2 PERSONAL DATA AND ITS USES
(a) What we collect and why
TYPICAL PURPOSES ARE AS FOLLOWS:
(i) Answering your queries
Where you send us personal data in the context of asking us a question or query (for example, about the company, or its services) we shall use the data you provide in order to respond to your question. In some cases, and where permitted by data protection law, it may be necessary to share your details with other members of Shaftesbury Group, or with other third party data processors, in order to respond to your question or for limited other purposes as required (see “Data Processors and Data Disclosures” below).
(ii) Entering a promotion
We may use personal data submitted in an entry form for a promotion for the purpose of administering the promotion in accordance with its stated rules and, with your consent where necessary, for direct marketing purposes (see “Future direct marketing” below). Such rules may include obtaining consent from participants who are winners to the publication of abbreviated winners' identity details, and may obtain consent from winners to participate in future publicity. The promotion may be administered by third party agencies on our behalf, who may have access to the data you submit (see “Data Processors and Data Disclosures” below).
(iii) Future direct marketing
With your consent where necessary, we will from time to time send you information about special offers, events, launches and other promotions within the Shaftesbury Group (this means the Shaftesbury Villages i.e. six areas in central London in which Shaftesbury has extensive property holdings in - Carnaby, Chinatown, Berwick Street, Seven Dials, St Martin’s Courtyard, Opera Quarter) about products or services of other companies in the Shaftesbury Group and those of carefully selected third parties which we believe may be of interest to you. If you agree, we may also share your data with or pass it to other companies in the Shaftesbury Group for the purposes of their sending you information about other offers and events which they may be running which may be of interest to you but we will not pass your details on to third parties outside the Shaftesbury Group for their own marketing. All of this marketing may be sent by email, SMS, or other electronic means, depending on the contact details you give us when you agree to receive that marketing. At any time, however, you may unsubscribe from ("opt out" of) such future contact by following the instructions in the marketing communication itself.
(iv) For other purposes permitted or required by data protection law
This may include, for example, use of personal data where necessary as part of any restructuring relating to us and our business or assets, or as part of a sale of our company or its assets. It may also include responding to governmental or law enforcement agency requests for information about visitors to our website or to the Villages.
3 DATA PROCESSORS AND DATA DISCLOSURES
At times we may retain third parties to process or analyse data we collect on our websites, including your personal data. For example, the website may be maintained or hosted by a specialist IT services agency, and any promotions may be administered by a sales promotion agency. These suppliers and other third parties are contractually obliged not to use your personal data in any way other than that which we have specified.
We may also share your personal data with third party businesses based in the Shaftesbury Villages to the extent needed for proper management of the Villages and with third party businesses who advertise on this website or who wish to send their own marketing to you (see “Personal data and its Uses”).
WE MAY ALSO DISCLOSE YOUR PERSONAL DATA:
(i) In response to a court order, or a request for cooperation from a law enforcement or other government agency or if disclosure is otherwise required by search warrant or law;
(ii) To establish or exercise legal rights, defend legal claims, or for responsible corporate governance;
(iii) To buyers where necessary as part of any restructuring relating to us and our business or assets, or as part of a sale of our company; and
(iv) As may otherwise be permitted or required by data protection law.
We take all reasonable precautions to seek to keep your personal data secure, and to require third party data processors to do likewise, in accordance with our obligations under data protection law. All personally identifiable information is subject to restricted access to prevent unauthorised access, modification or misuse. Please note, however, as indicated above, that we may release your personal data if required to do so by law, or by search warrant, or court order. Like all website operators, we cannot guarantee that all data transmitted over the Internet or through this website will be secure. Please do not provide us with your personal information through this website unless you accept the security implications of dealing online.
8 DATA ANONYMISATION AND AGGREGATION