Privacy Policy

Wolfe Commercial Properties Southbank Limited (also referred to in the policy as “we”, “us”, “our”) are committed to protecting and respecting your privacy.

This privacy policy explains the types of information we collect about you when you visit our website 76southbank.com, register an interest in our property opportunities, use our associated services, or otherwise communicate / engage with us. It also outlines how we use your information and your associated rights.

We are the data controller for personal data that we collect about you.

This policy covers:
• Personal data we collect about you
• Lawful basis for processing personal data
• Purposes for which we use your personal data
• Marketing
• Cookies and other technologies
• Links to other websites
• Who we share your personal data with
• Processing your personal data outside the UK and the EEA
• How we protect your personal data
• How long we keep your personal data for
• Your rights
• Changes to this policy
• Contact us

Personal data we collect about you

We collect information from you, including personal data, when you visit our Site, register an interest in our property opportunities, use our associated services or otherwise communicate / engage with us. Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect and process the following personal data from you:

a) Personal data you give us

You may give us personal data by filling in forms or corresponding with us by social media, post, phone, email or otherwise. This includes personal data you provide when you:

• register an interest in one of our property opportunities;
• create an account on our Site;
• subscribe to our services or publications;
• request marketing to be sent to you;
• sign up to attend our upcoming events; and
• give us feedback, make an enquiry or otherwise contact us.
This information includes your name, email address, username, log-in credentials, job title, relationship with a corporate bidder, marketing preferences, and other identity, contact or profile details. Given the free text nature of some of our forms, completing them may also involve you, at your option, providing us with additional personal data.
If you reach out to us via a third party, for example, if you send us a direct message on a social media platform, we may also collect your name and information related to your social media profile which is visible in the message.

b) Personal data we receive about you automatically

As you interact with our Site, we will automatically collect certain technical data about your equipment, browsing actions and patterns. This may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website. We collect this personal data by using cookies and other similar technologies.

For more information about how we process this information, please see our Cookie Policy.

c) Personal data we may receive from other sources

We may receive personal data about you from certain third parties and public sources including:

• other companies in our group and other affiliates;
• your employer, our corporate customers or suppliers with which you have a relationship or are an authorised representative/user;
• social media sites;
• other publicly available databases such as Companies House;

We may also receive your personal data from third party providers and partners which we work with, including our advertising partners and networks. For more information about how we process this personal data, please see our Cookies section below and our Cookie Policy.

Lawful basis for processing personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal data. However, where we do rely on consent (such as in relation to direct marketing), you have the right to withdraw such consent at any time by contacting us.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose we are using your data.

Purposes for which we will use your personal data

We will use your personal data for the following purposes:

• to take steps to enter into any contract or carry out our obligations arising out of a contract with you, such as:
o provide information or services to you as requested, including in relation to registering your interest in a property (where you are an individual bidder);
o administer any account you may have with us;
o manage our relationship with you; and
o notify you about changes to our services.

• in our legitimate interests to:
o provide our services to you as requested, including in relation to registering your interest in a property (where you are a corporate bidder);
o provide the information you request from us, including responding to any queries you have submitted;
o keep our Site and services safe and secure;
o improve our Site and our services;
o analyse your use of the Site, services and interactions with us;
o ensure content from our Site is presented in the most effective manner for you and your device;
o provide relevant and tailored content to you;
o analyse how the Site is used and how you engage with us;
o manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
o where permitted in our legitimate interest, or with your prior consent where required by law, we will use your personal data for marketing analysis or to provide you with promotional update communications about our products, events, newsletters and services.

• where required, when you give your consent (for example, for us to send you our marketing communications and deliver certain cookies). Please see “Your rights” section below for further information about how to withdraw your consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your personal data to form a view on what services or other offerings we think you may want or need, or what may be of interest to you. You may receive marketing communication from us if you have requested information from us, have consented to marketing or have used our services and you have not opted out of receiving that marketing or where we are otherwise legally permitted to send you marketing.

Cookies

We use cookies and other similar technologies to collect and store certain information about you which includes Personal Data. These technologies include cookies, pixels, web beacons and JavaScript (together “Cookies”), and typically involve storing pieces of information or code transferred to or accessed from your device to store and, sometimes, record information about your interaction with online services from your device.

Cookies and similar technologies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content. They allow us to distinguish you from other users of our Services which helps us to provide you with a good experience and also allows us to improve our Services and see how they are performing. Cookies also allow us to keep secure certain areas of our Services.

A number of Cookies and similar technologies we use last only for the duration of your online session and expire when you close your browser. Others are used to remember you when you return to our Services and will last for longer. Some Cookies will also record where you came to our Services from and where you visit once you have left.

We use Cookies and/or other similar technologies, either alone or in combination with each other, to create a unique ID which corresponds to you.

For further information about the Cookies we use and the purposes, as well as how to disable / control Cookies, please see our Cookie Policy.

Links to other websites

Our Site may, from time to time, contain links to external websites, plug-ins and applications including social media platforms. This policy does not apply to such third-party services and we are not responsible for the privacy policies or practices or the content of any third party. Please review third-party privacy policies.

Who we share your Personal Data with

We may share your personal data with:

· our group companies, who may also process your personal data for the purposes set out in this policy;
· organisations who process your personal data on our behalf and in accordance with our instructions. This includes supporting our services, in particular data hosting services, fulfilment services, communications providers, fraud detection services, advertising services, marketing services, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your personal data to the extent necessary to perform their support functions;
· analytics and search engine providers that assist us in the improvement and optimisation of our Site or services and advertising and are subject to our Cookie Policy;
· other third parties such as professional advisors, including banks, accountants, and lawyers; and
· credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will also disclose your personal data to third parties in the event that:
· we sell our business or assets, in which case we will disclose your Personal Data to the prospective buyer of such business or assets subject to the terms of this privacy policy;
· such disclosure is required in order: to comply with legal requests, where required or legally permitted to establish, exercise or defend legal rights; in order to enforce or apply our terms of supply and other agreements with you; or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others. This includes exchanging personal data with other companies and organisations for the purposes of fraud protection, credit risk reduction and to prevent cybercrime.

Processing your Personal Data outside the UK and EEA

We are based in the United Kingdom (“UK”).

Where we transfer your personal data outside of the UK and European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

• We transfer your personal data to countries that have been deemed to provide an adequate level of protection by the UK Secretary of State or the European Commission.
• We implement certain standard contractual clauses with the recipients of your personal data to safeguard transfers to countries outside of the UK / EEA.

Please contact us if you would like further information about the specific mechanism used by us when transferring your personal data out of the UK / EEA.

How we protect your personal data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, we reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.

How long we keep your personal data for

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory and tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal data (see your rights below). In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

You have the right under certain circumstances to:

• access a copy of your personal data held by us;
• object to processing of your personal data;
• request correction of your personal data if it is inaccurate or incomplete;
• request erasure of your personal data in certain circumstances;
• restrict our use of your personal data in certain circumstances;
• object to the use of your personal data for automated decision-making;
• request that your provided personal data be provided to a third party; and
• withdraw consent (only if you have provided your consent and wish to withdraw it). If you withdraw your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legal reason for continuing to use the data.

We do not undertake solely automated decision-making which has a legal or similarly significant effect on you.

If you would like to exercise any of these rights you can contact us using the details below. We may ask you for further information in order to confirm your identity before we provide the information requested or otherwise comply with your request.

You can change your preferences and object to receiving further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to the email address below.

If you have any concerns about this policy please contact us using the details below.

If your request or concern is not satisfactorily resolved by us, you have the right to make a complaint with your relevant data protection authority. In the UK, this is the Information Commissioner’s Office. You can visit their website at www.ico.org.uk.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page. This policy was last updated on 31st August 2023.

Contact us

Questions, comments and requests regarding this privacy policy should be addressed to:

Wolfe Commercial Properties Southbank Limited
19a Town Range, PO BOX 872, Gibraltar, Gibraltar, WC1N 3AX