Data Privacy Notice for clients and website users
Last updated: 28th January 2019
Experience Invest takes the privacy and security of your personal information very seriously. We are committed to protecting your privacy and keeping it safe in accordance with the relevant legislation including but not limited to the General Data Protection Regulation (GDPR) and Data Protection Act 2018.
As Experience BG Limited, (registration number 05301679) we include the entities we have listed below under (who we are). When we use "Experience Invest", ('we'/ 'us'/ 'our') throughout this Policy we are referring to Experience BG limited trading as Experience Invest which is registered in England and Wales and may act as a data controller of your personal information.
By engaging with us as set out in this policy, you confirm that you have read and understood the entirety of this Policy and consent to the practices described in our Website Conditions www.imperial-square.co.uk ('the Website').
Who we are
Why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party such as:
- run, grow and develop our business;
- ensure a safe environment for our staff and website visitors;
- marketing, market research and business development;
- provide client services; and,
- or internal group administrative purposes.
to confirm your identity
(A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests)
- To provide you with information or with related information to which you have consented.
If you have any feedback on this Policy, please let us know using the contacts details at the end of this Policy.
Your Rights to Object
You have rights in respect of your personal information as set out below however two of the fundamental rights to be aware of are:
Ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using personal information for this purpose.
We may send you (by email, telephone, post, instant messaging or social media) certain direct marketing communication if it is in our legitimate interests to do so for marketing and business development purposes. We will always obtain your permission to send you direct marketing campaigns and promotional offers. When we first obtain personal data from you, or when you subscribe to our services, we will give you the opportunity to 'opt-out' of all or any of our marketing campaigns and promotional offers. An 'opt-out' option means you do not wish us to send you information about some or all our services or products (as applicable). You can do this by ticking a box on the subscription form, unsubscribing from emails by following the unsubscribe instructions contained in every email, by going onto the www.imperial-square.co.uk website and logging on to your account (if applicable). You can also contact us by post or email using the contact details below.
Ask us to consider any valid objections or exercise any legal right which you have to our use of your personal information where we process your personal information based on our, or another person's legitimate interest.
You have the right to ask us for your personal data that we hold about you and we must respond within a calendar month on the day after we receive your request. This is commonly referred to as a Subject Access Request. You can ask us for a copy of your personal information, confirmation of whether your personal information is being used by us, details about how and why it is being used and details of what safeguards are in place if we transfer your information out side of the EEA (European Economic Area).
In certain specific circumstances you also have following further rights:
- Right of deletion: This is also known as the right to be forgotten. You have a right to ask us to delete any personal information which we are holding about you.
- Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information.
- Right to data portability: You have a right to ask us to provide your personal information to a third-party provider of services.
- Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information based on our or another person's legitimate interest.
- Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request, unless we tell you we are entitled to a longer period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations such as to HMRC;
preventing or detecting a crime, fraud or misuse of Our services, and investigating where We believe any of these have or may have occurred;
meeting Our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the London Local Authorities Act 2007; and meeting Our obligations under the Data Retention (EC Directive) Regulations 2009. or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
You also have the right to ask us to make changes or amendments to the information we hold about you that may be incorrect. You have the right to complain about our handling of your personal information and can get in contact with us at the address below or by telephoning 0207 834 1114. Additionally, in accordance with Article 77 of the General Data Protection Regulation, you have the right to complain about our collection and use of your personal information to the Information Commissioner's Office or the data protection authority in the country where you usually live or work, or where the alleged infringement of the General Data Protection Regulation has taken place. For more information, please contact the local data protection authority at: Information Commissioner's Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire SK9 5AF or by phone on 0303 123 1113. You may also seek remedy through local courts if you believed your rights have been breached.
Collecting your data
When do we collect your information
We collect, use and process your information in these circumstances:
When you enquire about our services and give us your personal information by phone, email, via our website, in writing, by text message, instant messaging or social media. This includes but is not limited to information you give us when you request quotations, register for email alerts, request literature, exclusive offers and new products/services. The information you give us can include:
Your name, telephone number and your email address, information to enable us to check and verify your identity, e.g. your date of birth, your gender information, location data, from your IP location and also if you choose to give this to us personal, your billing information National Insurance number, financial transaction and payment card information, your personal or professional interests, your professional online presence, e.g. LinkedIn profile, your contact history, purchase history and saved items, information from accounts you link to us, e.g. Facebook, information to enable us to undertake credit or other financial checks on you, information about how you use our website, IT, communication and other systems, your responses to surveys, competitions and promotions
This personal information is required to provide property investment products and services to you. It also allows us to comply with our legal obligations such as Anti-Money laundering checks. If you do not provide the personal information we ask for, it may delay or prevent us from providing products and services to you.
- When you visit our premises. Because of our security policies and procedures in our office premises, we will collect images of visitors using closed circuit television (CCTV)
When you visit our website. When you visit our website, we automatically collect information which includes: The Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, your browser and browser plug-in type and version, and your operating system and platform. We also collect information about your visit, including the source of your visit, and the full click path and mouse movement through our sites (including date and time). This includes the services you viewed, searches you made on our sites, page response times, download errors, length of visits to certain pages, page interaction information (such as page scrolling, mouse clicks, mouse movements and keyed text), and how you navigated away from any page.
When we email you: From time to time when you open an email, we've sent you, we automatically collect information including your geographic location, browser type and version, the device, and the operating system and platform you're using. We also collect information about your email consumption, including the full click path from within and on to our sites (including date and time), and whether you opened, deleted, forwarded, printed or unsubscribed from the email, and how long the email was open.
When we receive your information from third party service providers: We may receive information about you from third party service providers such as credit reference agencies, payment service providers, or analytics providers. If we don't receive all of the personal
information, we've requested from you, then we won't be able to provide all of our products and services to you.
Reasons for collecting your data
In compliance with GDPR Article 6 ("processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract"), we will use the personal data for purposes that include but are not limited to:
Processing any enquiries, you have about our services. This includes carrying out any obligations specified in any contracts between us.
Verifying your identity when you use our services or contact us;
When you call our main contact phone number, 0207 834 1113, we'll collect the Calling Line Identification information and keep a copy of the call for training and security purposes. We'll also use your information to help improve our efficiency and effectiveness.
Delivering our services to you;
Analysing our services with the aim of improving them;
Notifying you about changes to the Website, services or Website Conditions or anything else we may be required or reasonably expected to notify you of; and
Ensuring the content on the Website is presented in the most effective manner for you and for your computer.
In compliance with GDPR Article 6 ("the data subject has given consent to the processing of his or her personal data for one or more specific purposes"), if you have given and not withdrawn consent, we may use the personal data for these purposes:
Providing you with information about our other services, offers or products that you may be interested in; and
Providing you with information about third-party services, offers or products that you may be interested in.
In compliance with GDPR Article 6 ("processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."), we will use the personal data for purposes that include but are not limited to:
Providing you with the best service and information about our services, and to review your ongoing needs;
Responding to your enquiries or requests and investigating or settling disputes;
Providing you with your subscription confirmation;
Identifying and preventing fraud; and
Determining the effectiveness of promotional campaigns and advertising.
To deal with any enquiries or issues you have about how we collect, store and use your information, or any requests made by you for a copy of the information we hold about you.
For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.
Storing your data
We take reasonable and appropriate measures to keep your personal data secure where we have an ongoing legitimate business need to do so (for example to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). We shall prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed.
All personal data will be stored on our computer system and external hard drive and/or in the cloud. All storage systems will be password protected and may be encrypted. Where data is stored on paper or forms, all personal data is locked away when not in use and disposed of securely after use either using document shredders or third-party disposal organisations who have been contracted to dispose of documents appropriately. Any personal data sent to Us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.
We will make reasonable efforts to ensure the data is accurate and up to date. We undertake to rectify any inaccuracies of which we become aware of without delay.
We will only keep your data for as long as necessary and justified. We ensure that we only keep the minimum data needed for the purposes of performing the services to you, legitimate interests, and in line with our legal obligations. For example, but not limited to dealing with complaints and audits.
Personal data will usually be retained for 10 years as necessary to fulfil the purposes we collected it for, after which time it is destroyed. We can use it to respond to any questions or complaint, to maintain records according to the rules that apply to us, or for fighting financial crime including fraud.
In certain circumstances, we will keep your information for longer than ten years - for example if we can't delete it for technical reasons or for compliance with our legal and regulatory obligations. If your personal information is kept for longer than ten years for research and statistical purposes it will be anonymised.
When we have no ongoing legitimate business need to hold your personal information, we will either delete or anonymise it. If we can't do this (for example, because your personal information is stored in backup archives), we'll securely store your personal information, only use it for a purpose we've already communicated to you and isolate it from any further processing until archives are deleted.
We usually store your information on our secure servers in the United Kingdom.
However, where we use third parties to process your information for us, for any reason detailed in our Terms and Conditions, we may transfer your information to, and store it and process it inside or outside the European Economic Area. This could be for (but isn't limited to) the following purposes:
In order to obtain quotations or to arrange investments or insurances with regulated entities.
Our partners and service providers may also transfer your personal information outside of the European Economic Area.
We'll take all steps reasonably necessary to make sure that your personal information is treated securely. For example, as permitted by Article 46 of the General Data Protection Regulation, we use standard contractual clauses with third parties, so that your information is protected to the same standards as it is in the European Economic Area. If your information is sent to the US, in accordance with Articles 45 and 46 of the General Data Protection Regulation we make sure it goes to an organisation that is part of the Privacy Shield or that we use standard contractual clauses with third parties, so that your information is protected to the same standards as it is in the European Economic Area. Privacy Shield is the framework that sets privacy standards for information sent between US and EU countries, and it uses similar standards as the European Economic Area.
Countries outside the European Economic Area where your personal information can be transferred to include: United States of America, Canada, India and Australia.
Using our website
This Policy applies when you use one of the above websites and their content. Partners who provide content or other linking sites found on our websites can also gather information and you should check their privacy notices.
If you visit our websites or use our mobile and/or tablet apps (collectively referred to as "our sites") you acknowledge that the practices described in this Policy apply. Our sites can, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please remember that they have their own policies and that we do not accept any responsibility or liability for their policies or how they collect and use your information.
We do not and will not knowingly collect information from any unsupervised child under the age of 13. If you are under the age of 13, you may not use our sites unless your parent or guardian has provided us with their consent for your use of our sites or our site (as applicable).
. You can also opt out of being tracked by Google Analytics
across all websites.
This privacy notice was published on 28th January 2019. We will update or amend this Policy from time to time, to comply with law or to meet our changing business requirements. You should bookmark and periodically review this page to make sure that you are familiar with the most current version and so you're aware of the information we collect, how we use it and under what circumstances we disclose it.