Cubitt House respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites, when we send you other digital or non-digital marketing communications or other digital media and also tells you about your privacy rights and how the law protects you.
You acknowledge and agree that your personal data may be processed in accordance with this policy. Without this, we will be unable to provide you with certain marketing communications.
Important Information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Cubitt House collects and processes your personal data through your use of our websites or when we send you other digital or non-digital marketing communications, including any data you may provide through our websites when you sign up to one of our newsletters, purchase a product or service or take part in a promotion or competition, as an example.
Our websites are not intended for children (under the age of 18 years) 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.
Cubitt House is made up of different legal entities. This privacy notice is issued on behalf of the Cubitt House Group so when we mention “Cubitt House”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Cubitt House Group responsible for processing your data. The Cubitt House Group are the controller and responsible for all websites.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.
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 first on, firstname.lastname@example.org.
Your duty to 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 following the procedure on our latest communication to you or by emailing email@example.com
Our websites 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. When you leave our websites/apps, we encourage you to read the privacy notice of every website you visit
The 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 e.g. your name, or date of birth.
- Contact Data e.g. your address or telephone number.
- Financial Data e.g. bank account details.
- Transaction Data e.g. other details of products and services you have purchased from us.
- Technical Data e.g. your login data, browser type , geo-location, IP addresses and version.
- Profile Data e.g. your username and password, your interests or preferences.
- Usage Data e.g. information about how you use our websites/apps, products and services.
- Marketing and Communications Data e.g. your preferences in receiving marketing from us.
- We do not collect any Special Categories of Personal Data about you. For details about this category please visit the ICO website and search for ‘Special Category Data’.
We may record or monitor calls, emails, text messages and other correspondence for training purposes to improve the quality of our offering and to prevent and detect fraud.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you:
You may give us your information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our websites;
- subscribe to our service or publications;
- sign in to our Wifi platform;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions:
How we use your 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 or regulatory obligation.
- Where you have specifically requested to be kept informed about our products, services and promotions etc
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our latest communication to you will tell you how to unsubscribe, or you can email firstname.lastname@example.org and your request will be processed.
Promotional offers from us
We may use your 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.
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 signed up to one of our newsletters, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Cubitt House Group of companies for marketing purposes.
Each time we send you a new marketing communications message, you will be given the opportunity to opt-out easily and securely, by confirming the preferences you would like to unsubscribe from and then clicking the one time unsubscribe button. Alternatively contact us at any time at email@example.com we will organise the unsubscribe process on your behalf.
Change of purpose
We will only use your personal data while necessary for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your personal data
We may have to share your personal data with service providers or as required by law. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, relating to Cubitt House and in accordance with our instructions. We may need to share your personal data with the following categories of third parties:
- Service providers and suppliers assisting with our business activities, business associates, customers, payment service providers, hosting providers, providers of IT support, advertising platforms, providers of booking systems, providers of cloud-based software or services used by us, accounting firms and law firms;
- Ombudsman, regulators, public authorities and security organisations, such as the police, HM Revenue & Customs and the Information Commissioner’s Office, to the extent required by law, regulation or court order.
- Companies in the same group as us;
- Current, past and prospective employers, recruitment and employment agencies, trade and employer associations and professional bodies and educators and examining bodies;
- Financial organisations and advisors, credit reference agencies, debt collections and trading agencies, and tenants;
- Family, associates and representatives of the person whose personal data we are processing;
We do not transfer your personal data outside the European Economic Area (EEA).
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 team members, 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
How long will you use my personal data for?
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.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, to include the right to:
- Request access to your personal data.
- Send a copy of your personal data to another data controller.
- 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.
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org
No fee usually required
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.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
Cubitt House, 57 Gloucester House, Gloucester Place, Marylebone, London, W1U 8JH
Tel: 020 7881 9840
Company No. 05399542 (UK)
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