The Quintain group of companies takes your privacy seriously where we deal with your personal information. This means information that identifies you personally such as your name, credit card information, photo and contact details or data that can be linked with such information in order to identify you directly or indirectly (“information”).
Quick guide to contents
References to ‘we’, ‘our’ or ‘us’ in this Policy are to the following members of the Quintain group:
Quintain Ltd, Quintain Services Ltd, Quintain NW01 Developments Ltd, Quintain Alto Developments Ltd, Wembley NW07 Investments Ltd, all of 180 Great Portland Street, London W1W 5QZ (hereinafter “Quintain”).
Wembley Park Residential Ltd, of 180 Great Portland Street, London W1W 5QZ (hereinafter “Wembley Park Residential”).
Wembley Park Ltd and Wembley Park Estate Management Ltd, both of 180 Great Portland Street, London W1W 5QZ which includes Wembley Park brands – Wembley Official Parking and Yellow Pavilion) (hereinafter “Wembley Park”).
How do we collect your information?
We collect your information in the context of offering and providing our services to you, and when you interact with us. We collect your information in a number of ways, being either information you give to us, information we collect automatically, information we receive from third parties, information you provide about other people or information we collect through CCTV and surveillance.
Information you give us
We collect information on you where you:
- register to receive any kind of marketing communications from us, including our newsletters and the alert services on our website;
- contact us over the phone, or via email, post, live chat or social media messaging;
- interact with our social media profiles;
- create an account with us, or log in and make changes to your online account;
- visit, attend classes at or interact with any of our community centres such as the Yellow Pavilion and you provide us with your information;
- complete a consent form to allow us use photo or video footage of you or attend any of our events or programmes with our official photographer present;
- hire parking space or venue space from us online or otherwise;
- enquire about renting a property with us or book a viewing for a property;
- lease or purchase a property from us;
- act as a guarantor for a lease or purchase and complete our guarantor form and declaration;
- purchase any of our event tickets or attend any of our events;
- are a landlord or owner of a property and engage us to manage, sell or lease your property;
- enter into a supplier agreement or relationship with us; and
- voluntarily provide us with information for any other reason.
- walk past one of our onsite or in office CCTV cameras
- drive past one of our private road or car park CCTV or ANPR cameras
- book parking through the Wembley Park car park online booking portal or pdq payment machine
- use our Wi-Fi service
Information from third parties
- We collect public information on you and the company you work for from the online database of MIPIM, the leading property summit for all key stakeholders in UK real estate to connect and do business. This information is collected only for the purposes of communicating with the relevant company representatives to invite them to our stand at the MIPIM event. This information includes name, company name, job title and email address;
- Where you are provided as either a reference, a previous landlord or a guarantor, we collect information on you from the relevant individual who has identified you as such. This generally includes name, relationship with tenant or prospective tenant, contact details and salary details (for guarantors);
- We collect information on you from individuals who you provide as either references, previous landlords or guarantors when you wish to rent a property from us. This is generally a description of the relationship between you and the referee along with any merits (or demerits) in relation to you as concerns the renting/purchasing of a relevant property; and
- We collect information on you from referencing companies we engage to carry out pre-tenancy checks on you to ensure you are who you say you are. This is generally information that confirms or refutes the information you have provided to us.
Information we collect automatically
- We collect certain information by automated means, such as cookies and web beacons, whenever you visit our websites. This could include IP address, browser type, operating system, referring URLs, information on actions taken on our websites, and dates and times of website visits. See our Cookie Notice here.
Information we collect through CCTV and surveillance
- We use CCTV and other surveillance systems such as Automatic Number Plate Recognition equipment and where you are recognisable from the images or audio recordings (where applicable) these records are classed as your information. Please see our CCTV and Surveillance Policy to find out more about how we use these surveillance systems.
How do we use your information?
The information we hold on you will be used in a number of ways including to provide you with services related to renting, purchasing or investing in our properties, and to facilitate community engagement by informing and managing your participation in our community programmes, initiatives, activities, promotions and events.
Where we rely on legitimate interest as a ground for processing your information, our legitimate interest is necessary for promoting our business, improving the services we offer to you and your experience when you interact with us, and ensuring effective operational management and internal administration of our business and the exercise of our rights.
To provide you with services requested or where we have a contract
- To register you as a new tenant or property owner when you lease or purchase a property from us;
- To manage and provide you with the services under a lease or purchase agreement, or any other agreement you enter into with us. This includes managing rent, aftercare and maintenance services (including dealing with your queries); and
- To raise sales invoices, to confirm the success of payments you make to us for leased or purchased properties, and to issue you with refunds where applicable.
To send you direct marketing communications relating to our available properties or services, according to your marketing preferences where we do not have a legitimate interest grounds for sending these communications; and
Where we have a legal obligation
- To protect, investigate, deter and report fraudulent, unauthorised or illegal activity. Where you are interested in leasing or purchasing a property, this includes carrying out KYC checks, money laundering checks and sanction checks against you and/or the business you represent.
Where we have a legitimate interest
- To verify that the details you have provided us are true and accurate, and to carry out insolvency and credit checks on you. This is to ensure you are suitable to be able to proceed with purchasing or leasing a chosen property and can finance it;
- To ascertain the kind of property you may be interested in from your enquiries/ information requests and to contact you in relation to such property where you have expressed a desire to be contacted;
- To raise sales invoices and to confirm the success of payments you make to us;
- To process payments for services provided where you are a supplier or a supplier’s representative;
- To contact you with public relations and marketing information, including planning information and information on upcoming events and promotions where you are a representative of a stakeholder company;
- To respond to any enquiries, information requests or complaints you make to us;
- To send you marketing communications where we have a commercial relationship with you or where you have made enquiries in relation to any of our properties and you have not objected to receiving such communications from us;
- To assist with marketing research, processing sales and for statistical purposes;
- To use photographs and video footage which identify you for our marketing, advertising and research campaigns where you have completed a release form and we do not have a contract with you or another legitimate interest ground for using this information;
- To use photographs and video footage which may identify you, for our marketing, advertising and research campaigns where you attend an event or programme with our official photographer in attendance and we have given prior notice of the presence and purpose of such photographer or placed prominent notices at the relevant event to that effect. You are able to object to us taking a picture of you or request we delete this picture at the time;
- To tailor content that we display to you on our website;
- To assist with internal record keeping;
- To improve the properties and services we offer to you;
- To provide you with, and maintain the quality of, our website and to analyse the use of our website in order to help guide improvements; and
- To contact you for your views and feedback on our services and to notify you if there are any important changes or developments to our services.
We may also use aggregate anonymised information in order to help us develop our services and may provide such information to third parties. This information cannot identify you.
Where we rely on legitimate interest as a ground for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request, and can find out more by contacting us using the details below.
Do we share your information?
- We share your information in limited circumstances with the members of our group, government authorities, our suppliers, business partners and other trusted third parties. Where shared, we ensure your information will only be used for the purposes outlined in this policy. We do not sell your information under any circumstances.
- We share your information with our other group companies for internal reasons, primarily for business and operational purposes in line with this Policy (see introduction section for details of these group companies and the below):
- We share your information with our trusted suppliers subject to appropriate controls. In particular we share information with:
- We share your information with estate agents, mortgage providers and independent financial advisers;
- We share your information with Brent Council, the Homes and Community Agency (now Homes England) and relevant utility providers where you purchase or rent a property with us. This is so they are able to update their systems and direct any correspondence or bills directly to you;
- We share your information with property management agents, FirstPort, Mainstay and Homeground who manage certain developments on our behalf and on behalf of our ground leaseholders;
- We share your information with our legal representatives, solicitors, auditors and lenders;
- We share your information with law enforcement agencies who may access and use your information for prevention of crime such as fraud and money laundering. This includes exchanging information with other companies and organisations (as necessary) for the purposes of fraud protection and prevention;
- We share your information with the emergency services or other relevant requesting authority where it relates to a serious incident you are involved with on our property;
- We share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce a lease/purchase agreement and any other agreement; or to protect our rights, property, safety or security, and that of third parties, visitors to our websites or the public;
- We share your information with a third party if we transfer, change or assign your agreement or we employ a third party to manage any aspect of your account and are required to pass relevant information about you to them;
- As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, such information may be considered an asset of ours and as such it is possible they will be sold or transferred to third parties; and
- We share your information where you give us express permission to share your information in the course of your relationship with us from time to time.
Please note that our website may contain links to other websites operated by third parties – these websites are outside of our control and are not covered by this Policy. This Policy applies only to the information we collect and we cannot be responsible for information that third parties may collect, store and use.
How long do we keep your information?
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘How do we use your information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws. For example, we generally keep your information for 6.5 years after termination of a lease agreement with you, in our legitimate interest, to be able to bring claims or defend against potential legal action.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase or anonymise your information where we no longer require your information for the purposes collected.
Do we transfer your information abroad?
Your information is stored within the EU generally and in limited circumstances may be transferred to India or the US; this is the case only where you provide your name and email address details for the alert service on our www.quintain.co.uk website or when you register for email newsletters delivered by our marketing software Mailchimp. We ensure that any of your information processed outside the EEA is protected in the same way, as it would be, if it were processed within the EEA by putting appropriate security measures and safeguards in place. For the transfer to India, we have EU Model Clauses in place as a safeguard. To find out more about how we safeguard your information as related to transfers and to obtain a copy of such safeguard, contact us using the contact details below.
MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework. It subjects all Personal Information received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view Mailchimp’s certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome.
What are your privacy rights?
By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our details below.
Rights – What does this mean?
- The right to object to processing
- You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
- The right to be informed
- You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
- The right of access
- You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Policy).This is so you’re aware and can check that we’re using your information in accordance with data protection law.
- The right to rectification
- You are entitled to have your information corrected if it is inaccurate or incomplete.
- The right to erasure
- This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.
- The right to restrict processing
- You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability
- You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
- The right to lodge a complaint
- You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See details of the UK data protection regulator in the contact us section below.
- The right to withdraw consent
If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your information for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
Changes to this policy
We may periodically make changes to this Policy. We will notify you of any significant changes where we have a relationship with you and otherwise post updated documents on our website.
If you have any questions, comments and requests regarding this Policy, please get in touch with us at email@example.com.
If you are not satisfied with our response to a complaint you have made, or think we aren’t complying with data protection law, you can make a complaint to the UK data protection regulator – the Information Commissioner’s Office:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113