BROADGATE QUARTER PRIVACY NOTICE

Last updated: 17 April 2023

Who are we and what is this notice?

Buffalo Propco 1 and Buffalo Propco 2 (“Buffalo”) are Revantage Group companies which, along with Revantage Real Estate LTD (“Revantage“), manages and operates the Broadgate Quarter Campus located at: 9 Appold Street, London EC2A 2AP and 1 Snowden Street EC2A 2DQ, and the Broadgate Quarter website: https://www.broadgatequarter.com.

Where we say “we“, “us“, or “our” in this notice we are referring to either or both of Buffalo and Revantage.

If you visit the Broadgate Quarter website or the Broadgate Quarter Campus or if you interact with us in some other way, we may collect and process some of your personal information (also known as ‘personal data’). This privacy notice explains:

We are a ‘controller’ of your personal information, this means we decide how your personal information is processed and protected.

1) What information we collect and process about you

We may collect and process the following information about you:

Information that you give us

This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar), while applying for a role with us, attending one of our events or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with us; information about your professional role, background and interests; and information relating to an onsite event you want to attend (for example your dietary requirements or accessibility support needs).

Information that our website and other systems collect about you

If you visit our website it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on our site that you visit.

Our website may also download “cookies” to your device, please see our cookies policy for more information.

If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.

CCTV and onsite security at Broadgate Quarter Campus

The Broadgate Quarter Campus has closed circuit TV systems which may record you if you visit our premises, for security and safety purposes. Revantage is responsible for the operation of our CCTV system and works with specialist providers who act as data processors to operate the system. Cameras are placed both externally and internally in public and common areas. Signage on site will indicate where cameras are placed.

Our tenants and other occupiers may have their own CCTV or similar security systems in operation in their units. We are not responsible for the operation of these systems and any questions about them should always be directed to the relevant occupier.

You may be issued with a security pass when you work at or visit our premises, these passes will, if scanned, enable us and our security partners to identify your location, arrival and exit times on our premises. Our tenants/occupants may make additional security arrangements which involve the collection of your personal information.

Other information

We may also collect information from other sources. For example:

  • if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship;
  • we sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations; and
  • we (and/or our partners) record whether or not you attend events you have booked through our website.

2) How and why we use your information

For each of our uses of your personal information we must have a legal basis. We may use your information in the following ways and for the following purposes:

What we do with your information and why we do it Our legal basis for what we do
To operate, manage, develop and promote our business and, in particular, our relationship with you or the organisation you represent (if any) and related transactions. Usually the legal basis is our legitimate interests but sometimes we will require information about you in order to fulfil a contract we have with you, or to enter into a contract with you.
To send you emails containing marketing information, which we believe you will find relevant and of interest. This will usually be done with your consent but in some cases, we may rely upon our legitimate interests (but you will always have the right to tell us to stop sending you marketing information).
To operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations. Here we rely upon our legitimate interests.
To protect the security of our premises. This will normally be done in our legitimate interests but sometimes security related processing will be necessary for compliance with a legal obligation or to protect the vital interests of an individual.
To ensure that you are able to safely access and move around our premises. This will normally be done in our legitimate interests but sometimes security related processing will be necessary for compliance with a legal obligation or to protect the vital interests of an individual.
To protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes. Here we rely upon our legitimate interests.
To comply with our legal and regulatory obligations and bring and defend legal claims. This will normally be done in our legitimate interests, but sometimes security related processing will be necessary for compliance with a legal obligation.

Legitimate interests

We will only process your personal information as necessary so that we can pursue the purposes described above. If we are relying upon our legitimate interests to use your personal information we will only do so if we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.

Security reviews – more information

We may from time-to-time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. These reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties.

Asking us for more information

We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information.

If you are uncertain why we have requested information from you, please feel free to contact us (see below for details), with your query.

3) When we share your information and with whom we share it 

Access to your information

Your information, including your emails and other communications may be accessed by persons other than the member of staff you sent them to for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left our organisation).

Sharing your information

We may disclose personal information about you, where reasonably necessary for the various purposes set out above:

  • to the other members of the Revantage Group;
  • to your colleagues in the Revantage Group;
  • to service providers who host our website or other information technology systems (including our CCTV system) or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
  • to partners who run any events that you sign up to through our website;
  • to a person who takes over our business and assets, or relevant parts of them; or
  • in exceptional circumstances, such as to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or where we are required by law to disclose.

International Transfers

These disclosures may involve transferring your personal information overseas. If you are dealing with us from within the European Economic Area or the UK, you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws. In those cases, where we transfer personal data to other members of our group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission and the UK Government. Please contact us (see below) if you would like to know whether any such agreements are in place or, if so, to see a copy (aspects of which may be redacted for confidentiality and security reasons).

4) How long we keep your information for

We will delete the information that we hold about you when we no longer need it (usually information is retained for a maximum of six years and often for shorter periods). CCTV footage is generally stored for a 30-day period, after which it is overwritten. Specific information about our record retention policies is available on request. Please  contact us (see below).

Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.

5) Your rights

You may have a range of legal rights in relation to the personal information that we hold about you, and to some related information, under data protection law. These include the right to:

  • access your personal information;
  • require any inaccurate personal information to be corrected or deleted;
  • object to our use of your personal information for direct marketing purposes at any time; and
  • object to our processing of some or all of your personal information (and require them to be deleted) in some circumstances.

If you wish to exercise any of these rights, please contact us as set out below.

You can also lodge any concerns you may have about our processing of your personal information with the office of the UK Information Commissioner (www.ico.gov.uk).

6) Contact us

We welcome questions, comments and requests regarding this privacy statement and our processing of personal information. Please send them to dataprivacy@revantage.eu FAO Alice Tickle. We will identify whether Revantage or Buffalo, is the lead data controller for your query and ensure that it is directed to the appropriate person for a response.

If you wish to contact Revantage directly, please contact dataprivacy@revantage.eu.  

7) Changes to this policy

Any changes we make to this privacy statement in the future will be posted to our website https://www.broadgatequarter.com and also available if you contact us. Please check back frequently to see any changes.