1. BACKGROUND
1.1 A/O UK 1 Limited with its registered office at 20 Thayer Street, London W1U 2DD and other companies in the A/O PropTech group collect and use certain Personal Data. A/O PropTech is responsible for ensuring that it uses Personal Data in compliance with data protection laws.
1.2 At A/O PropTech, we respect the privacy of our clients, and we are committed to keeping all your Data secure. This Privacy Policy governs the handling of Personal Data by A/O PropTech in the course of carrying on commercial activities.
1.3 We use the following definitions in this Privacy Policy:
• “”A/O PropTech””, “”we”” or “”us”” means A/O UK 1 Limited and other companies in the A/O PropTech group. ” “Personal Data” means any data which relates to a living individual who can be identified from that D-Data and other information owned. It is likely to come into the possession of, A/O PropTech (or their representatives or service providers). In addition to factual information, it includes opinions about individuals and the intentions of A/O PropTech in respect of any individual.
2. THE PRODUCTS AND SERVICES WE PROVIDE
2.1 This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:
• Information we receive through our website (“A/O PropTech Website”); and
• Information we receive through or in connection with the provision of our products and services (“Services”).
3. THE TYPES OF PERSONAL DATA WE COLLECT
3.1 Many of the services offered by A/O PropTech require us to obtain Personal Data about you to perform services we have been engaged to provide. Concerning each of the services described in paragraph 2.1 above, we will collect and process the following Personal Data about you:
• Information that you provide to A/O PropTech. It includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
• Basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
• Any information that you choose to share with us (whether through our websites or otherwise) which may be considered Personal Data;
• Information that we collect or generate about you. That includes (by way of a non-exhaustive list):
• Information about the Services which you have purchased and our interactions with you;
• When you visit A/O PropTech Websites, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by A/O PropTech, please see our Cookie Notice.6
• Information we obtain from other sources.
• We may be supplied with the CV of prospective candidates for roles at both A/O PropTech and our portfolio companies.
• We may from time to time use 3rd party public and private data sources to find out more information about an ‘individual’s employment history
• Anonymised D-Data
• In addition to the categories of Personal Data described above, A/O PropTech will also process further anonymised information and data that is not processed by reference to a specific individual.
4. HOW WE USE YOUR INFORMATION
4.1 Your Data may be stored and processed by us in the following ways and for the following purposes:
• For ongoing review and improvement of the information provided on or operation and security of A/O PropTech Websites;
• To assess your application for our Services, where applicable;
• To set you up as a customer;
• To provide you with our Services
• To understand feedback on our Services and to help provide more information on the use of those products and services quickly and easily;
• To communicate with you to provide you with services or information about A/O PropTech and our products and services;
• To understand your needs and interests;
• For the management and administration of our business;
• In order to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• For the administration and maintenance of databases storing Personal Data; and / or
• We may process business communications traffic data sent and received by us to evaluate our existing or prospective business relationship.
4.2 However, when using Personal Data, we make sure that the usage complies with the law. It allows us and requires us to use Personal Data for a variety of reasons. These include where:
• We need to do so to perform our contractual obligations with our customers;
• We have obtained your consent;
• We have legal and regulatory requirements that we have to discharge;
• We may need to do so to establish, exercise or defend our legal rights or for legal proceedings;
• The use of your data, as described, is necessary for our legitimate business interests, such as:
• Allowing us to effectively and efficiently manage and administer the operation of our business;
• Maintaining compliance with internal policies and procedures; and
• Promoting our business or A/O PropTech Services.
4.3 We will take steps to ensure that the Personal Data is accessed only by employees of A/O PropTech that need to do so for the purposes described in this Privacy Policy.
5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
5.1 We may share your Data within the A/O PropTech group of companies for the purposes described above
5.2 We may also share your Data outside of the A/O PropTech group for the following purposes:
• With our business partners. For example, this could include intermediaries that introduced you to us or through whom you purchased our Services. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• With third party agents and contractors to provide services to us (for example, A/O ‘PropTech’ accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations, and they will only use your Data as described in this Privacy Policy;
• To the extent required by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
• If we sell our business or assets, in which case we may need to disclose your Data to the prospective buyer for due diligence purposes; and
• If we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
6.1 A/O PropTech is a global business. Our operations are spread around the world. As a result, we collect and transfer Personal Data on a worldwide basis. That means that we may transfer your Data to locations outside of your country.
6.2 Where we transfer your Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. About the Data being transferred outside of Europe, for example, this may be done in one of the following ways:
• The European Commission might approve the country that we send the data to as offering an adequate level of protection for Personal Data;
• The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
• In other circumstances, the law may permit us to transfer your Personal Data outside Europe otherwise.
• You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe. Including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data), by contacting us as described in paragraph 11 below.
7. HOW WE SAFEGUARD YOUR INFORMATION
7.1 We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Adequate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
7.2 As a condition of employment, A/O PropTech employees are required to follow all applicable laws and regulations, including data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by an A/O PropTech employee is prohibited and may result in disciplinary measures.
8. HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR
8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:
• The purpose for which we are using it – A/O PropTech will need to keep the data for as long as is necessary for that purpose; and
• Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
9. YOUR RIGHTS
9.1 In all the above cases in which we collect, use or store your Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
• The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party when possible. Please note that this right only applies to Personal Data which you have provided directly to A/O PropTech;
• The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• The right to request that we erase your Data in certain circumstances. Please note that there may be circumstances where you ask us to delete your Personal Data, but we are legally entitled to retain it;
• The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to or ask us to restrict our processing of your Personal Data. However, we are legally entitled to refuse that request; and
• The right to complain with the relevant data protection regulator if you think that we have infringed any of your rights.
9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.
10. DESIGNATED REPRESENTATIVE
10.1 A/O PropTech (UK) ‘LLP’s registered office may be contacted using the following contact information:
11. A/O 1 UK Limited
11.1 Questions & Concerns
If you have any questions or concerns about A/O ‘PropTech’ handling of your Personal Data, or about this Policy, please contact the Data Protection Team using the following contact information:
• Address: 32 Wigmore StreetLondon W1U 2RP
• Mail: dataprotection@aoproptech.com
