Privacy Policy

BXS DM Limited and BXSLP are the data controller and responsible for your personal information (collectively referred to as “BXS”, “we”, “us” or “our” in this privacy policy).

This privacy policy describes how BXS collects and processes personal information about you, how we use and protect this information and your rights in relation to this information.

This privacy policy covers all personal data collected by us and where we tell other organisations to collect information for us.

Personal information we use

Personal information is information, or a combination of pieces of information, that could reasonably allow a living person to be identified. We may collect the following information about you:

• When you visit our websites the web server collects some basic information about your computer such as your IP address, operating system and browser type. Our website also uses cookies to distinguish you from other users of our website and to promote a good experience when you browse our website. Details of cookies that we use on our websites can be found in our cookie policy;
  
• When you sign up for a newsletter, fill out a feedback form, complete a ‘contact us’ form, report a problem with our site or contact us by email, we collect personal information such as your email address, name, contact number, postcode and date of birth;
• You may be asked to complete surveys or questionnaires either directly or by email and in doing so we may ask for details such as your age, gender and postcode. The information captured is for research purposes so we can understand our type of visitors and customers, although you do not have to respond to these surveys;
• When you visit Brent Cross Town, your image may be captured by CCTV operated by BXS or on our behalf. There are signs in place to inform you where cameras are in use by us.
• When you visit Brent Cross Town you may be photographed by our appointed photographer. These photographs are used by us for marketing, advertising and promotional purposes.
• We collect statistical information on the footfall (visits) to Brent Cross Town. Data is collected from footfall counters or CCTV images but only statistical data is collected on the number of visits, not the personal information of visitors.

How we use your personal information

We use your personal information to:

• Provide and personalise our services, including promoting a good experience when browsing our website;
• Deal with your enquiries and requests;
• Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
• Contact you with marketing and offers relating to products and services offered by us, or selected third parties, unless you have opted out of marketing, or we are otherwise prevented by law from doing so;
• Personalise the marketing messages and offers we send you to make them more relevant and interesting;
• Allow us to compile statistical information and undertake research;

• Maintain the safety of visitors to Brent Cross Town , create a safer environment and reduce the fear of crime;
• Secure the property and premises in Brent Cross Town;
• Detect, prevent and investigate crime, fraud or anti-social behaviour and prosecuting offences, including working with law enforcement agencies; and
• For marketing, advertising and promotional purposes.

Why we can use your personal information

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

• To fulfil our contractual obligations to you, for example, to fulfil the terms of a promotion you have entered or to provide you with information you have requested or to administer a reservation you have requested;
• To fulfil any legal requirements;
• To meet our legitimate interests, for example:
  • to understand how you use our services;
  • to contact you about these services;
  • to develop and tailor our services following our interactions with you;
  • to maintain the safety of visitors, to secure property and premises in Brent Cross Town;
  • to detect, prevent and investigate crime; and
  • to use photographs of  Brent Cross Town (where you are not clearly identified) for marketing, advertising and promotional purposes.
• When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or privacy and the use is proportionate;
• It is necessary for employment purposes;
• It is necessary to protect someone in an emergency; and
• It is necessary for archiving, research or statistical purpose.

We may obtain your consent to collect and use certain types of personal information, for example, in relation to our direct marketing activities or our cookies. You may withdraw your consent to process your personal information at any time by contacting us using the details at the end of this privacy policy.

Who we share personal information with

Where it is in our legitimate interests, because you have contacted us for information or because we have a legal requirement to do so, we may share your personal information with our group company Related Argent Limited or its subsidiary undertakings for the fulfilment of the purpose for which you have contacted us or we have contacted you.

We may also share your personal information with third parties under the following circumstances:

• Service providers and business partners – we may share your personal information with our service providers and business partners who perform marketing services, property management services, security services and other business operations for us. For example, we may partner with other companies to optimise our services, send newsletters and marketing emails, support email and messaging services, manage our CCTV surveillance and security systems and to analyse information;
• Law enforcement agencies, courts, regulators, government organisations, insurance companies or other third parties – we may share your personal information with these parties where it is necessary to comply with a legal or regulatory obligation, to enforce our terms and conditions and policies, or to protect the rights, property, or safety of our website and users, the Brent Cross Estate and visitors, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, professional advice and security; and
• Asset purchasers and joint venture partners – we may share your personal information with any third party that purchases one or more of our properties or the companies with which we might jointly own a property.

Where we store your personal information

Your personal information may be transferred to, stored and processed by us or our service providers in a country outside of the UK. Where that country is not regarded as ensuring an adequate level of protection for personal information under UK law / by the UK Information Commissioner’s Office, we will ensure that we have put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately protected. For example, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

How long we store your personal information for

We will keep your personal information for as long as we have a relationship with you or for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.

Once our relationship with you has come to an end, or the purpose for which we collected your data has been fulfilled, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or for audit or risk management purposes;
• Comply with our records retention policies;
• Defend or bring any existing or potential legal claims;
• Satisfy any legal, accounting or reporting requirements; and
• Deal with any complaints regarding our services.

In some circumstances, we will anonymise your personal information (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.

How we keep your personal information secure

We have put in place appropriate security measures to prevent your personal information 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.

Your rights over your personal information

Individuals like you (called data subjects) have rights under data protection laws to control what information you provide to us and what we can do with it.

You have the right to:

Request access. You can ask for access to information we hold on you. When we receive a request from you in writing (also called a subject access request), we will provide you with a copy of the personal information that we hold about you, unless an exemption applies. Requests are free, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within 30 days, unless your request is large or complicated in which case we may take longer to respond to you. We will notify you if this is the case and keep you updated. If you would like to make a subject access request, please contact us at [email protected].

Request correction. You can ask us to change information you think is incomplete or inaccurate about you, though we may need to verify the accuracy of the new data you provide to us. If you believe that the information we hold about you is incomplete or inaccurate, you can ask us to change it, for example, if we have spelt your name wrong or have an incorrect address. Please contact us at [email protected]. We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Request erasure. You can ask us to delete information we hold about you (the right to be forgotten). In some circumstance you can ask for your personal information to be deleted, for example:

• Where your personal information is no longer needed for the reason it was collected in the first place;
• Where you have removed your consent for us to use your information (where there is no other legal reason for us to use it);
• Where there is no legal reason for the use of your information or it is not in our legitimate interests; or
• Where deleting the information is a legal requirement.

We cannot always delete your information, for example, if there is a legal reason we need to keep it or where you still expect us to deliver a service to you. But we should tell you why we can’t delete what you are asking us to.

Object to processing. You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time. Where we are relying on consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Request transfer. You may request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

For more information on your legal rights, please look at the Information Commissioner’s Office (ICO) website for further information (details below).

Contact us

If you have any questions or concerns about how we collect, use or share your personal information, please contact our Data Protection Officer ([email protected]).

For independent advice about data protection and privacy, please contact the ICO. The ICO oversees how businesses and organisations comply with data protection legislation in the UK:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 / 01625 545745

Email: [email protected]
Website: https://ico.org.uk

Changes to this privacy policy

You may request a copy of this privacy policy from us using the contact details set out above. We may update this privacy policy from time to time. We will post any updates on our website and, where appropriate, notify you by e-mail. All personal information held by us will be governed by the most recent privacy policy posted on our website, so please regularly check back to see any updates or changes.