We understand that your privacy and security of your personal data is very important. We have many different procedures and controls that we follow to help protect the data we collect about you.
This policy explains what we do with your information and the steps taken to secure it, the way in which we collect your personal data and the rights over your personal data that you possess.
Your Data & Affinity Global Real Estate Ltd
Who we are?
When we say Affinity Global Real Estate Ltd or “we” in this policy we are referring to;
Affinity Global Real Estate Ltd and associated companies with their registered address:
41-43 Brook Street, Mayfair, London W1K 4HJ
It will also include any other business that we add to this group in the future.
Why we collect and keep your data?
Affinity Global Real Estate Ltd Limited, it’s group affiliations, subsidiaries and the services it renders acts as a property Investment business to support the regeneration of mixed use and sole use purpose buildings across the UK.
As part of our service, Affinity Global Real Estate Ltd provides information on our own property projects and general property market information in the form of a subscription-based newsletter.
When you subscribe to our newsletter Affinity Global Real Estate Ltd collect your data with your explicit consent for the specific processes and purposes as outlined in this policy and any other specific and explicit purposes and processes as detailed to you at the time of consent.
Affinity Global Real Estate Ltd collect and process your personal information for certain legitimate business purposes which include some or all of the following:
- To enable us to update you on our property portfolio, our intentions with our regeneration portfolio and new partnerships or contracts within our group.
- To update you on the events that Affinity Global Real Estate Ltd are attending.
- To inform you of regulations, market changes and insights from the Property investment industry.
Affinity Global Real Estate Ltd understand that your interest in the Property Investment and Regeneration industry may change other time. Therefore, we provide an ‘unsubscribe’ option in every newsletter that we send you, so you can update us of your change in interest at any time.
What data do we keep?
When it comes to your Personal Identifiable Information, the data we keep can involve some or all of the following:
- First and last names
- Contact details:
- Registered Email Address
How we use your data?
We use your data through both manual and automated processes to perform actions such as some or all of the following:
- Direct marketing for Affinity Global Real Estate Ltd services.
- Direct marketing in the form of a newsletter and new blog content notification.
How long do we keep your data?
As a responsible data handler, Affinity Global Real Estate Ltd take maintaining up to date and accurate records of your data as a priority. Therefore, we ask that you register with your most up to date contact details and we will follow the following data retention procedure.
- Every 3 years, we will send a details confirmation email that we ask you to reply with an update of your contact details and resubmission of you consent to keep and process your details under the processes and terms outlined in this statement.
- Any bad returns or negative responses we receive shall have all data and details removed from our database.
How do we collect your data?
Affinity Global Real Estate Ltd only collect your data via our newsletter subscription form on our website.
How do we protect your data?
Affinity Global Real Estate Ltd use the latest and most secure mail listing technologies and third parties to protect your data and the information we hold. All Eden Smith’s systems are provided by reputable trusted providers such as Mailchimp using cloud technologies providing tested secure environments with multi-layer security and authentication.
Our web systems and networks are certified and secured with the latest trusted technologies including SSL and TLS and hosted on dedicated servers and networks to protect your data and reduce risks of data breaches and cyber-attacks.
Our consultants are trained on GDPR practices, our policies and procedures that promote being responsible and vigilant in protecting our customers data. These policies include hardware protection and best practices to restrict and prevent access to personal data particularly in high risk areas, anonymisation where applicable and response to data threats and breaches.
Who do we share your data with?
Affinity Global Real Estate Ltd do not share your data with third parties, except in the purpose of storage in our third- party mail list management software, Mailchimp.
You & Affinity Global Real Estate Ltd
As a data controller, the data Affinity Global Real Estate Ltd hold is the owned by you, the data subject. Therefore, you have a number of rights and obligations beyond this statement of what data we hold, your access, consent and obligations around it, we have outlined these below. If you have any questions on how we use your data or would like to take action under your rights below, including Subject Access Requests then please refer to our SAR process at the bottom of this document.
Your data consent to Affinity Global Real Estate Ltd
By entering your details, checking the opt-in selection box and clicking submit on the Affinity Global Real Estate Ltd email subscription form on our website you are providing your consent for Affinity Global Real Estate Ltd to keep and process your data under the processes and terms outlined within this document.
Your declaration to Affinity Global Real Estate Ltd
For Affinity Global Real Estate Ltd to provide an efficient and effective service that benefits you in the best way possible we need to ensure the data we control is relevant and as up to date as reasonably possible. Therefore, when subscribing to our newsletter via the website, you are making a declaration that the information you provide for the uses and processes listed within this document are to the best of your knowledge correct, accurate and true. In doing so you also acknowledge that deliberately given false or misleading information you are liable not only to be withdrawn or dismissed by Affinity Global Real Estate Ltd but also may be liable to legal proceedings against damages caused to Affinity Global Real Estate Ltd’s business.
Your right to Access and to be informed
As a reasonable data controller, Affinity Global Real Estate Ltd provide you with the right to be informed of whether we hold or process your data, that we do so in a fair and transparent way and to have access to the data we hold on you as an individual.
If you would like to raise a Subject Access Request (SAR) then please see our procedure at the bottom of this document.
Your right to rectification, erasure, portability or object.
As the data subject and owner, you also have rights to port the personal information we hold on you, to object to Affinity Global Real Estate Ltd holding your data or processing it and to rectify inaccurate and incorrect data we control. You also hold the right to request for the data we hold to be erased however, this does not provide an absolute ‘right to be forgotten’, as there may be some instances where we are required to maintain basic details and data on you as a subject that will enable us to protect you and provide an efficient service. Examples of such legitimate interest can include some or all the following:
- The need to maintain data records to comply with your marketing preferences to prevent spam and contact by our business to you as an individual.
Affinity Global Real Estate Ltd will provide erasure when it meets some or all the following criteria:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When the individual withdraws consent.
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed
- The personal data must be erased in order to comply with a legal obligation.
If you wish to see further information around your data rights then please look on the information available on the ICO website: https://ico.org.uk/
If you wish to make a request under any of these rights please see the Subject Access Request procedure provided at the end of this document.
Your right to restrict processing and in automated decision making and profiling.
Affinity Global Real Estate Ltd only process your data for sending the mail newsletter, no profiling or automated decision making takes place when we process your data. Any future profiling of decision making would be made at your own discretion and profile selection of what news you wish to receive.
Affinity Global Real Estate Ltds Subject Access Request Procedure
As a responsible data controller Affinity Global Real Estate Ltd provide you with the rights to request information on the data we hold and how we use it in accordance with the rights and purposes outlined in this document.
In addition, Affinity Global Real Estate Ltd take protecting your data that we hold as a priority and to protect you against fraudulent access to your data we have created and outlined our Subject Access Request procedure here within to handle all request procedures you may have regarding your data.
Although Affinity Global Real Estate Ltd will still respond to requests made outside this procedure, such as those made on social media, verbally or via other methods, in most cases those responses will refer you to this procedure below.
All Subject Access Requests and requests to the data we hold on you as an individual under any of the rights outlined in this document must be made to our Data Protection Officer at one of the following addresses:
41-43 Brook Street,
The subject line must include SAR followed by your full name and the body to clearly outline your request, under which rights you wish to make the request and under what grounds you believe the request should be granted.
In order to protect your data, Affinity Global Real Estate Ltd will only grant requests where we have been provided with evidence that you are the data owner we have on record in the form of a photographic identity document such as passport or driving license.
When sending us proof of identity, we recommend that you protect your documents by emailing in a password protected zip file. If you wish to see further support in how to create a password protected zip file, please follow this link: here
The reason we request proof of identity is to allow us to verify that the request is a legitimate request made by the data owner.
All Subject Access Requests will receive a response from Affinity Global Real Estate Ltd within 72 hours acknowledging the request and the necessary actions we will take to grant or respond to the request.
If you have any further questions around our privacy statement, then please feel free to contact us to discuss further