Privacy Policy
This website is operated and provided by Sterling Property Ventures Ltd (“we“, “us“, “our“) having its registered office at Office 2, Tweed House, Park Lane, Swanley, Kent, BR8 8DT. 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.
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 the following carefully to understand our views and practices regarding your personal data and how we will treat it.
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 and the UK Data Protection Act 2018; together with all other applicable legislation relating to privacy or data protection.
What personal information do we collect you and how do we use it?
Personal information (which includes ‘personal data’ as defined in Data Protection Legislation) is generally collected so we can deliver requested materials or information.
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 postings on any other social media applications and services that we provide;
- your IP address, your browser type and language;
- 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.
How we collect information about you
- Information you give to us. This is information about you that you give us by filling in forms on our site (“our site”) (e.g. the contact us section or to sign up to our newsletter) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register on the site for us to contact you, and when you report a problem with our site. The information you give us may include your name and e-mail.
- Social Media. Depending on your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram you might give us permission to access information from those accounts or services.
- 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 and to provide the goods you have requested. 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 carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- 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 site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to send you our newsletter or updates, or to make suggestions and recommendations to you and other users of our site about services that may interest you or them; and provide you or them with targeted marketing in relation to our services (unless you or they indicate at any time that you or they do not wish us to do so); and
- When requesting material or asking someone to contact you, you will have the option to request other information that may be of interest.
Legal grounds for using your personal information
The law permits us to process your personal data in the way that it does 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 any contract we enter with you; and/or
- necessary in order to comply with a legal obligation to which we are subject.
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 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, respond to your inquiries or for any other related purposes.
- We may also share your personal information with:
- other companies we have instructed to provide services for us;
- analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
- third parties who support our information technology or handle mailings or events on our behalf;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
- other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted; and
- 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.
Links to Other Sites
The Site contains links to other websites. We are not responsible for the privacy policies of third party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered via, the Site.
How we protect your information
We take your online security seriously and have implemented generally accepted standards of technology and operational security to protect your personal information from loss, misuse, alteration or destruction. Once we have received your information we will ensure that the collection and use of your information is in accordance with Data Protection Legislation. All of our personnel are required to keep personal information confidential and only authorised persons have access to such information.
Please note, however, that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.
How long we keep your information
We will only keep the information we collect about you, through your use of the Site or otherwise, 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.
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. Your personal data may be transferred to, and stored at, a destination outside the UK and/or European Economic Area (“EEA“) to a country not deemed to provide adequate protection of your information by the European Commission or relevant data protection regulator, and may also be processed by staff operating outside the UK or 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 the Site or to assist in our security or fraud protection activities.
When we, or our permitted third parties, transfer your information outside the UK and/or EEA, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the UK and/or EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. We do not generally rely on your consent as the legal basis for transferring your personal data to outside the UK and/or 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
You 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 will be included on each electronic mailing we send you. Alternatively, just send an email to accounts@sterlingpv.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 be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- 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 (e.g. our newsletter) at any time by using the below contact details;
- 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 to 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 incomplete 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 the Site. This helps us to provide you with a good experience and allows us to improve the Site. Unless you have adjusted your browser settings so that it will refuse cookies, the Site 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 Site. Cookies are then sent back to the originating Site during your browsing session or on each subsequent visit, or to another Site that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the Site 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 Site 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 Site (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
- Functionality cookies – these cookies allow a Site 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 Site 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 Site, 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.
Changes to this Privacy Policy
Any changes we make to our Privacy Policy in the future will be posted on this page of the Site and, where appropriate, notified to you by e-mail.
We would encourage users to check the Privacy Statement each time they use the Site. If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
Contacting us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to The Data Manager, Sterling Property Ventures Ltd, 91 Wimpole Street, London, W1G OEF. 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: 3 October 2019
