Privacy Policy

Date of Issue: 16 June 2020

1. Introduction

Gleeds understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, gleeds.com and approved sub-domains (“our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

The gleeds.com sub-domains are:

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site.

To jump to a specific section of this Privacy Policy, please click below:

1. Introduction

2. Definitions and interpretation

3. Information about Gleeds

4. What does this Policy cover?

5. What is personal data?

6. What are my rights?

7. What personal data do we collect and how?

8. How do we use your personal data?

9. How long will we keep your personal data?

10. How and where do we store or transfer your personal data?

11. Do we share your personal data?

12. How can I control my personal data?

13. Can I withhold information?

14. How can I access my personal data?

15. Our use of Cookies

16. How do I contact you?

17. Changes to our Privacy Policy

2. Definitions and interpretation

In this Policy, the following terms shall have the following meanings:

Cookie

means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in our Cookie Policy.

3. Information about Gleeds

3.1

Our Site is owned by Gleeds Corporate Services Ltd., a limited company registered in England under company number 03547158, whose registered address is 95 New Cavendish Road, London W1W 6XF, and whose main trading address is the same.

3.2

Our Site is operated by Merchant Marketing Group Ltd. whose main trading address is Saxon House, Saxon Wharf, Southampton SO14 5QF

3.3

Our Site is hosted by Microsoft Azure.

3.4

Data Protection Officer:

Name	David Benge
Email address	david.benge@gleeds.co.uk
Postal address	Mr D P Benge
	Data Protection Officer
	Gleeds Corporate Services Ltd.
	Trinity House
	Tunbridge WellsKent
	TN1 1AG
Telephone number	01892 501 300

3.5

We are regulated by the Royal Institution of Chartered Surveyors (RICS).

3.6

We are corporate members of the Association for Project Management (APM).

4. What does this Policy cover?

This Privacy Policy applies only to your use of our Site. our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

5. What is personal data?

5.1

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (in the UK) (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

5.2

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

6. What are my rights?

6.1

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

(1)	The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.
(2)	The right to access the personal data we hold about you. Part 14 will tell you how to do this.
(3)	The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.
(4)	The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 16 to find out more.
(5)	The right to restrict (i.e. prevent) the processing of your personal data.
(6)	The right to object to us using your personal data for a particular purpose or purposes.
(7)	The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
(8)	The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
(9)	Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

6.2

For more information about our use of your personal data or exercising your rights as outlined above, please refer to our Data Subject’s Rights Policy or contact us using the details provided in Part 16.

6.3

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

6.4

Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizens Advice Bureau in the UK, or your country’s supervising authority.

6.5

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 16.

7. What personal data do you collect and how?

Depending upon your use of our Site, we may collect some or all of the following personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see our Cookie Policy on our use of Cookies. We do not collect any ‘special category’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

Data collected	How we collect the data
Identity Information, including: first name, last name, title, age and gender.	Google Analytics.
Identity Information: first name, last name, and title.	Direct from you.
Contact information including: email address	Google Analytics.
Contact information including: email address	Direct from you.
Profile information, including: interests, language, frequency and recency of website use and behaviour flow (how website used).	Google Analytics.
Technical information, including: internet protocol (IP) address, device identifiers, browser type and version, operating system, and source/medium from which directed to website.	Google Analytics.

8. How do we use your personal data?

8.1

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What we do	What data we use	Our lawful basis
Providing, maintaining, and improving our website to meet the needs of our users.	Frequency and recency of website use, behaviour flow (how website used), internet protocol (IP) address, device identifiers, browser type and version, operating system, and source/medium from which directed to website	Legitimate interests.
View statistics.	First name, last name, title, age, gender, interests, language, frequency and recency of website use, behaviour flow (how website used), internet protocol (IP) address, device identifiers, browser type and version, operating system, and source/medium from which directed to website.	Legitimate interests.
Communicating with you.	First name, last name, title and email address.	Valid consent.
Supplying you with information by email that you have opted-in-to (you may opt-out at any time by clicking the unsubscribe link at the bottom of the communication you receive from Gleeds’).	First name, last name, title and email address.	Valid consent.

8.2

Third Parties (including: You Tube and Twitter) whose content appears on our Site may use third-party Cookies, as detailed in our Cookie Policy. Please refer to our Cookie Policy for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

8.3

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 16.

8.4

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

8.5

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

9. How long will we keep your personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Data collected	How long do we keep it?
Identity Information collected by Google Analytics:	12 months
Identity Information received directly from you for the purpose of supplying you with information by email:	Until you opt-out
Contact information collected by Google Analytics:	12 months
Contact information received directly from you for the purpose of business to business communication:	12 months
Profile information collected by Google Analytics:	12 months
Technical information collected by Google Analytics:	12 months

9.3

Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site. We have strict security measures to protect your personal information. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures, such as encryption, to protect your information.

10. How and where do we store or transfer your personal data?

10.1

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

(1)	We share your data within the Gleeds’ group of companies. Where this involves the transfer of personal data outside the EEA, we use specific contracts within the Gleeds’ group that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
(2)	We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
(3)	Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

10.2

Please contact us using the details below in Part 16 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

10.3

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

(1)	Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;.
(2)	Encryption
(3)	Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office (ICO) where we are legally required to do so.

11. Do we share your personal data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

(1)	If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
(2)	In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

12. How can I control my personal data?

12.1

In addition to your rights under the Data Protection Legislation, set out in Part 6, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

12.2

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

13. Can I withhold information?

13.1

You may access certain areas of our Site without providing any personal data at all. [However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

13.2

You may restrict our use of Cookies. For more information, see our Cookie Policy.

14. How can I access my personal data?

14.1

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

14.2

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

14.3

here is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

14.4

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

15. Our use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and approve your experience of our Site and to provide and improve our services. By using our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services and/or parties other than us. Third party Cookies are used on our Site, amongst other things, to identify you, to remember the selected language of the website you chose, and for storing your preferences and other unspecified preferences. In addition, our Site uses analytical services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use our Site. For more details please refer to our Cookie Policy.

16. How do I contact you?

16.1

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Mr D P Benge or David Benge, Data Protection Officer):

Email address	david.benge@gleeds.co.uk
Postal address	Gleeds Corporate Services Ltd.
	Trinity House
	Tunbridge WellsKent
	TN1 1AG
Mobile number	0791 7461 468
Telephone number	01892 501 300

16.2

If you have any questions about our Site, please contact us through Corporate Communications by email at corporate.comms@gleeds.co.uk or by post at

	Corporate Communications
	Gleeds Corporate Services Ltd.
	95 New Cavendish Street
	London
	W1W 6XF

17. Changes to our Privacy Policy

17.1

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

17.2

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 16 June 2020.