Privacy Policy and Cookie Policy (Sugar House Island App)
Background:
Vastint UK Services Ltd, its parent company Vastint UK B.V. and its subsidiary Vastint UK Residential Ltd all understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits the Platform and will only collect and use information in a manner consistent with your rights and our obligations under the law.
This Policy applies to our use of any and all data collected by us in relation to your use of the Platform. Please read this Policy carefully and ensure that you understand it. Your acceptance of our Policy is deemed to occur upon your first use of the Platform. If you do not accept and agree with this Policy, you must stop using the Platform immediately.
The Platform operates on an application created and hosted by Blackbell UK Ltd and Blackbell Inc. (“Blackbell”) on our behalf. Blackbell also has its own privacy policy which relates to your use of the Platform and the information it collects about you which is available here: https://www.blackbell.com/privacyendusers
1. Glossary
In this Policy we have used the following terms:
Platform - which means this website, https://sugarhouseislandapp.com or https://sugarhouseislandapp.blackbellapp.com or the Sugar House Island app available via Apple or Google.
we/us/our which means (1) Vastint UK Services Limited, a company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB; (2) Vastint UK Residential Limited, a company registered in England under company number 12413617, of the same registered address as (1); and (3) Vastint UK B.V., a company registered in the Netherlands with trade register number 34363982, whose registered address is Hettenheuvelweg 51, 1101 BM Amsterdam, The Netherlands.
Other terms which appear in bold in this Policy have the meanings given in the relevant section below.
2. Information About Us
This Platform is managed by (1) Vastint UK Services Limited, a limited company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB. Our Platform is also operated on behalf of, and contains content belonging to: (2) our subsidiary Vastint UK Residential Limited, a company registered in England under company number 12413617, whose registered address is 135 High Street, London E15 2RB; and (3) our parent company Vastint UK B.V., a company registered in the Netherlands with trade register number 34363982, whose registered address is Hettenheuvelweg 51, 1101 BM Amsterdam, The Netherlands.
3. Scope – What Does This Policy Cover?
This Policy applies only to your use of the Platform. It does not extend to any websites that are linked to from the Platform. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Our Platform also contains contact details for and allows you to order services from third parties in relation to our development, such as our managing agents, local businesses and other service providers. If you choose to contact / order services from those third parties and in doing so provide them with any personal data, the use of your data by those third parties will be determined by their own privacy policies, details of which they should supply to you. This Policy does not apply to any data you choose to supply to any third parties via the Platform.
4. What Data Do We Collect?
4.1 Some data will be collected automatically by the Platform (for further details, please see section 10 on our use of cookies), other data will only be collected if you input it yourself for example when signing up for an account or when ordering services via the Platform. Depending upon your use of the Platform, we or others (via a third party cookie – see section 10) may collect some or all of the following types of data:
4.3 We do not routinely collect any special categories of 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, although it is possible that we may receive such information if you provide it voluntarily to us, for example in the context of raising a query or complaint with us.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and other relevant legislation in the UK including the Data Protection Act 2018 (DPA) (together, the Data Protection Legislation). For more details on security see section 6, below.
5.2 Under the Data Protection Legislation we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. 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:
5.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
5.4 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
5.5 Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
5.6 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the unsubscribe links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, updates or other transactions.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
6.2 Some or all of your data may be stored or transferred outside of the UK or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein), where it is transferred to third parties based outside the EEA, as described in section 7. If we do store or transfer data outside the UK and/or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and/or EEA and under the Data Protection Legislation.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Platform.
6.4 Steps we take to secure and protect your data include:
a. Limiting access to your data strictly to those personnel who need to use it for the purposes of their role;
b. Using password protected access to systems where your data may be held;
c. Limiting or preventing use of printed or other insecure copies (e.g. copies on USB sticks) of documents containing personal data; and
e. Ensuring any third parties who have access to your data are contractually obliged to have secure systems and processes in place and to comply with their legal obligations in relation to personal data (see section 7 for further information.)
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in our group. This includes our holding company, Vastint Holding B.V., and its subsidiaries.
7.2 We may from time to time contract with third parties to supply services to you on our behalf. These may include our managing agents and other local service providers, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. Some of these third parties are based outside the UK and/or EEA. In these cases, we will act as described in section 6.2 above.
7.3 We may compile statistics about the use of the Platform including data on traffic, usage patterns, user numbers, referring sites and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates and partners. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
8. What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the data for the purposes for which it was originally collected by us.
9. Understanding, Controlling and Accessing Your Data
Summary of your rights under the Data Protection Legislation
Under the Data Protection Legislation, you have:
9.1 the right to request access to, deletion of or correction of, your personal data held by us;
9.2 the right to complain to a supervisory authority;
9.3 the right to be informed of what data processing is taking place;
9.4 the right to restrict processing;
9.5 the right to data portability;
9.6 the right to object to processing of your personal data;
9.7 rights with respect to automated decision-making and profiling (these are not applicable to our use of your personal data - see section 11 below).
To enforce any of the foregoing rights or if you have any other questions about the Platform or this Policy, please contact us using the details set out in section 12 below.
Controlling your data
9.8 We aim to give you strong controls on our use of your data. This includes the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails. You may also contact us to make corrections if you believe any of the data we hold about you is inaccurate. Our contact details are set out in section 12.
9.9 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given
9.10 Some data is collected automatically when you visit the Platform. You may be able to restrict collection of some data by restricting your internet browser’s use of cookies. For more information, see section 10.
9.11 You may withdraw your consent for us to use your personal data as set out in section 5 at any time by contacting us using the details set out in section 12, and we will delete your data from our systems except where we need to retain some or all of the data for legal reasons. If this applies we will explain this to you at the time of your request.
Accessing Your Data
9.12 You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us using the contact details below in section 12.
10. What Cookies Do We Use and What For?
10.1 As you interact with the Platform, 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. We may also receive Technical Data about you if you visit other websites employing our cookies.
10.2 Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect information relating to your use of the Platform and other internet use and to enhance your experience using the Platform.
10.3 We may use the following types of cookies and tracking technologies:
Strictly Necessary Cookies. These cookies are essential because they enable you to move around the Platform and use certain features on the Platform. For example, strictly necessary cookies allow you to access secure areas of the Platform. Without these cookies, some services on the Platform cannot be provided.
Performance/Analytics Cookies. These cookies collect information about your use and interaction with the Platform and services. The types of information collected by such cookies include which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages.
Functionality Cookies. These cookies allow us to remember your preferences and choices so that we can tailor our services to you and your interests. For example, these cookies will remember which country or language you selected, or will use your display name on parts of the Platform. If you are logged in to your account, we may associate the cookie information with the personal information tied to your account.
10.4 We may also receive personal data about you from various third parties and public sources as set out below:
a. Technical Data from the following parties:
i. Third-Party Analytics. We use third-party analytics services (such as Google Analytics which may be based outside the EU) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Platform and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.
For Google Analytics, please visit https://www.google.com/analytics
For Clicky, please visit https://clicky.com
For Inspectlet, please visit https://www.inspectlet.com/
ii. advertising networks such as Google which may be based outside the EU; and
iii. search information providers such as Google which may be based outside the EU.
B Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, which are based in the EU.
10.5 All cookies used by and on the Platform are used in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended.
10.6 Before cookies are placed on your computer or device, you will be shown a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Platform may not function fully or as intended. You can choose to enable or disable Cookies in your internet browser. Limited data may be collected automatically even if you enable or disable Cookies.
10.7 Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. Some third party cookies can also be individually disabled by following the instructions given in the relevant link in a. above.
10.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. Automated Decision-Making and Profiling
We do not currently use personal data for the purposes of automated decision-making or for profiling. If this changes, we will let you know.
12. Contacting Us
If you have any questions about our use of your data or this Policy, please contact us by email at dataprotection@sugarhouseisland.com, by telephone on 020 3384 7900, or by post at Vastint UK Services Ltd, 135 High Street, London E15 2RB marked for the attention of the Legal Counsel. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
13. Changes to Our Policy
We may change this Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on the Platform and you will be deemed to have accepted the terms of the Policy on your first use of the Platform following the alterations. If you have submitted your contact details to us, we will notify you of any significant changes to this Policy which may affect how your data is used or which may otherwise have a significant impact on you. We will not notify you directly of minor changes but we recommend that you check this page regularly to keep up-to-date.
This Policy was last updated in September 2020.
Vastint UK Services Ltd, its parent company Vastint UK B.V. and its subsidiary Vastint UK Residential Ltd all understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits the Platform and will only collect and use information in a manner consistent with your rights and our obligations under the law.
This Policy applies to our use of any and all data collected by us in relation to your use of the Platform. Please read this Policy carefully and ensure that you understand it. Your acceptance of our Policy is deemed to occur upon your first use of the Platform. If you do not accept and agree with this Policy, you must stop using the Platform immediately.
The Platform operates on an application created and hosted by Blackbell UK Ltd and Blackbell Inc. (“Blackbell”) on our behalf. Blackbell also has its own privacy policy which relates to your use of the Platform and the information it collects about you which is available here: https://www.blackbell.com/privacyendusers
1. Glossary
In this Policy we have used the following terms:
Platform - which means this website, https://sugarhouseislandapp.com or https://sugarhouseislandapp.blackbellapp.com or the Sugar House Island app available via Apple or Google.
we/us/our which means (1) Vastint UK Services Limited, a company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB; (2) Vastint UK Residential Limited, a company registered in England under company number 12413617, of the same registered address as (1); and (3) Vastint UK B.V., a company registered in the Netherlands with trade register number 34363982, whose registered address is Hettenheuvelweg 51, 1101 BM Amsterdam, The Netherlands.
Other terms which appear in bold in this Policy have the meanings given in the relevant section below.
2. Information About Us
This Platform is managed by (1) Vastint UK Services Limited, a limited company registered in England under company number 07394552, whose registered address is 135 High Street, London E15 2RB. Our Platform is also operated on behalf of, and contains content belonging to: (2) our subsidiary Vastint UK Residential Limited, a company registered in England under company number 12413617, whose registered address is 135 High Street, London E15 2RB; and (3) our parent company Vastint UK B.V., a company registered in the Netherlands with trade register number 34363982, whose registered address is Hettenheuvelweg 51, 1101 BM Amsterdam, The Netherlands.
3. Scope – What Does This Policy Cover?
This Policy applies only to your use of the Platform. It does not extend to any websites that are linked to from the Platform. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Our Platform also contains contact details for and allows you to order services from third parties in relation to our development, such as our managing agents, local businesses and other service providers. If you choose to contact / order services from those third parties and in doing so provide them with any personal data, the use of your data by those third parties will be determined by their own privacy policies, details of which they should supply to you. This Policy does not apply to any data you choose to supply to any third parties via the Platform.
4. What Data Do We Collect?
4.1 Some data will be collected automatically by the Platform (for further details, please see section 10 on our use of cookies), other data will only be collected if you input it yourself for example when signing up for an account or when ordering services via the Platform. Depending upon your use of the Platform, we or others (via a third party cookie – see section 10) may collect some or all of the following types of data:
- Identity Data which includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data which includes billing address, delivery address, email address and telephone numbers.
- Financial Data which includes bank account and payment card details.
- Transaction Data which includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data which includes 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.
- Profile Data which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data which includes information about how you use our website, products and services.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.3 We do not routinely collect any special categories of 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, although it is possible that we may receive such information if you provide it voluntarily to us, for example in the context of raising a query or complaint with us.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and other relevant legislation in the UK including the Data Protection Act 2018 (DPA) (together, the Data Protection Legislation). For more details on security see section 6, below.
5.2 Under the Data Protection Legislation we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. 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 or regulatory obligation.
5.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
5.4 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
5.5 Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
5.6 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the unsubscribe links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, updates or other transactions.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
6.2 Some or all of your data may be stored or transferred outside of the UK or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein), where it is transferred to third parties based outside the EEA, as described in section 7. If we do store or transfer data outside the UK and/or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and/or EEA and under the Data Protection Legislation.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Platform.
6.4 Steps we take to secure and protect your data include:
a. Limiting access to your data strictly to those personnel who need to use it for the purposes of their role;
b. Using password protected access to systems where your data may be held;
c. Limiting or preventing use of printed or other insecure copies (e.g. copies on USB sticks) of documents containing personal data; and
e. Ensuring any third parties who have access to your data are contractually obliged to have secure systems and processes in place and to comply with their legal obligations in relation to personal data (see section 7 for further information.)
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in our group. This includes our holding company, Vastint Holding B.V., and its subsidiaries.
7.2 We may from time to time contract with third parties to supply services to you on our behalf. These may include our managing agents and other local service providers, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. Some of these third parties are based outside the UK and/or EEA. In these cases, we will act as described in section 6.2 above.
7.3 We may compile statistics about the use of the Platform including data on traffic, usage patterns, user numbers, referring sites and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates and partners. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
8. What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the data for the purposes for which it was originally collected by us.
9. Understanding, Controlling and Accessing Your Data
Summary of your rights under the Data Protection Legislation
Under the Data Protection Legislation, you have:
9.1 the right to request access to, deletion of or correction of, your personal data held by us;
9.2 the right to complain to a supervisory authority;
9.3 the right to be informed of what data processing is taking place;
9.4 the right to restrict processing;
9.5 the right to data portability;
9.6 the right to object to processing of your personal data;
9.7 rights with respect to automated decision-making and profiling (these are not applicable to our use of your personal data - see section 11 below).
To enforce any of the foregoing rights or if you have any other questions about the Platform or this Policy, please contact us using the details set out in section 12 below.
Controlling your data
9.8 We aim to give you strong controls on our use of your data. This includes the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails. You may also contact us to make corrections if you believe any of the data we hold about you is inaccurate. Our contact details are set out in section 12.
9.9 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given
9.10 Some data is collected automatically when you visit the Platform. You may be able to restrict collection of some data by restricting your internet browser’s use of cookies. For more information, see section 10.
9.11 You may withdraw your consent for us to use your personal data as set out in section 5 at any time by contacting us using the details set out in section 12, and we will delete your data from our systems except where we need to retain some or all of the data for legal reasons. If this applies we will explain this to you at the time of your request.
Accessing Your Data
9.12 You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us using the contact details below in section 12.
10. What Cookies Do We Use and What For?
10.1 As you interact with the Platform, 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. We may also receive Technical Data about you if you visit other websites employing our cookies.
10.2 Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect information relating to your use of the Platform and other internet use and to enhance your experience using the Platform.
10.3 We may use the following types of cookies and tracking technologies:
Strictly Necessary Cookies. These cookies are essential because they enable you to move around the Platform and use certain features on the Platform. For example, strictly necessary cookies allow you to access secure areas of the Platform. Without these cookies, some services on the Platform cannot be provided.
Performance/Analytics Cookies. These cookies collect information about your use and interaction with the Platform and services. The types of information collected by such cookies include which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages.
Functionality Cookies. These cookies allow us to remember your preferences and choices so that we can tailor our services to you and your interests. For example, these cookies will remember which country or language you selected, or will use your display name on parts of the Platform. If you are logged in to your account, we may associate the cookie information with the personal information tied to your account.
10.4 We may also receive personal data about you from various third parties and public sources as set out below:
a. Technical Data from the following parties:
i. Third-Party Analytics. We use third-party analytics services (such as Google Analytics which may be based outside the EU) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Platform and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.
For Google Analytics, please visit https://www.google.com/analytics
For Clicky, please visit https://clicky.com
For Inspectlet, please visit https://www.inspectlet.com/
ii. advertising networks such as Google which may be based outside the EU; and
iii. search information providers such as Google which may be based outside the EU.
B Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, which are based in the EU.
10.5 All cookies used by and on the Platform are used in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended.
10.6 Before cookies are placed on your computer or device, you will be shown a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Platform may not function fully or as intended. You can choose to enable or disable Cookies in your internet browser. Limited data may be collected automatically even if you enable or disable Cookies.
10.7 Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. Some third party cookies can also be individually disabled by following the instructions given in the relevant link in a. above.
10.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. Automated Decision-Making and Profiling
We do not currently use personal data for the purposes of automated decision-making or for profiling. If this changes, we will let you know.
12. Contacting Us
If you have any questions about our use of your data or this Policy, please contact us by email at dataprotection@sugarhouseisland.com, by telephone on 020 3384 7900, or by post at Vastint UK Services Ltd, 135 High Street, London E15 2RB marked for the attention of the Legal Counsel. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
13. Changes to Our Policy
We may change this Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on the Platform and you will be deemed to have accepted the terms of the Policy on your first use of the Platform following the alterations. If you have submitted your contact details to us, we will notify you of any significant changes to this Policy which may affect how your data is used or which may otherwise have a significant impact on you. We will not notify you directly of minor changes but we recommend that you check this page regularly to keep up-to-date.
This Policy was last updated in September 2020.
