- The personal data We may collect or that you may provide when you access or use the Company’s website located at http://www.hillwoodinvestmentproperties.com (the “Hillwood Site”).
- Our practices for collecting, using, maintaining, protecting, disclosing, and otherwise processing that personal data.
- We collect offline or on any other Company or affiliate apps or websites, including websites you may access through the Hillwood Site.
- You provide to or is collected by any third party.
1. Personal Data We Collect and How We Collect It
We collect personal data from and about users of the Hillwood Site:
A. Personal Data You Provide to Us
All Users. When you use the Hillwood Site, you have the option of voluntarily contacting Us through (i) the “Contact” page on the Hillwood Site; or (ii) through “Contact” links provided for Our various divisions and projects. By contacting Us, you are consenting to Our replies to your communications. Communicating with Us through these customer service channels allows Us to answer questions and provide you with assistance. We do not retain personal data you provide though the “Contact Us” page or links for general marketing purposes. By voluntarily contacting Us, you may provide information by which you may be personally identified, such as name, email address, telephone number, an identification number, or location data by which you may be contacted online or offline (“personal data”). We may retain records and copies of your correspondence if you contact Us. If you do not want to provide Us with personal data, you may simply choose not to contact Us online.
Customers. We collect personal data from customers when they contact us through the means noted above. Customers of Hillwood have the ability to access additional functionality on the Hillwood Site.
We do not perform behavioral tracking, such as using these technologies to collect data about your activities over time and across third-party websites, apps, or other online services.
2. How We Use Your Personal Data
We are allowed to use your personal data if, and to the extent that, We have your consent to use your data for a specific purpose, or if another legally permitted reason applies, in particular if and to the extent that such processing is necessary:
- for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
- for compliance with a legal obligation to which We are subject;
- in order to protect your vital interests or those of another natural person;
- for the performance of a task carried out in the legitimate and considerable public interest or in the exercise of official authority vested in Us;
- to prevent threats to state or public security or to prosecute criminal offences;
- processing is necessary for the purposes of the legitimate interests of Ourselves or the third party, except where such interests are overridden by the interests or fundamental rights and freedoms of yourself or another data subject that require the protection of personal data, in particular when the data subject is a child.
In particular, We may use the personal data We collect for one or more of the following purposes:
- to fulfill or meet the purpose for which you provided such personal data. For example, if you share your name and contact data to request a price quote or ask a question about our products or services, We will use that personal data only to respond to your specific inquiry. If you provide your personal data to purchase a product or service, We will use that data only to process your payment and facilitate delivery. However, to the extent legally permissible, We may also save your data to facilitate your new product orders or process returns, or as otherwise required to fulfill the contract We have with you;
- to the extent that it is required to enforce any claim We may have against you or to defend Ourselves in the event that a claim is brought against Us;
- to create, maintain, customize, and secure your account with Us;
- to process your requests, purchases, transactions, and payments as well as to prevent transactional fraud;
- to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve Our responses;
- to personalize your website experience;
- to help maintain the safety, security, and integrity of the Hillwood Site, products and services, databases and other technology assets, and business.
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We will not collect additional categories of personal data or use the personal data We collected for materially different, unrelated, or incompatible purposes without providing you with previous notice.
We will not use your personal data to conduct any automatic decision-making (profiling).
We will not retain your personal data for longer than necessary to fulfil the purpose for which it was collected; comply with any legal, regulatory, or reporting obligations; or otherwise fulfil a legitimate public interest or legal grounds to retain such data.
3. Disclosure of Your Personal Data
We may disclose information that does not constitute personal data without restriction.
In addition, We may disclose personal data that We collect and/or you provide, to the extent legally permissible:
- if and to the extent required for any purposes of legitimate processing, to Our subsidiaries, affiliates and Our and their employees, contractors, service providers, and other third parties We use to support Our business and website and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which it was disclosed to them.
- to the extent it is not inconsistent with the purpose of the processing, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company about the Hillwood Site users is among the assets transferred.
- to fulfill the purpose for which you provide it.
- with your consent.
- if and to the extent it becomes necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- if and to the extent it becomes necessary to protect the rights, property, or safety of Our customers, tenants, employees, or others. If necessary and legally permissible, this may include exchanging data with other companies and organizations for the purposes of public safety or fraud protection.
However, We will only transfer your personal data outside of the European Economic Area or United Kingdom (as applicable) if the transfer is compliant with the GDPR and/or the UK GDPR (as applicable) and all other applicable laws (e.g., as applicable where the transfer is to a country which has been assessed by the European Commission as ensuring an adequate level of protection for the concerned personal data and/or where the transfer is based on adequacy regulations pursuant to Article 45 of the UK GDPR [as applicable]).
4. Exercising Your Rights Regarding Your Personal Data
You have certain legal rights in respect of your personal data including the right to information (Article 15 of the GDPR), right to rectification (Article 16 of the GDPR), right to be forgotten (Article 17 of the GDPR), right to restriction of processing (Article 18 of the GDPR), right to data portability (Article 20 of the GDPR), right to object (Article 21 of the GDPR) as well as right to lodge a complaint (Article 77 of the GDPR).
In particular your rights include a right to:
- object to the use of your personal data. When you exercise this right, We will either stop using your personal data or explain to you why We are unable to do so.
- to restrict Our use of your personal data, so that it can only continue subject to restrictions.
- ask for a copy of the personal data that We hold about you, subject to certain exemptions, e.g. if the personal data were recorded only because they may not be erased due to legal or statutory provisions on retention, or only serve the purposes of monitoring data protection or safeguarding data and providing information would require a disproportionate effort, and appropriate technical and organizational measures make processing for other purposes impossible.
- ask Us to update or correct inaccurate information about you.
- require Us to delete (or stop making active use of) your personal data if it is no longer needed for the purpose for which it was collected (except if We are legally allowed to keep your personal data, e.g. if the deletion would conflict with retention periods set by statute or contract or if, in the case of non-automated data processing, deletion would be impossible or would involve a disproportionate effort due to the specific mode of storage and if your interest in deletion can be regarded as minimal).
- where Our processing is based on consent, the right to withdraw that consent.
- request a copy of the personal data that you provided to Us so that you can use it for your own purposes.
- object to any decision that significantly affects you being taken solely by a computer or other automated process.
- to require personal data that you have provided to the Company and that are processed by using automated means, based on your consent or the performance of a contract with you, to be provided to you in machine-readable format so that they can be "ported" to a replacement service provider.
If you wish to exercise any of these rights, please contact HIP@hillwood.com. The fulfilment of such requests may be subject to further exceptions or exemptions permitted under the GDPR, the UK GDPR or other data privacy laws (in which case We will inform you about the occurrence of such exception or exemptions if you contact Us to exercise your rights – for example, We will not be able to comply with your request to delete your personal data if and to the extent We are under legal obligation to retain such personal data).
We will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.
5. Data Security
We have implemented appropriate (technical and organizational) measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. In this respect, We in particular take into account the relevant technical guidelines and recommendations from the UK's Information Commissioner's Office. All data you provide to Us is stored on secure servers behind firewalls and encrypted. However, the safety and security of your data also depends on you. We urge you to be careful about giving out personal data in public areas of the Hillwood Site such as message boards. The personal data you share in public areas may be viewed by any user of the Hillwood Site. Unfortunately, the transmission of personal data via the internet and mobile platforms is never completely secure. We are not responsible for the circumvention of any privacy settings or security measures We provide.
All information appearing on the Hillwood Site is provided for your convenience only.
All artwork, videos, images, content, text, and other materials appearing on the Hillwood Site are subject to copyrights owned by Company, its affiliates, or its licensors. Any reproduction, retransmission, or replication of all or part of any materials, content, image, video, or recording found on the Hillwood Site is expressly prohibited unless the Company or copyright owner of the material has expressly granted its prior written consent to reproduce, retransmit, or republish the material. All rights reserved.
The names, trademarks, service marks and logos of the Company appearing on the Hillwood Site may not be used in any advertising or publicity, or otherwise to indicate the Company’s sponsorship of, or affiliation with, any product or service, without the Company’s prior express written permission.
The Hillwood Site may contain links to social media sites that are not under the control of the Company. These links are provided as a convenience to you and the Company is not responsible for the content, policies, or security protocols of any such sites. The inclusion of any such link within the Hillwood Site does not imply any approval or endorsement of such linked sites or their operators.
7. Children Under the Age of 13
The Hillwood Site is not intended for children under 13 years of age, and We do not knowingly collect personal data from children under 13. If We learn that We have collected or received personal data from a child under 13 without verification of parental consent, We will delete that data. If you believe We might have any data from or about a child under 13, please contact Us at HIP@hillwood.com.
8. Contact Information
You have a right to file complains with the relevant data protection authority. Contact details of the UK's Information Commissioner's Office can be found at https://ico.org.uk/.
A list of other data protection authorities within the European Economic Area is available at https://edpb.europa.eu/about-edpb/board/members_en.