Real Estate Investing and Developing with Principles

Privacy Policy

1. Introduction

We care about you, your privacy and how your personal information is used. Here you’ll find details of our privacy policy. Please let us know if your personal information changes.

This notice sets out how we collect, process and hold any personal data that we collect from you, or that you provide, while using boxmill.co.uk and affects some of your rights and obligations. By providing us with your data, you agree to us using your data as follows and confirm to us that you are aged 16 or over.

References in this notice to “we” and “our” refer to Boxmill Developments, 53 Davies St, London, W1K 5JH. Company No. 05032901. We can be contacted on invest@boxmill.co.uk.

2. What Personal Data Do We Collect and Why?

Personal data includes any information capable of identifying an individual. It does not include anonymised data. We only use personal data for the purpose for which it was collected or a reasonably compatible purpose if necessary. If we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We have a number of lawful reasons for using (or ‘processing’) your personal information. One lawful reason is ‘Legitimate Interests’ meaning we can process your personal information if: we have a genuine and legitimate reason AND we are not harming any of your rights and interests. We may process the following categories of personal data about you.

Communication Data includes any communication that you send to us through our website, by email, text, social media messaging, social media posting or any other medium.

We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.

We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. We may also use Customer Data to send you recommendations via email or Facebook adverts or other display advertisements about our goods and services that maybe of interest to you. Our lawful ground for this processing is legitimate interests which is to grow our business.

User Data includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.

We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.

We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.

We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy or your consent.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of advertising. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

Sensitive Data
We do not collect Sensitive Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

3. How Do We Collect Your Personal Data?

Direct interactions
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, signing up for one of our events or when you communicate with us by post, phone, email or otherwise).

Automatically
We may automatically collect certain Technical Data about your equipment, browsing actions and usage patterns as you use our website via cookies and similar technologies. Please see our Cookie Policy for more details about this.

Third parties
We may receive data from third parties such as analytics providers like Google based outside the EU, advertising networks such as Facebook based outside the EU, information providers such as Google based outside the EU, providers of technical,
payment and delivery services, such as data brokers or aggregators.

4. Email Marketing Communications

Our lawful ground for processing your data is either your consent or our legitimate interests (to grow our business).

You may receive marketing communications from us if you (i) made a purchase, (ii) asked for information about goods or
services or (iii) provided your email address and agreed to receive communications and in each case you have not opted out of receiving such communications. Our email communications are sent by Boxmill Developments.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent, however, you can still opt out from receiving these at any time.

We will never share your personal data with any third party for marketing purposes unless we have your express consent.
You can choose to stop receiving future emails at any time by either clicking the unsubscribe link in the email or emailing invest@boxmill.co.uk. If you opt out this does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. Disclosure

We do not sell, trade, or rent your personal data to outside parties.

We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, event ticketing providers, email communication providers, IT service providers, accountants, auditors and lawyers.

Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party’s rights, property, or safety.

We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

International Transfers
Some or all of your personal data may be stored or transferred outside of the European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers or their servers are based outside of the EU. We shall only transfer your personal data to organisations that have provided adequate
safeguards in respect of your personal data.

6. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

7. Data Retention

We will only retain your 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic data about our customers (Contact, Identity, Financial and Transaction Data, etc.) for six years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this data indefinitely without further notice to you.

8. Links to Other Websites

This website may contain links to other websites of interest. However, once you have used these links, please note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement for every website you visit.

9. Cookies

Our website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy

10. Your rights

You have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw
consent.

You can see more about these rights here (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)

If you wish to exercise any of the rights set out above, please email invest@boxmill.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, a reasonable fee may be charged if your request is clearly unfounded, repetitive or excessive or we may refuse to comply with your request in these circumstances.

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.

We will respond to all legitimate requests within 28 days. This may take longer if the request is complex or comprises multiple requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), www.ico.org.uk. In the first instance, please contact us in order that we can try to resolve the matter.

11. Changes to this Privacy Policy

We may change this notice from time to time. You should check this notice periodically to ensure you are aware of the most recent version. Last updated, 31st September 2018.