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Date of last revision: April 1, 2020

70 GS Privacy Policy

Our Policy

Welcome to Grosvenor Estate Management Limited (“we”, “us”, “our) mobile application (hereinafter referred to as the “App”). The protection and security of your personal data are important to us. Personal data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession) (“Personal Data”). This privacy policy (“Privacy Policy”) tells you how we collect, use, share and protect your Personal Data which is collected through the App.

Grosvenor Estate Management Limited 70 Grosvenor St, London, England W1K 3JP is the controller of your Personal Data collected through your use of the App pursuant to the EU General Data Protection Regulation 2016/679, and any other applicable data protection legislation.

Please read this Privacy Policy to understand how Company may process your Personal Data via your use of our Site and/or Company Services. 

  1. Information We Collect:

When you interact with us through the App, we may collect Personal Data and other information from you, as further described below:

  • Personal Data That You Provide: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries.
  • Usage of the App: The following information will also be collected via the App: your full name, email address, tenant status, location, your user ID, your building ID, time stamp, make and model of your device, operating system, operating system version, the services you engage with and your actions in relation to them.   
  • Aggregated Personal DataIn an ongoing effort to better understand and serve the users of the App, we conduct research on user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

  1. Our Use of Your Personal Data and Other Information:

We process the Personal Data you provide to us to enable us via the App to perform the contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including:

  • to enable us to carry out our obligations arising from any contracts and to provide you with the information and services that you request from us;
  • to enable us to respond to an enquiry or other request you make when you contact us via our App, including for customer services support;
  • to notify you about any changes to the App; 
  • to enable us to issue a notice or corrective action to you in relation to the App, if required; and 
  • to help us improve the content and functionality of the App.

If we intend on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

 

  1. Our Disclosure of Your Personal Data and Other Information

We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

  • HqO, Inc. (“HqO”): HqO is the operator of the App. If you have downloaded the App and have set up an account direct with HqO, HqO will collect certain Personal Data from you (such as, your username and password) and HqO will be the controller of that Personal Data. For further details as to how HqO processes your Personal Data, please read HqO’s privacy policy at https://www.hqo.co/privacy-policy. For all other Personal Data collected via the App, we will be the controller of your Personal Data. 
  • Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets. 
  • Related Companies: We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.
  • Agents, Consultants and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include the operator of this App, mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.             
  • Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
  1. Storing your Personal Data

Your Personal Data collected via the App will be stored on servers located in the United States. We have taken steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected (such as, where required to do so, by implementing the European Commission approved standard contractual clauses or ensuring our Service Providers are certified to the EU-U.S. Privacy Shield Framework). If you require more information please contact us using the details in the “Contact Us” section below.

  1. 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 unauthorised 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.

  1. Exclusions

This Privacy Policy does not apply to any Personal Data collected by us other than Personal Data collected through the App. This Privacy Policy will not apply to any unsolicited information you provide to us through the App. All unsolicited information will be deemed to be non-confidential and we will be free to reproduce, use, disclose, and distribute such unsolicited information to others without limitation or attribution.

  1. Children

We do not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the App. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the App without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the App, please contact us, and we will endeavor to delete that information from our databases.

  1. Links to Other Web Sites

This Privacy Policy applies only to the App. The App may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the App do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

  1. Security

We take reasonable steps to protect the Personal Data provided via the App from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. However, no Internet is ever fully secure or error free.  Therefore, you should take special care in deciding what information you send via the App. Please keep this in mind when disclosing any Personal Data to us.

  1. Changes to Company’s Privacy Policy

The App and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above.

  1. Your Rights

You may have the right to: request (a) access the to your Personal Data we hold about you; (b) request we correct any inaccurate Personal Data we hold about you; (c) request we delete any Personal Data we hold about you; (d) restrict the processing of Personal Data we hold about you; (e) object to the processing of Personal Data we hold about you; and/or (f) receive any Personal Data we hold about you in a structured and commonly used machine-readable format or have such Personal Data transmitted to another company. 

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with any local laws and our policies and procedures. You have the right to lodge a complaint about how we process your Personal Data with the supervisory authority in your country.

If you wish to exercise any of your rights, please contact us using the information provide in the “Contact Us” section below. 

  1. Contact Us

If you have any questions about this Privacy Policy or our information practices, please email [email protected]. When you contact us, we will do our best to address any concerns you may have about our processing of your Personal Data.