Ediston Properties Limited, together with Ediston Investment Services Limited (“We”, “Ediston”, “us” or “our”) are committed to protecting and respecting the confidentiality, integrity and security of personal information which has been entrusted to us.
Ediston processes data in respect of the following groups:
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how Ediston complies with its responsibilities under applicable data protection laws, including, when and to the extent in force, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulations 2003 (or a successor regulation) (“Data Protection Laws“). Please read this policy carefully.
For the purpose of the Data Protection Laws, the data controller of your personal information is Ediston Properties Limited (registered number 04910369) of 1 St Andrew Square, Edinburgh EH2 2BD.
We hold personal data about you which you provide by corresponding and/or contracting with us, investing in funds which we manage, through our website or by some other means (such as via a business card, social media (such as LinkedIn) or other public sources).
We may collect the following information from you:
We will use personal data which you provide us as follows:
We will use your personal data in the following circumstances:
Such processing may include the use of your personal data for the purposes of sending you electronic marketing communication, in relation to which you can at any time unsubscribe by following the instructions contained in each marketing communication.
Where you provide personal information to us on our website, you will be asked if you consent to us sending marketing materials to you. If you give your consent, we are processing your personal information based on your consent. Where we collect personal information about you (such as via a business card, social media (such as LinkedIn) or other public sources), we are processing it on the basis that in doing so, we are pursuing our legitimate business interests. In either case, you have the right to object at any time to us processing your personal data for marketing purposes.
We try to ensure that the information we hold about you is accurate and kept up-to-date by contacting you at regular intervals. However, if in the meantime you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us at 1 St Andrew Square, Edinburgh, EH2 2BD as soon as possible. We will promptly correct or delete any information found to be incorrect.
We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of personal data we hold, and against the accidental loss of, or damage to, personal data.
We will not disclose personal information we hold about you to any third party except as set out below.
We may disclose personal data to third parties who are providing services to us, including IT, marketing (if you agree) and data cleansing, or for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.
We may also disclose personal data we hold to third parties:
We will not transfer any personal data we hold about you to a country outside the European Economic Area (“EEA”) without notifying you in advance in writing. If we transfer any data outside the EEA, we will provide you with details of the country to which data is being transferred, along with details of the measures we have put in place to protect it (which you may see a copy of, on request).
We will only retain your personal 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. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.
Please note that you may contact us at any time at 1 St Andrew Square, Edinburgh, EH2 2BD and ask for your details to be removed.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In certain circumstances, by law you have the right to:
If you wish to exercise any of the rights set out above, please contact Gregg Carswell or the Data Privacy Manager in writing.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, 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 try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk.). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We may make changes to this data protection policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer back to this page regularly to see any changes or updates to this policy.
If you have any queries about this policy or your data, or you wish to submit an access request or raise a complaint about the way your personal information has been handled, please do so in writing and address this to Gregg Carswell or the Data Privacy Manager at Ediston Properties Limited, 1 St Andrew Square, Edinburgh EH2 2BD or by email to firstname.lastname@example.org.
Ediston Properties Limited is a limited company registered in England and Wales (registered number 04910369) and its registered office address is Level 4, Dashwood House, 69 Old Broad Street, London, EC2M 1QS. It has its principal place of business at 1 St Andrew Square, Edinburgh EH2 2BD.
Ediston Investment Services Limited is a limited company registered in England and Wales (registered number 09626337) and its registered office is Level 4, Dashwood House, 69 Old Broad Street, London, EC2M 1QS. It has its principal place of business at 1 St Andrew Square, Edinburgh EH2 2BD. Ediston Investment Services Limited is authorised and regulated by the Financial Conduct Authority.
© Ediston Properties Limited. All rights reserved.
18 May 2018