Privacy Policy

 

DEFINITIONS (A-Z)

In this Privacy Policy:

the term "DP Act" refers to currently applicable data protection legislation effective in the United Kingdom; 

the term "Managing Agent" refers to Keith Perry Chartered Surveyor, of 17a High Street, Hucknall, Nottingham NG15 7HJ, UK, who is the agent appointed by SST to manage its interests in SST House;

the term "Resident Caretaker" refers to the individual currently appointed by SST to act as caretaker of SST House, and who resides there as part of his / her duties.

the term "Site" refers to this ssthouse.org website;

the term "SST" refers collectively to Sinclair Sandwich Thanet Limited and S S T Management Limited; the registered office of each of those companies is at: Origin Two, 106 High Street, Crawley, West Sussex RH10 1BF, UK; and

the term "SST House" refers to the properties at Sinclair House, Sandwich House and Thanet House, all in the London WC1H postal district.

1. INTRODUCTION

Each of Sinclair Sandwich Thanet Limited and S S T Management Limited is committed to protecting and respecting your privacy. SST will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

This Privacy Policy (together with the SST Terms of Use, and any other documents referred to below) sets out the basis on which any personal data which SST collects from you, or that you provide to SST, will be processed by or on behalf of SST. Please read the following carefully to understand SST's views and practices regarding your personal data and how SST will treat it. By visiting and then using the Site, you are accepting and consenting to the practices described in this Privacy Policy.

For the purposes of the DP Act:

  • the data controller is Sinclair Sandwich Thanet Limited or (where applicable) S S T Management Limited; and
  • SST's nominated representative is the Managing Agent.

2. INFORMATION WHICH SST MAY COLLECT ABOUT YOU

SST may collect and process the following data about you:

  1. Information you give to SST. You may give SST information about you by filling in forms on this Site or by communicating with SST or the Managing Agent by phone, e-mail or otherwise. This includes information you provide when you register to use the Site, subscribe to SST's service, when you report a problem with or through the Site, and all information that you provide to or through the Managing Agent. The information which you give to SST or the Managing Agent may include (without limitation) your full name, residential or commercial address, e-mail address and home, work or mobile telephone number(s). Further, you may provide us with contact details for anyone authorised to act on your behalf (if applicable), as well as updates to any of the foregoing types of personal information.

  2. Information which SST collects about you. With regard to each of your visits to the Site, SST may automatically collect the following information:

    1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and computer or device platform; and

    2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to and through the Site (including date and time), and download errors.

  3. Information which SST receives from other sources. SST may receive information about you if you use any of the other services which SST provides; in this case, SST will have informed you when SST collected that data that it may be shared internally and combined with data collected on the Site. SST also works closely with third parties (including, for example, the Managing Agent, other professional advisers and commercial suppliers) and will from time to time receive information about you from them.

 If you contact SST, a record may be kept by SST or the Managing Agent of that correspondence, including any information provided or required to resolve your enquiry or issue.

Neither SST nor the Managing Agent collects or stores any bank account or other payment account information relating to you.

3. COOKIES

The Site uses 'cookies' to distinguish you from other Site users. This use of cookies helps SST to provide you with a good experience when you browse the Site. For detailed information on the cookies which SST uses and the purposes for which SST uses them, see SST's Cookie Details statement.

4. USES MADE OF THE INFORMATION

SST and the Managing Agent use information held about you in the following ways:

1. Information which you provide. SST will use this information:

- to carry out SST's obligations arising from any contracts entered into between you and SST, to apply the detailed provisions of applicable leases, lease regulations, other legal requirements and regulations, and to provide you with the information and services that you request from SST;

- to notify you about changes to SST's services; and

- to ensure that content from the Site is presented in the most effective manner for you and for your computer.

2. Information which SST collects about you. SST will use this information:

- to administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

- to improve the Site, to ensure that content is presented in the most effective manner for you and for your computer;

- to allow you to participate in interactive features (if any) of the SST service, when you choose to do so; and

- as part of SST's efforts to keep the Site safe and secure.

 3. Information which SST receives from other sources. SST may combine this information with information you provide to SST and information which SST collects about you. Depending on the types of information which SST receives, SST may use this information and the combined information for the purposes set out above.

5. DISCLOSURE OF YOUR INFORMATION

a) Sinclair Sandwich Thanet Limited and S S T Management Limited may share your personal information with each other.

b) SST may also share your information with selected third parties, including:

  1. its agents (including but not limited to the Managing Agent), its professional advisers and commercial suppliers, as well as its employed personnel and (if applicable) any sub-contract staff - in each case, for the performance of any relevant contract which SST enters into with them or with you; and

  2. analytics and search engine providers (if any) that assist SST in the improvement and optimisation of the Site.

c) Further, SST may disclose your personal information to other third parties:

  1. in the event that SST sells or buys any business or assets, in which case it may disclose your personal data to the prospective seller or buyer of such business or assets;

  2. if either Sinclair Sandwich Thanet Limited or S S T Management Limited, or substantially all of either of their assets, is acquired by a third party, in which case personal data held by the acquired company about its leaseholders (as well their tenants) and its suppliers will be one of the transferred assets;

  3. if SST is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the SST Terms of Use, or other relevant agreements; or

  4. to protect the rights, property, or safety of Sinclair Sandwich Thanet Limited or S S T Management Limited, their respective contract partners or others. This could - without limitation - include the exchange of information with other organisations for the purposes of fraud protection and credit risk reduction.

6. WHERE SST STORES YOUR PERSONAL DATA

All information which you provide to SST is stored on secure servers operated by or for: (i) an SST entity; (ii) the Managing Agent; or (iii) one of their respective suppliers or service providers. 

More specifically:

  • - the Site (i.e., SST's production website) is located in Paris, France and is hosted under contract by gandi.net ;
  • - electronic mail received by the Site is received in Paris, France;
  • - SST's development website is located in Manchester, UK and is operated under contract by evocat.net; and
  • - electronic mail sent by ssthouse.org is sent via evocat.net in Manchester.

.

The Managing Agent and the Resident Caretaker have access to laptop computers on which a copy of some of your data may be stored. Those computers are password-protected, protected by current anti-malware software, kept secure when not in use, and not accessible to unauthorised third parties. 

.

The data that SST's Managing Agent or one of SST's and the Managing Agent's respective suppliers or service providers collects from you may be transferred to, and stored at, a destination outside the European Economic Area (the "EEA"). It may also be processed by staff operating outside the EEA who work for SST or for one of its suppliers. Such staff may be engaged in, among other things, the provision of IT support services.

By submitting your personal data to SST or the Managing Agent on its behalf, you agree to any transfer, storing or processing of such data as described in this section 6.

7. PASSWORDS AND TRANSMISSION OF INFORMATION

Where SST has given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. SST asks you not to share any such password with anyone else.

Although SST will do its best to protect your personal data (for example, through the application of technical measures such as "https" security on web pages), SST cannot guarantee the security of your data transmitted to the Site; any transmission is therefore at your own risk. Once SST has received your information, SST will use strict procedures and security features to try to prevent unauthorised access.

8. YOUR RIGHTS

The DP Act gives you a number of specific rights, which include the following:

  • - a right to data erasure;
  • - a right to make a “subject access request” (i.e., a request for a copy of the data which we hold about you); your right of access can be exercised in accordance with the DP Act;
  • - a right of correction (or, where appropriate, erasure) of data which we hold about you where this is inaccurate;
  • - a right to data portability;
  • - a right to withdraw your future consent for SST to process your personal data;
  • - a right to contact and make enquiries of SST's data protection co-ordinator, who can be contacted as follows:

- by email: via the "Contact Us" option, which appears in the menu on the left side of all pages on the Site; or
- in writing: Data Protection Co-ordinator, Sinclair Sandwich Thanet Limited (or where applicable S S T Management Limited), Origin Two, 106 High Street, Crawley, West Sussex RH10 1BF, UK; and

  • - a right to complain to the Information Commissioner's Office (sometimes referred to as the 'ICO').

If you exercise any of the above-listed rights, please be aware that in order to protect your privacy, SST may require you to undergo some verification tests to make certain that SST is dealing with you (rather than with an impostor).

You also have the right to be informed of the matters stated in this Privacy Policy.

You have the right to ask SST not to process your personal data for marketing purposes. However, it is not SST's practice (and SST does not intend) either to use your data for any such purpose or to disclose your information to any third party for any such purpose. You can exercise your right to prevent such processing by contacting SST and so informing SST or the Managing Agent; to do that, please use the "Contact Us" option which appears in the menu on the left side of all pages on the Site.

9. LINKS TO OTHER SITES

From time to time the Site may contain links to and from the websites of other parties and entities. If you follow any such link to a third party website, please note that third party websites have their own privacy policies, and that SST does not accept any responsibility or liability for these policies. Please therefore check these policies before you submit any personal data to any third party website.

10. SST's LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

There are three legal bases upon which SST collects, processes and transfers your personal data, as described in this Privacy Policy:

  • Contract - to consider potential or to fulfil actual contracts with you. If you are not able to provide this data, it is possible that SST will be unable properly or fully to perform its side of any contract with you;

  • Legitimate Interest - in order to consider potential or to fulfil actual contracts with you and others, SST needs to collect and process personal data about you; and

  • Consent - also, SST may rely on your specific consent for it to use your personal data. You may revoke any such consent at any time, as specified in the second paragraph of section 11 (Data Retention + Termination of Processing) immediately below, and subject to the provisions of that paragraph.

11. DATA RETENTION + TERMINATION OF PROCESSING

SST and the Managing Agent normally hold and process your data for a maximum of seven (7) years from the date when you last interacted with SST's services.  In this context, to “interact” with SST's services means being (or contemplating being) a leaseholder or tenant of one of the SST House properties, or a supplier to SST. 

In any event, SST will stop the processing of your data where you ask SST to do so by contacting SST (i) by email, via the "Contact Us" option, which appears in the menu on the left side of all pages on the Site; or (ii) by post, addressed to The Data Protection Co-ordinator, Sinclair Sandwich Thanet Limited (or - where applicable - S S T Management Limited), Origin Two, 106 High Street, Crawley, West Sussex RH10 1BF, UK. You may also address such requests in writing to the Managing Agent.

The only circumstances in which SST will not stop the processing of your data following any such request from you are where SST has either (i) a legal obligation or (ii) a legitimate interest to continue processing your data.

12. MANAGING AGENT

The Managing Agent is an independent business and SST is not its only customer; the Managing Agent operates its own website, on which you may find a copy of its own privacy policy statement.

13. CHANGES TO SST's PRIVACY POLICY

Any future change which SST may make to this Privacy Policy will be posted on this Site page and, where appropriate, notified to you by e-mail or otherwise. SST encourages you periodically to check this page on the Site in order to see whether any updates or changes have been made to this Privacy Policy.

13. CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed, and should be addressed either: (i) via the "Contact Us" option, which appears in the menu on the left side of all pages on the Site; or (ii) via the Managing Agent in writing to the address shown in the Definitions section above.

 

Date last revised: May 31, 2018.