Privacy Policy
INTRODUCTION
This Policy sets out the obligations of Rushbrook and Rathbone Limited registered in the United Kingdom under number 2259486 whose registered office is at Windsor House, Station Court, Great Shelford, Cambridge CB22 5NE “the Company” regarding data protection under General Data Protection Regulation “GDPR”, regarding the collection, processing, transfer, storage, and disposal of personal data. These procedures and principles must be followed at all times by the Company, its employees, agents, contractors or other parties working on behalf of the Company.
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
PROCESSING OF PERSONAL DATA
Roles of the Parties. The parties acknowledge and agree that with regard to the Processing of Personal Data, Rushbrook and Rathbone is the Controller. When Rushbrook and Rathbone receives Personal Data, they will act as data controllers for any activity they undertake in accordance with this Privacy Policy.
Customer’s Processing of Personal Data. Rushbrook and Rathbone shall Process Personal Data in accordance with the requirements of Data Protection Laws and Regulations. For the avoidance of doubt, a Customer’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations. A Customer shall have sole responsibility for the accuracy, quality and legality of Personal Data and the means by which Rushbrook and Rathbone acquires Personal Data.
Rushbrook and Rathbone’s Processing of Personal Data. Rushbrook and Rathbone shall treat Personal Data as Confidential Information and shall only Process Personal Data on behalf of and in accordance with Customer’s documented instructions for the following purposes: (i) Processing in accordance with any Terms of Business(s); (ii) Processing initiated for the use of Rushbrook and Rathbone’s services; and (iii) Processing to comply with other documented reasonable instructions provided by the Customer (e.g., via email) where such instructions are consistent with the terms of this policy.
Details of the Processing The subject-matter of Processing of Personal Data by Rushbrook and Rathbone is the performance of the services pursuant to Terms of Business. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified below. (Details of the Processing)
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
RIGHTS OF DATA SUBJECTS
Rushbrook and Rathbone will, to the extent legally permitted, action a request from a Data Subject to access, correct or delete that person’s Personal Data or if a Data Subject objects to the Processing thereof (“Data Subject Request”).
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
SUB-PROCESSING
The Customer understands that Rushbrook and Rathbone may be required to provide Personal Data to carefully selected suppliers for the purpose of performing services under any Terms of Business. A list of suppliers can be supplied on request.
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
SECURITY
Rushbrook and Rathbone shall maintain appropriate technical and organisational measures for protection of the security (including protection against unauthorised or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorised disclosure of, or access to, Customer Data), confidentiality and integrity of any Personal Data.
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
THIRD PARTY SERVICE PROVIDERS
We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your personal information with them. We provide our service providers with only the personal information they need in order to perform the services we request and we require that they protect this information appropriately and do not use it for any other purpose.
For example, we may rely on a 3rd party service provider to:
• Fulfil your service requests and answer your questions.
• Host our sites and deliver our email or other communications.
• Analyse our data, sometimes combined with data from other sources, to send you communications.
• Conduct research and analyse data to improve our products, services and sites.
• Maintenance requests reported by Tenants / Landlords under any Terms of Business.
• Where services are provided to us by a third party and it is necessary or expedient for us to share information
with such third parties.
• Perform other services that we request.
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
DETAILS OF THE PROCESSING
Nature and Purpose of Processing
Rushbrook and Rathbone will Process Personal Data as necessary to perform the services pursuant to any Terms of Business, and as further instructed by a Customer in its use of the services.
Duration of Processing
Rushbrook and Rathbone will Process Personal Data in accordance with the Privacy Policy for the duration of the delivery of services, unless otherwise agreed upon in writing, and for such time after as is required by law.
Categories of Data Subjects
The Customer may submit Personal Data to obtain the Services, the extent of which is determined and controlled by the Customer in its sole discretion, and which may include, but is not limited to, Personal Data relating to the following categories of data subjects:
• Prospects, customers, business partners and vendors of Customer.
• Employees or contact persons, agents, advisers, sub-contractors and freelancers of Customer’s prospects, customers,
business partners and vendors.
• Customer’s Users authorised by Customer to use the Services.
Type of Personal Data
The Customer may submit Personal Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to the following categories of Personal Data: –
• First and Last Name
• Title
• Position
• Employer – Contact information (company, email, phone, physical business address)
• ID data
• Professional life data – Personal life data
• Connection data – Localisation data
• Financial Data – Bank Details
Data subjects
Rushbrook and Rathbone may collect Personal Data which falls under the following categories:
• Prospects, Customers, Customer’s customer data (landlord and tenants), Business Partners and Vendors
Categories of data
The Customer may submit Personal Data to Rushbrook and Rathbone which may include, but is not limited to the following categories of Personal Data:
• First and Last Name
• Title
• Position
• Employer
• Contact information (not limited to company, email, phone, physical business address)
• Professional life data
• Personal life data
Processing operations
The objective of Processing of Personal Data is the performance of Rushbrook and Rathbone services pursuant to any Terms of Business or any other contractual agreements between the parties.
-------------------------------------------------------------------------------------------------------------------------------------------------------------------
CONTACT
Should you need to contact us regarding the above, please email our team on enquiries@rushbrookrathbone.co.uk