Any reference to “you” or “your” refers to anyone whose personal information we process.
2. What is personal data?
Personal data consists of all information that tells us something about you. This may include, for example, names, contact details, date of birth, bank account information or information about your needs or circumstances that enable us to identify you.
Certain personal data are classified as "special" data under data protection legislation. These include information on health, racial or ethnic origin, religious conviction or political opinion and sexual orientation.
Such information is more sensitive and requires further actions / reasons for collecting, storing or using such information.
3. What personal data do we collect?
We will collect your full name and contact details (such as phone number, email address and postal address)
from you when you hire us. In addition, if we provide our services to you or on your behalf, and if we are required by law, we will collect information pertaining to you, which will include at least one form of photo identification (such as passport, driving license or other ID document) and a form of documentation that shows where you live.
We will also verify whether you have relatives or associates working for Savills IM so that we can consider potential conflicts of interest and, as far as they exist, how these should be treated in accordance with our obligations under laws and ordinances. Depending on the services we provide to you (or on your behalf) we may also collect additional personal information as described below.
When you hire Savills IM as an individual investor, we will collect the information needed to identify you to meet the requirements to counter money laundering and terrorist financing. If the investor is a legal person such as a company or foundation, we may need to collect personal information about representatives and other principals / stakeholders of the legal entity.
If you subscribe to share information about research, news or other market updates from us, we will collect, in addition to the above, details about the industry in which you work and what kind of content you would like to share.
4. How we use your personal information
What legal basis do we have for managing data?
According to applicable data protection laws, we only have the right to use your personal information in cases where we have legal basis for the treatment.
Our processing of your personal data is based on the following legal bases;
When processing is necessary for purposes related to Savills IM, or third party legitimate interests, provided that your interests or fundamental rights and freedoms do not contemplate these interests, including:
In the event that you hire us to provide portfolio management, we may share your personal information with external lenders to the extent that it is necessary for us to fulfil our obligations to you, to arrange financing for you and for to carefully manage and advise you in your real estate investments.
In case you hire Savills IM, we will collect and store your personal data in order to maintain a register of investment holdings to comply with relevant laws and regulations.
Other processing of your personal data:
We will share personal data with the legislators, state or governmental organizations, law enforcement agencies, as well as the courts, tribunals and arbitration tribunals that will, from time to time, be required to fulfil our obligations arising from laws and regulations;
When we use external service providers who process personal information on our behalf in order to provide us with services. This includes providers of IT systems and IT consultants as well as external reference or screening organizations for the purpose of detecting and preventing crimes.
If there is a need for us to fulfil our obligations to you, we may share your personal information with any or all of the people working in the Savills Group.
We will store your personal information in our CRM systems and use them to provide marketing related services provided by Savills IM and similar to the services you hired us to provide and which we believe may be useful to you from time to time. You may at any time decline the receipt of the information.
Other recipients of personal data
What happens if you do not provide us with the information we request?
We need some information to fulfil our legal obligations. For example, we may need identity documents from you to fulfil our anti-fraud and money laundering obligations. If you do not provide the necessary information to fulfil these purposes, we will not be able to fulfil our agreement with you and may be prevented from providing services to you or to continue providing certain services to you. If such a situation arises, you will be notified of this when we collect information from you.
5. How we keep your information safe
The security of personal data is very important for us and we have taken measures designed to prevent
unauthorized access to your personal information, including but not limited to:
All personal data is stored in data centres, which have systems and on-site protection to protect against unauthorized access, as well as other external factors that could harm your personal data. There are strict eligibility requirements in place and the access is limited to those persons whose access is strictly necessary.
We ensure that access to personal data for Savills IM employees and employees or other persons working within the Savills IM Group is limited on a demand basis. Education is provided to Savills IM employees and workers who need access to personal data.
6. How long do we store your personal information?
The time during which we store your personal information will vary depending on the type of service you have requested. The storage period may be longer than the time during which we provide you services if it is by law or regulation that we have a duty to store personal data for a long time or in cases where we may need to store the information due to legal claims.
7. Transfers of personal data outside the EU / EEA
We may transfer, store or process your personal data in locations outside the United Kingdom and the European Economic Area (EEA). In cases where the countries where your personal data have been transferred does not have the corresponding privacy data provided under laws of the United Kingdom, we will ensure that appropriate safeguards are in place.
We will take one of the following safeguards:
8. Your rights in relation to your personal data
You have a number of rights in relation to your personal information, which includes the right to:
If you would like to exercise any of your rights, please contact firstname.lastname@example.org.
9. Complaints and contact details
If you have complaints about how we use your personal information, please contact us via email@example.com who will try to resolve your case. If we cannot find a solution, you are entitled to bring your complaints to the Information Commissioner’s Office in the United Kingdom. If you need further information on how to contact the Information Commissioner’s Office, please inform us via firstname.lastname@example.org.