HTA Real Estate Limited (“HTA”) respects the privacy of visitors to our website and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data acting as a data controller (referred to as “HTA”, “we”, “us” or “our” in this privacy notice) and tell you about your privacy rights and how the law protects you.
2.0 Purpose Of This Privacy Notice
This privacy notice aims to give you information on how HTA collects and processes your personal data, including any data you may provide through this website.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
3.0 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
4.0 Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, marital status, title.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account details, for instance if you pay us direct into our bank, we will have details showing where that payment came from.
- Transaction Data includes details about payments to and from you.
- Usage Data includes information about how you use our website, products and services. The source of this usage data is Google Analytics.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5.0 How We Collect Your Personal Data
We use different methods to collect data from and about you including through the following methods:
- Direct Contact – you may provide details of your identity, contact details and financial data by filling in forms or by corresponding with us by post, phone, email, electronic message or otherwise. This includes personal data you provide when you contact us via our website or request to subscribe to our services or publications.
- Automated Technologies or Interactions - as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy (10.0) for further details.
- Third Parties or Publicly Available Sources - we may also receive personal data about you from various third parties and public sources including technical data from search, analytics & advertising providers such as Google and others based inside the EU and identity and contact data from publicly availably sources such as Companies House, Creditsafe and the Electoral Register based inside the EU.
6.0 Use And Disclosure Of Your Personal Data
We are required to have a lawful basis to hold and process your data. We will only use your personal data when the law allows us to. Broadly most of the data we hold and process is used 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 or regulatory obligation.
- Where we have your specific consent. This would normally be to receive marketing or newsletter updates.
- Where we need to supply personal data to insurers and/or professional advisors to adhere with legal and/or compliance related matters and obligations.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email.
7.0 Inform Us Of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
8.0 If You Do Not Provide Your Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, or in order to contact you and conduct business with you and you choose not to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service and/or contract you have with us but we will notify you if this is the case at the time.
9.0 Data Security
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.
10.0 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 following:
- 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
- the applicable legal requirements.
In some circumstances we may 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.
11.0 Cookies Policy
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
12.0 Your Rights
You have rights under the General Data Protection Regulation 2016 in relation to your personal data including;
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We aim to respond to all legitimate requests within 30 days. It may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13.0 Contact Details
We have appointed Controllers and Data Protection Officers who are responsible for overseeing questions in relation to any queries you may have about this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact by any of the following methods:
- Postal: Floor A Milburn House, Dean Street, Newcastle Upon Tyne, NE1 1LE
- Email: [email protected]
- Telephone: 0191 245 1234
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.