Eco World-Ballymore Holding Company Limited ("Eco World-Ballymore"), regularly collects and uses personal data about current, former or prospective purchasers, when you make a reservation, note interest in a property or purchase a property in one of our developments, when you browse our corporate website https://www.ecoworldballymore.com/ or any of the websites for developments of Eco World-Ballymore, in particular Embassy Gardens, Wardian London and London City Island (each a “Website“) or where you register as a resident on any of the community applications made available for the developments, e.g. the WARDIAN.LIFE application (“Apps“).
The purpose of this privacy policy (“Policy“) is to provide a clear explanation of when, why and how we collect and use that personal data. We have designed it to be as user friendly as possible, and have labelled sections to make it easy for you to find the information that is most relevant to you. Please read this Policy carefully as it provides important information about how we use personal data and explains your legal rights.
We will make changes to this Policy from time to time for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. We will make sure that you are aware of any significant changes by sending an email message to the email address you most recently provided to us or by posting a notice on our Website or the Apps so that you are aware of the impact to the data processing activities before you continue to engage.
Eco World-Ballymore is a joint venture between Eco World ACE Co Ltd (“EcoWorld”) and ACE Investment Holdings Limited (“Ballymore”) , having its place of incorporation at 22 Grenville Street, St Helier, Jersey, JE4 8PX (the joint venture and each entity of the joint venture together, “we“, “us“, “our” for the purpose of this Policy). A list of the developments within our current portfolio can be found here https://www.ecoworldballymore.com/.
We collect the following data:
The information marked with an * is mandatory, otherwise we would be unable to fulfil our contractual obligations to you pursuant to our contract or to respond to any enquiries you make on an interest form.
Where you are a contractor engaged to provide work at one of our developments, we collect: 1/ identity data (including: name, address, gender, telephone numbers, email address, username) and 2/ employment / work related data (including: place of employment and profession; employment history, qualifications, accreditations; operational records relating to daily work activity (such as handover logs); and report sheets and work certification.
We will use your personal data to:
We have to establish a legal ground to use your personal data, so we will make sure that we only use your personal data for the purposes set out in this Section 4 and in Appendix 1 where we are satisfied that our use of your personal data is necessary to:
Where we process special categories of personal data, for example health information, we have an additional lawful basis, this additional basis will either be:
Where we process information that reveals or relates to criminal convictions or offences (for example as part of credit checks to prevent money laundering or to manage accidents that occur at a property on our development), we have an additional lawful basis, this additional basis will be either based on condition 14(1) or 15 of Schedule 1 of Data Protection Act 2018.
We share the data with the following entities:
To ensure we manage our developments in a streamlined manner, we also share the data with Service Providers who provide database, IT and system administration services, such as Salesforce which is based in the USA.
Also, if we were to sell part of our businesses, we would transfer your personal data to the purchaser or potential investors.
We may use your personal data to send you direct marketing communications about our developments or services. This will be in the form of email, post, SMS or targeted online advertisements.
Where we require explicit opt-in consent for direct marketing in accordance with the Privacy and Electronic Communications Regulations (“PECR”) we will ask for your consent - we may also ask if you wish to receive marketing from any of our Associated Companies listed in Section 6 above. Otherwise, for non-electronic marketing or where we can rely on the soft opt-in exemption under the PECR, we will be relying on our Legitimate Interests for the purposes of GDPR as further detailed in Section 4 and Appendix 1.
We also use your personal data for customising or personalising advertisements, offers and content made available to you based on your visits to and/or usage of any of our Websites or the Apps, and analyse the performance of those advertisements, offers and content. This constitutes 'profiling' - it does not have any significant legal impact on you but simply means we can ensure marketing materials are tailored to your preferences or what we think you will be interested in.
You have a right to stop receiving direct marketing at any time - you can do this by following the opt-out links in electronic communications (such as emails), or by contacting us at dataprotection@ecoworldballymore.com.
We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests, in particular we will either:
You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us at dataprotection@ecoworldballymore.com. if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).
We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 5 of this Policy.
Where we are required to do so to meet legal, regulatory, tax or accounting requirements, we will retain your personal data for longer periods of time, but only where permitted to do so, including so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings.
We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required and we do not have a legal requirement to retain it, we will ensure it is either securely deleted or stored in a way such that it is anonymised and the personal data is no longer used by the business.
You have a number of rights in relation to your personal data. In summary, you have the right to request: access to your data; rectification of any mistakes in our files; erasure of records where no longer required; restriction on the processing of your data; objection to the processing of your data; data portability; and various information in relation to the basis of any international transfers. You also have the right to complain to your supervisory authority (further details of which are set out in Section 11 below). These are defined in more detail as follows:
Right | What this means |
---|---|
Access |
You can ask us to:
|
Rectification | You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it. |
Erasure / Right to be Forgotten |
You can ask us to erase your personal data, but only where:
|
Restriction |
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
|
Portability | You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Controller, but in each case only where: the processing is based on your consent or the performance of a contract with you; and the processing is carried out by automated means. |
Objection | You can object to any processing of your personal data which has our 'Legitimate Interests' as its legal basis (see Appendix 2 for further details), if you believe your fundamental rights and freedoms outweigh our Legitimate Interests. Once you have objected, we have an opportunity to demonstrate that we have compelling Legitimate Interests which override your rights. |
You also have various rights in relation to any automated decision making, however we do not carry out these activities as we always involve meaningful human intervention.
To exercise your rights you can contact us at dataprotection@ecoworldballymore.com. Please note the following if you do wish to exercise these rights:
If you have a complaint or concern about how we use your personal data, please contact us at dataprotection@ecoworldballymore.com in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority. In the UK, the supervisory authority for data protection is the ICO (https://ico.org.uk/). We do ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Activity | Type of information collected | The basis on which we use the information |
---|---|---|
carry out our obligations arising from any contracts entered into
between you and us, in particular:
|
Identity Information Employment Information Bank details and financial information Conveyancing Information Communications Vehicle details Details on energy usage |
Performance of a contract or potential contract with you. Legitimate Interest to provide services and to operate and grow our business. |
comply with internal record keeping requirements, including records of changes in name and ownership of leasehold properties. |
Identity Information Conveyancing Information |
Performance of a contract or potential contract with you. Legitimate Interest to operate our business and keep our records updated. |
process information that you provide by filling in forms on our Website, or any of the Apps or a reservation or registration of interest form at one of our sales offices and, if applicable, deal with any concerns if you contact us with a query or issue. |
Identity Information Communications |
Performance of a contract or potential contract with you. Legitimate Interest to provide services and to operate and grow our business. |
administer and protect our business, property portfolio and our Website and Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
Identity Information Communications Device Data |
Legitimate Interest to operate our business, to provide administration & IT services, for network security and for prevention of fraud and ensure that our Websites and Apps operate efficiently. |
carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes. |
Identity Information Employment Information Identification details Bank details and financial information Insolvency and bankruptcy information |
Performance of a contract. Legal obligation. Condition 14(1) or 15 of Schedule 1 of Data Protection Act 2018. |
facilitate registration as a resident on the Apps, and managing enquiries and providing services via the Apps. |
Identity Information Communications |
Performance of a contract. Legitimate interest to manage and maintain our portfolio. |
where we are responsible for the costs of doing so, arrange and manage repairs. |
Contractors: Identity data & Employment / work related data Leaseholders/Residents: Identity Information, Communications and Conveyancing Information |
Performance of a contract or potential contract with you. |
communicate with you in the event of emergency, for general crisis management, and to manage emergency response procedures, including evacuation plans. |
Identity Information Communications Health information |
Performance of a contract or potential contract with you. Legitimate interest to manage our portfolio and maintain security and protect our interests and reputation and deal with crises. Necessary to protect the vital interests of the data subject. Necessary for the establishment, exercise or defence of legal claims. |
manage operational issues and issue general estate communications, including to notify you about changes. |
Identity Information Communications |
Performance of a contract or potential contract with you. |
issue marketing communications and feedback surveys and to enable you to partake in a viewing, open house, launch or event, prize draw or competition. |
Identity Information Communications |
Legitimate interest for marketing activities relating to our developments and to grow our business or where opt-in consent is required for electronic marketing pursuant to PECRs, consent. |
carry out profiling and analytics and take steps to ensure that content from our Websites and Apps and, where applicable, our marketing communications, is presented in the most effective manner for you and for your computer. Further, using data analytics to improve our property portfolio, products/services, marketing, customer relationships and experiences. |
Identity Information Communications Profile/Demographic Information Details on energy usage Device data Vehicle details |
Legitimate interest to define types of customers based on their age, gender & interests for our products or services, to keep our Websites and Apps updated & relevant, to develop our business and to inform our marketing strategy; also to ensure communications are relevant and of interest to recipients. |
process CCTV footage and protect facilities / properties in our development. |
CCTV imagery and details Health information Vehicle details |
Legitimate interest to manage our portfolio and maintain security and protect our interests and reputation. Condition 14(1) or 15 of Schedule 1 of Data Protection Act 2018. Necessary to protect the vital interests of the data subject. Necessary for the establishment, exercise or defence of legal claims. |
comply with legal and regulatory obligations. |
Identity Information Conveyancing Information Identification details Bank details and financial information |
Legal obligation. |
Controller: means a natural or legal person which determines the means and purposes of processing of personal data.
Data Subject: means an individual whom the personal data is about.
EEA: means the European Economic Area.
GDPR: means the General Data Protection Regulation, which came into force on 25 May 2018 and replaces the previous Data Protection Directive 95/46/EC.
ICO: the Information Commissioner's Office regulates the processing of personal data by all organisations within the UK.
Legitimate Interests: this is a ground which can be used by organisations as a lawful basis of processing, for example where personal data is used in ways that could reasonably be expected, or there is a compelling reason for the processing.
Personal Data: is information that relates to an identified or identifiable individual. What identifies an individual could be as simple as a name or a number or could include other identifiers such as an IP address or a cookie identifier, or other factors.
Service Providers: these are a range of third parties to whom we outsource certain functions of our business. For example, we have service providers who provide / support IT applications or systems, which means that your personal data will be hosted on their servers, but under our control and direction. We require all our service providers to respect the confidentiality and security of personal data.