above, please contact us via email at dpo@goldensquaregroup.co.uk.

or in writing to:
Data Protection Officer, Golden Square Group, 9 Golden Square, London, W1F 9HZ.
Telephone: +44(0)20 7439 1122

No fee usually required. 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 your request in these circumstances.

9.1 What we may need from you

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.

9.2 Time limit to respond

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.

10. GLOSSARY

10.1 Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to bylaw).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.2 Third Parties

Service providers [acting as processors] based within the EU who provide IT and system administration services Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based within the EU who provide [consultancy, banking, legal, insurance and accounting services].

HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom [who require reporting of processing activities in certain circumstances]

10.3 Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check thatwe are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have success fully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have over riding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you with draw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you with draw your consent.

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