Fiducia Capital understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.fiduciacapital.com (“our Site”) and as described in Parts 5 and 6, below, we do not collect personal data about you unless you contact us or register. Any personal data we do collect will only be used as permitted by law.

Fiducia appreciates the privacy of all persons who supply personal information to us. This privacy notice describes how we collect, store and use personal information, and provides information about the rights of the individual whose information we hold.

This notice is issued on behalf of Fiducia Capital and its subsidiary entities, and it applies to both personal information supplied to us either by an individual or by others.

We will only process personal information where we have a lawful reason for doing so. This is likely to be one of the following:

the processing is necessary for the performance of a legal agreement (such as a lease or service supply contract) in which you, or a person professionally connected to you, are a party to – or in connection with the establishment of such an agreement;

the processing is necessary in order for us to comply with our legal obligations (such as anti-money laundering legislation);

the processing is necessary for the pursuit of our legitimate business interests (including recruitment, delivery of our services and development of our business); and

processing is necessary for connection with the establishment and exercise of legal claims.

Further information on the ways in which we collect and process personal data is set out in the category sections below. The rights of all data subjects are set out in the second part of this notice.

Website Visitor Data

We do not use, collect or perform any analysis on visitors to our website, other than basic information such as the number of visitors to the various parts of the site. We do not retain any means of identifying individual visitors. We do not use cookies for any purpose other than to identify the volume of visitors to various parts of our website.

Email Enquiries

If you contact us using the enquiry email address on our website, we will use any personal information contained in your email (including your email address) solely to deal with your enquiry. We will not use your information for any other purpose, such as marketing unless you authorise us to do so. We will periodically review our email enquiry files and delete those emails where there has been no ongoing correspondence for more than 12 months.

Our security systems automatically check for emails that contain viruses or malware.

Business Contacts

As is common within the business services environment, we process personal information about individual business contacts to get in touch with individuals and to maintain a database of professional contacts. Such information is likely to includes: name, email address, job title, telephone number, area of business, job role and other relevant business-related information. For the most part, such information will have been supplied by the individual concerned (for example, in an email or via a business card) or a person or entity authorised by him or her to supply the information to us.

We will use such information solely for the purpose for which it was supplied and to enable contact to be maintained for future relationships and business development. In some circumstances, we may need to use the information supplied to carry out regulatory searches, such as money laundering checks.

In order to fulfil the requirements for which the information was supplied, we may need to disclose the information to a third-party processor (for example a solicitor if the information was supplied in connection with a property transaction).

Tenants

We supply our tenants with a privacy notice regarding our use of their personal data, either directly or through the managing agents retained by us and our clients. Tenant privacy notices are issued as an addendum to leases and other tenancy agreements, usually by our managing agents. To view our standard tenant privacy notice, click on the link below.

Job Applicants

We use third-party recruitment consultants to assist us in our recruitment process, who supply us with personal data that candidates have supplied to them. We will therefore be acting as processors of candidates’ data. In these cases, the consultants will have sought the consent of candidates to supply personal data to us.

Where we have received personal information directly from candidates, we may supply this to recruitment consultants, acting as data processors for us, to facilitate candidate assessment. The consultants will only use the personal information we share with them for the purpose for which it has been supplied and will destroy the personal information at the end of the recruitment process.

In all instances we will:

only use candidates’ personal data for the purpose for which it has been supplied, i.e. candidate application and assessment; and

destroy the personal information of recruitment candidates at the end of the recruitment process, unless its retention has been specifically agreed (for example, in case another role becomes available in the future).

Candidates will be required to provide us with documents evidencing the consent of referees for their personal data, such as contact details, to be supplied to us.

Service Suppliers

We process the personal information of individuals who supply services directly to us or to our clients, either through us or via our managing agents. This information is likely to include name, email address and telephone number collected and maintained to procure and administer services from suppliers and to manage relationships with them.

We may need to share this information with others in order to facilitate the service supply. This is likely to include managing agents and letting agents and other service suppliers jointly engage on a project. We may also need to supply the information to property occupiers in order to arrange appointments for service delivery.

Employees

We process the personal information of our employees for a variety of purposes relating to their employment. We provide each employee with a privacy notice setting out these purposes and their rights as data subjects.

Complaints

If we receive a complaint, we set up a file which will ordinarily contain information on the identity of the complainant and other relevant individuals. We will use this information solely to address the subject matter of the complaint and to correspond with those concerned. This may include disclosing personal information of the complainant to other parties involved, where it is not possible to handle the complaint on an anonymous basis.

All our files are stored in a secure environment and may only be accessed by our authorised personnel. We will retain personal information provided in relation to a complaint for six years following the closure of the complaint, following which the need for it to be retained will be reviewed. Unless an ongoing need for the personal data to be retained is established, then the personal information will be destroyed.

Under applicable legislation, all data subjects have a number of rights in connection with the processing of their personal data. These rights, and the ways in which we address them, are set out below.

The right to be informed of the way in which your data is used details of this are set out above, depending on which category your data falls into.

The right of access you have the right to have copies of the personal data we hold on you. If you wish to do so, please contact us using the details set out at the end of this notice. We will provide a copy of the personal data we hold as soon as is practicable and, in any case, within one month of your request. If you submit unreasonably repetitive requests, we have the right to charge a fee or refuse to respond.

The right to rectification You may require us to rectify inaccurate personal data, to complete it where it is incomplete or to correct it where it is misleading as to any matter of fact. If you wish to do so, please contact us using the details set out at the end of this privacy notice. We will make the necessary adjustments as soon as is practicable and, in any case, within one month of your request. If on review, we are satisfied that the personal data is accurate, we will notify you of this and of your rights to refer the matter to the Information Commissioner. Please note that if you submit unreasonably repetitive requests, we have the right to charge a fee or refuse to respond.

The right to erasure your may request that your personal data is erased, provided the personal data is no longer necessary for the purpose for which it was collected and processed. If you have supplied personal information in connection with a legal agreement, this right may only arise when that agreement has been discharged and may be subject to regulatory retention requirements.

The right to restrict processing you can request that we restrict the processing of your personal data where:

you have contested the accuracy of your personal data;

we have unlawfully processed your data;

we no longer need your personal data, but you need us to keep (but not process) it in order to establish, exercise or defend a legal claim;

you have objected to our processing of your data and we are considering whether we have overriding legitimate grounds for doing so.

The right to data portability you have the right to be provided with a copy of the personal data that you have supplied to us and which we process by automatic means, to enable you to reuse for your own purposes. We will respond to such requests by supplying the data in a commonly usable, structured form as soon as practicable and, in any case within one month of your request. If you request it, we will do our best to supply the data directly to another organisation that you authorise to receive it.

The right to object. You may object to the processing of your data where:

the basis for processing is the processor’s legitimate or performance of a task in the public interest, including profiling;

the processing is for direct marketing, including profiling;

the processing is for scientific/historical research and statistics.

We do not consider that our processing of personal data falls within any of the circumstances listed above. However, if you believe that to be the case, please contact us using the details set out at the end of this privacy notice.

Rights in relation to automated decision making and profiling you have the right to object if you believe that your data is being processed in a manner which involves:

the basis for processing is the processor’s legitimate or performance of a task in the public interest, including profiling;

automated decision making (i.e. without human involvement); including

profiling (automated processing to analyse or predict things about you – such as behaviour, health, personal preferences.

We do not undertake such profiling activities.

Transfer of Personal Data outside the EEA and Switzerland

We do not as a matter of routine move personal data outside the European Economic Area and Switzerland. In the event that this becomes necessary we will put in place arrangements for the relevant personal data to be securely treated in accordance with standards set out by the European Union or, where applicable, the EU-US Privacy Shield.

If you wish to contact us in connection with the data subject rights set out above, please email: info@fiduciacapital.com.

For further information on the rights of the data subject, visit the website of the Information Commissioner’s Office: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/