June 2024
As you may know, the General Data Protection Regulation, also known as the GDPR, came into force on 25 May 2018. For purposes of the GDPR, we want to make you aware that we hold personal data about you, explain why we hold it and let you know whom you can contact if you have any questions. The purpose of this communication is to provide you with that information.
Under agreements you may have entered into with us, you may have consented to our use of personal data provided to us in order for us to meet our contractual obligations to you and for us to meet certain legal requirements. Those consents will remain in place under the GDPR (subject to certain rights you may have, as explained below).
In support of the transparency and information provisions of the GDPR, we also wanted to provide you with the following information:
Data Controller Identity: LondonMetric Property Plc (company number 7124797), with a registered office at One Curzon Street, London W1J 5HB, is the controller of the personal data described in this Notice.
Types of Data: The primary personal data we may hold about you includes your name, contact details, title and position information and professional background and experience details, including your relationship with LondonMetric. We may also hold personal data provided to us to verify your identity. We obtain this personal data from you and we may also obtain it from third party sources, such as governmental records, news and social media reports and databases of corporate information (publicly available and by subscription).
Purposes: We keep your personal information to maintain our contractual and compliance records (including our background screening, insider trading, market abuse and anti-bribery and corruption registers), to discharge our contractual relationship with you and to assist us with our investment and business development planning.
Recipients: To fulfil these purposes, we may share your data with our LondonMetric affiliated entities; our service providers who provide corporate, share registry, asset management, investment and similar services; our professional and legal advisors; applicable public, governmental, administrative or judicial entities; and/or other parties involved in judicial/legal matters with us.
Sensitive Data: We may process sensitive data about you for these purposes. We keep to a minimum the amount and types of sensitive data we process about you. We may need a separate consent to process such sensitive data, and if this is the case we will seek one from you.
Legitimate Interests: We hold this information for the legitimate interests of our maintaining a contractual, business and compliance relationship with you for the purposes outlined above.
International Transfers of Data: At present, your personal data is maintained by us within the EEA. As indicated above, we use service providers to undertake certain services relating to our investors, and these service providers may hold your personal data outside of the EEA. If this is the case, your personal data will continue to be adequately protected in accordance with the GDPR.
Retention Periods: In order to keep our corporate records regarding investors up to date and consistent with many of our regulatory requirements, the information you provide may be held for an indefinite period, subject to our duty to delete data we no longer require when this is the case.
Data Subject Rights: You have a number of rights under the GDPR. These rights (which are subject to conditions) include the right of data portability (for us to help you move your data to someone else at your request), the right to object to the processing of your personal data, the right to require us to update and correct your data, the right to require erasure of your data, the right to obtain a restriction on processing of your personal data, the right for you to review the personal data we hold and the right to withdraw your consent to the processing of your personal data. Should you withdraw your consent, we may continue to process your personal data if we are able to do so in accordance with the GDPR. You also have the right to lodge a complaint with a data protection supervisory authority in the Member State where you live or work or where you feel a GDPR issue concerning you has arisen.
Other Statutory or Contractual Information: As explained above, we hold your personal data for the purposes of fulfilling legal obligations to you and/or to meet our compliance obligations. We would not be able to meet these commitments if we did not hold your personal data.
We hope you will find this document useful, but if you have any questions or concerns, you should not hesitate to contact the Company Secretary at the registered office as set out above or at [email protected].