Privacy policy

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We at London Central Portfolio Ltd and LCP Capital Investments Limited (collectively, “LCP”) respect your concerns about privacy. This Privacy Policy describes the types of consumer personal information we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

London Central Portfolio Limited is registered in England, Company No. 02494797. It is an Appointed Representative of Clear Insurance Management Ltd (authorised and regulated by the Financial Conduct Authority in respect of general insurance business). Registered office: LCP House, Ogle Street, London W1W 6HU. Group VAT Reg No. 182 2473 10. LCP Capital Investments Limited is registered in England, Company No. 09634810. It is an Appointed Representative of F2 Capital Ventures LLP (authorised and regulated by the Financial Conduct Authority) in respect of investment business. Registered office: LCP House, Ogle Street, London W1W 6HU.

This Privacy Policy applies to the general practices of LCP with respect to its processing of consumer personal information in accordance with the General Data Protection Regulation 2016/679, as well as to LCP’s website.

Information we obtain

Information you provide to us

In respect of clients, tenants and in certain cases, permitted occupiers of property, the personal data which LCP may collect and use usually includes:

•        First name and surname

•        Date of birth

•        Contact details (work/personal email address, mobile or telephone numbers)

•        Work/home address

•        Financial information such as bank account information, income and savings

•        Source of wealth

•        Political exposure

•        Education and employment information

•        Photographic representation (passports and other identification paperwork)

•        Information for research, surveys and marketing activities

 

Please note that you are not required to provide any personal information to use the website. However, if you provide your contact details (name, address, telephone and email address) either through the website or at a meeting with us, these details will be stored in the LCP database and may be further processed for the purposes set out in this Privacy Policy. For information about how to change or update your contact details, or to exercise any of your other rights, please see the “Your Rights and Choices” section of this Privacy Policy.

In addition, depending on the nature of our relationship with you and the purpose for collecting it, we may process further information such as your personalised property criteria, property ratings and reviews. We limit the collection and processing of personal data to information that we need in order to meet our contractual obligations, a legal obligation or in furtherance to a legitimate interest. Where applicable, we may ask for your express consent.

Information we obtain by automated means

When you visit our website, open our emails or interact with LCP, we may collect certain information (including IP addresses) by automated means, such as cookies, web server logs, web beacons and JavaScript.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our website may use cookies (such as HTTP and HTML5 cookies) and Flash cookies, as well as other types of local storage (such as browser-based or plug-in-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our sites or other websites and online services.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We also may record information such as the address of the web page that referred you to our website and the IP address of the device you use to connect to our website. We may log information about your interaction with the website, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with our sites.

We may use third-party web analytics services on our website, such as those of Google Analytics. These service providers help us analyse how visitors use the website. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about Google Analytics, and how to opt out, please click here. The providers of third- party plug-ins and widgets on our website, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the website and your interactions with the plug-ins and widgets. We may also receive information you have made available to those third party services, including the geographic location of your mobile device and other information about you (such as name, email address, locale, time zone, languages, and certain security settings information) and your contacts on those services. This information is subject to the privacy policies or notices of the third-party providers of the plug-ins and widgets.

How we use the information we obtain

Depending on whether you are a client, a business associate or third-party supplier of services, a contracted party, an estate agent, a fund enquirer or a journalist, we may use the information described above for purposes necessary for the performance of our contractual obligations to you or to comply with our legal or regulatory obligations. We may also process your personal data for the purposes of our legitimate interests provided those interests do not override any of your own interests, rights or freedoms, which may include processing for marketing, business development and management purposes. Specifically, we may use your information to:

provide products and services to you;

perform transactions that you request;

incorporate your contact details into the LCP database;

send you promotional materials, newsletters and other communications relating to our products and services;

create and manage your account;

communicate with you about, and administer your participation in, special events, promotions, offers, surveys, focus groups and market research (where applicable, if you have not opted out of receiving such communications);

respond to your enquiries;

provide aggregate statistical information and perform data analyses (including market and consumer research, economic impact analyses, demographic analyses and anonymisation and aggregation of personal information);

operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analysing our products and services; managing our communications; and performing accounting, auditing and other internal functions)

protect against, identify and prevent fraud, copyright infringement, unauthorised use and distribution of protected content and other criminal activity; and

comply with and enforce applicable legal requirements, relevant industry standards and our policies.

In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as: (i) customising our users’ visits to our website; (ii) delivering content tailored to our users’ interests and the manner in which our users browse our website, and (iii) managing our sites and other aspects of our business.

We also may use the information in other ways for which we provide specific notice at the time of collection. We do not obtain or record personal information about our visitors’ online activities over time and across third-party websites.

Information we share

We do not disclose personal information we obtain about you outside LCP, except as described in this Privacy Policy. We may share your personal information with our affiliates and subsidiaries. We also may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorise these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with applicable legal obligations.

Examples of these service providers include entities that provide web hosting, analytics and email list management services.

We also may disclose information about you: (i) if we are required to do so by law or legal process; (ii) for the purposes of, or in connection with, any legal proceedings, or otherwise for the purposes of establishing, exercising or defending any legal rights;

(iii) to law enforcement authorities or any regulator or other government entities based on a lawful disclosure request; or (iv) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer personal information we hold about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, spin-off, dissolution or liquidation).

Information collected through third-party plug-ins and widgets on the website (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and LCP is not responsible for those providers’ information practices.

Direct Marketing

From time to time, we may send information to you regarding our products and services, upcoming events and promotions and other information that may be of interest to you. For information about how to unsubscribe from marketing communications, please see the “Your Rights and Choices” section of this Privacy Policy. We do not share your details with any other marketing organisations.

Your Rights and Choices

You may change your contact details at any time, or request that we remove your details from our database, or instruct us not to use the personal information which you have provided to us for marketing purposes, by notifying us by email. We may still continue using your personal information to meet our contractual or legal obligations in compliance with the legislation.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. Alternatively, to update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us. After you unsubscribe, we will not send you further promotional emails. However, we may retain your personal information to meet our legal or contractual obligations, or for the purposes of our legitimate interests. We may also continue to contact you as reasonably necessary in connection with the administration of your account.

You may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information. Where provided by law, where we relied on your express consent, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

Should you wish to make a data subject request under the GDPR or complain about the way we use your personal data or handle your request pursuant to your rights under the GDPR, please contact our Data Compliance Officer in the first instance by writing to us at our registered office address or via email at contact.ceo@londoncentralportfoio.com. Our Data Compliance Officer will investigate the matter and aim to address your concerns or respond to your request within 30 days of your initial communication. You can also lodge a complaint with the Information Commissioner’s Office (ICO). For more information, please visit ico.org.uk.

Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

How we protect personal information

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

Modern Slavery Act 2015 Statement

This statement is made on behalf of London Central Portfolio Limited (“LCP”) pursuant to the Modern Slavery Act 2015 (“the Act”) and comprises our slavery and human trafficking statement.

LCP is fundamentally committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. As a supplier of property-related services, we aim to provide our clients with high levels of service, and to uphold all relevant standards of professional conduct in our sector and accept nothing less from our suppliers. We recognise that there is a very small risk for slavery or human trafficking to occur in the supply chain. We also recognise that we should be vigilant in identifying and reporting to the authorities any possible exploitation in the form of modern slavery or human trafficking when we visit properties and/or deal with third parties. 

We are committed to taking all appropriate steps to ensure that slavery or human trafficking is not taking place in any of our supply chains.  We review our existing business and supply chains for the risks of slavery and human trafficking; we review and revise as needed our procurement processes; and we disseminate relevant information as part of awareness training to our employees. We will not support or deal with any business knowingly involved in slavery or human trafficking.

This statement is issued on behalf of the Board of Directors and will be reviewed annually.

Children's privacy

Our website is not directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on our website.

Links to other websites and apps

Our website may provide links to other websites and apps for your convenience and information. These websites and apps may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

Updates to our Privacy Policy

This Global Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices.

How to contact us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at contact.ceo@londoncentralportfolio.com

 

 

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