Data Privacy Notice

1.Introduction

Pembrey Asset Management (“We”) are committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).


2.Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


3.Who are we?

Pembrey Asset Management is a data controller. This means we decide how your personal data is processed and for what purposes. Pembrey Asset Management’s Data Protection Co-ordinator, who is responsible for ensuring our compliance with the GDPR, is:

Ian Griffiths
Pembrey Asset Management Ltd
5th Floor
20 North Audley Street
Mayfair
London
W1K 6WE

+44 (0)783 121 3885
ig@pembreyam.co.uk

All staff are aware of their responsibilities in collecting, using and sharing data.


4.The purpose(s) of processing your personal data

We use personal data for the following purposes:

  • Administration and billing
  • Compliance with property trading regulations
  • Appropriate property trading safeguards and due diligence
  • Legal processing
  • To respond to sales enquiries and setup initial appointments and instructions.


5.The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data.

  • Personal information (such as name, address, date of birth)

  • Passport data including passport number

  • Verification data including but not limited to a utility bill and or bank statements containing name and address
  • Our website uses cookies to track number of visits (see Appendix A).


6.What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR)

Our lawful basis for processing your personal data:

  • Consent of data; (responding to enquiries e.g. email enquiries, cookies)
  • Legal obligation; (administration & billing, compliance regulations, due diligence, legal processing)

More information on lawful processing can be found on the ICO website.


7.Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with our staff as needed

However, we should point out that the Internet is not a totally secure medium and you should acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data, except to the extent we are required to accept such responsibility by law.


8.How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes

  • To fulfil the purposes we collected it for, including for the purpose of satisfying any legal, accounting or reporting requirements.


9.Providing us with your personal data

Much of our data is required for lawful purposes but where our data collection is optional or permission based you are under no statutory or contractual requirement or obligation to provide us with your personal data.


10.Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (this is not an absolute right and only applies in certain circumstances).


11.Transfer of Data Abroad

Please note that we may sometimes transfer your personal data to countries outside the European Economic Area (“EEA”) that may not have the same level of protection as countries within the EEA. If we intend to do this, then, where practical and appropriate, before doing so we will put contractual arrangements in place to ensure the adequate protection of your data and we shall endeavour to ensure that any such contractual arrangements comply with the standards required by the Information Commissioner.


12.Automated Decision Making

We do not use any form of automated decision making in our business.


13.Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.


14.Changes to our privacy policy

A full version of our Privacy Notice can be found here. Any changes we may make to our privacy policy in the future will be posted on and linked to this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.


15.How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Controller Ian Griffiths : ig@pembreyam.co.uk

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.


Appendix A – Website Cookies

A 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.

Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Web browsers may automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer.

This may prevent you from taking full advantage of our website.