Privacy Notice

PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how ESH collects and processes your personal
data in our business dealings with you either directly in our day to day communications or through
your use of this website, including any data you may provide through this website when you:

• Visit our website;
• Log into our tenant portal;
• Complete a contact us form;
• Provide us with your personal data by any other means.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements any other previous notices and does not replace them.

Personal data, or personal information, means any information about an individual from which that
person can be identified. Anonymous data is therefore not treated as personal data.
We have grouped together different kinds of personal data which we may collect, use, store and
transfer as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital
  status, title, date of birth and gender
• Contact Data includes address, email address and telephone numbers
• Financial Data includes bank account and payment card details where you pay us for a service
• Marketing and Communications Data includes your preferences in receiving marketing from us
  and your communication preferences
• Profile Data includes any of your usernames and passwords, enquiries made by you, services we
  provide to you, or buy from you, your preferences and feedback to us
• Transaction Data includes details about payments to / from you and other details of services you
  have purchased from us
• Technical Data includes your IP address, your login data, browser type and version, time zone
  setting and location, browser plug-in types and versions, operating system and platform and other
  technology on the devices you use to access this website
• Usage Data includes URL data, web analytics data in relation to how you arrived at our sites,
  from where, what search items you looked for, which pages you visited on our sites, the duration
  of your visits and such other information about how you use our website or portal and the
  information provided on them, and how you use our products and services so as to assist us to
  improve our website offering to you
• Complainant Data includes name, address, email address, telephone number.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by
  filling in forms or by corresponding with us online on our tenant portal, by post, phone, email or
  otherwise or in person. This includes personal data you provide when you:
  • As an agent, when you work with us in connection with property services;
  • As a vendor, communicate with us in connection with change in tenant data;
  • As a vendor or purchaser, provide us with your AML identification documentation;
  • As a tenant, create an account or update your data on our tenant web portal;
  • As a supplier, perform any contract with us by supplying goods or services to us and
    providing us with a supplier account name and other details;
  • As a customer, contract with us for management services or agency services as
    applicable
  • As a business contact, when we meet at a business event or when you contact us or we
    contact you to establish or further develop business relations and identify mutual
    opportunities.
• Automated technologies or interactions. As you interact with our website or tenant portal, we
  may automatically collect Technical Data about your equipment, browsing actions and patterns.
  We collect this personal data by using cookies, and other similar technologies. Please read our
  cookie policy on our website.
• Third parties or publicly available sources. We may receive personal data about you from
  various third parties and public sources including as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google absed outside the EU;
    • search information providers such as Post Code look up services by the
      Royal Mail based inside the EU.
  • Contact, Financial and Transaction Data (if you are a tenant) from vendors
  • Identity and Contact Data from publicly availably sources such as the Electoral Register
    based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Please see the table below to find out about the lawful bases that we rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to our consumer (non-business) contacts via email or SMS. Whether you are a consumer or business contact, you have the right to withdraw consent to marketing at any time by contacting our DPM (​contact details above​) or by clicking the unsubscribe link in the relevant emails.

We have set out below a description of all the ways we plan to use your personal data, and which of
the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
We may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data.

The law requires us to meet additional conditions for collecting, storing and using personal data that is
considered ‘special category’ data. We have in place an appropriate safeguard which we are required
by law to maintain when processing such data. We may process special categories of personal
information in the following circumstances:

• Health data in relation to recording of accidents or other physical harm to any of our staff for
  health and safety and other record keeping purposes
• Health data to record absences and reason.

CRIMINAL OFFENCE DATA

We only process criminal offence data when we are at the outset of an employment relationship or
when we are doing our due diligence on prospective new sub-contractors or other third parties who
will be on our or our client’s sites.

CONSENT
Generally we do not rely on consent as a lawful basis for processing personal data about you. If we
do, then it is necessary for you to know that you can withdraw your consent at any time by letting us
know.

We do not need your consent in circumstances where we use special categories of your data in
accordance with our legal obligations (and we set this out in our written policies).
On rare occasions we may ask for your explicit (written) consent to use certain special categories of
data. If we do this we will make sure you have a detailed explanation of the data we need and why.
This will enable you to make an informed decision whether you wish to consent.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around our
direct marketing and advertising. We will always give you options to determine how we use your
personal data in this regard.

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which services and offers
may be relevant for you (we call this marketing).
You will receive relevant marketing communications from us if you have opted in for such marketing
or if you have previously bought services from us and, in each case, you have not opted out of
receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company
outside of ESH LLP for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the
opt-out / unsubscribe links on any marketing message sent to you at any time.

COOKIESA cookie is a small piece of data sent from a website and stored on the user’s computer by the user’s
web browser while the user is browsing. Our cookies are “analytical” cookies and allow us to count
the number of visitors and distinguish you from other users of our website, which helps us to provide
you with a good experience when you browse our website and also allows us to improve our site.
These cookies are typically deleted from your device once the browsing session is terminated.
You can choose to block cookies that we may deliver to your device through settings on your
web-browser; however, in doing so you may not be able to access or utilise all aspects of our website
or tenant portal.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact our DPM.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties identified in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our
  assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
  happens to our business, then the new owners may use your personal data in the same way as
  set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions.

We share your personal data within ESH LLP. This will not involve transferring your data outside the
European Economic Area (EEA).
Some of our external third parties may be based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an
  adequate level of protection for personal data by the European Commission. For further details,
  see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the
  European Commission which give personal data the same protection it has in Europe. For further
  details, see European Commission: Model contracts for the transfer of personal data to third
  countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the
  Privacy Shield which requires them to provide similar protection to personal data shared between
  the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact our DPO if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.

How long will you use my personal data for?
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 for personal data, 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.
Details of retention periods for different aspects of your personal data are available in our retention
policy which you can request from us by contacting our DPO.
In some circumstances you can ask us to delete your data: see Request erasure below for further
information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this information indefinitely
without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
•  Request correction of your personal data.
•  Request erasure of your personal data.
•  Object to processing of your personal data.
•  Request restriction of processing your personal data.
•  Request transfer of your personal data.
•  Right to withdraw consent.

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and your
rights before we process your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can obtain further information about
how we assess our legitimate interests against any potential impact on you in respect of specific
activities by contacting our DPM.
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take preliminary pre-contractual steps at your request before
entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in our group acting as joint controllers and which provide property management and
managing agency services.

EXTERNAL THIRD PARTIES

• Rox – Outsourced payroll
•  ICB – Life cover/workplace pensions
• Comis Technology – IT services
• Paragon Health Services – Healthcare
• AEJ Management Ltd, Shield Security, Venture FM, ICL Ltd, G24 – security services

Please note that from time to time these Specific Third Parties are subject to change without prior
notice.

YOUR LEGAL RIGHTS
You have the right to:

11.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

11.1.1 NO FEE USUALLY REQUIRED 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.

11.1.2 WHAT WE MAY NEED FROM YOU 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.

11.1.3 TIME LIMIT TO RESPOND 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.

11.2 Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.

11.3 Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of your
request.

11.4 Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts on your fundamental rights
and freedoms. You also have the right to object where we are processing your personal data
for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.

11.5 Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us
to erase it; (c) where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use it.

11.6 Request the transfer of your personal data to you or to a third party. We will provide to you,
or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract
with you.

11.7 Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw
your consent.

If you wish to exercise any of the rights set out above, please contact our DPM.