PRIVACY POLICY

Last updated 6 August 2018.

Savile Bay Management LLP (Florida, USA registration no. 804598) (“We”, “Our”, “Us”, “Savile Bay”) are committed to protecting and respecting your privacy.

This privacy policy (the “Policy”) sets out the types of personal data we collect and use when you access and visit www.savilebaymiami.com (the “Website”) and how we may use that data.

  1.     Introduction

This Policy covers our collection, processing and use of personal data when you use any of our Website.

When you supply any personal data to us we have legal obligations towards you in the way we use that data.  For ease of reading, we have divided this Policy into several sections:

  1.     Introduction
  2.     What is personal data and what do we collect
  3.     How and why do we use/share your personal data
  4.     For how long do we keep your personal data
  5.     Security
  6.     Your Rights
  7.     Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Policy supplements other notices including our Cookies Policy and is not intended to override or replace them.

By visiting or otherwise using our Website, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law.  Where these changes are significant we will endeavour to let users of the Website know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.

Please note that our Website is not directed at children under the age of 13 (each “Child” together “Children“) and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at www.savilebaymiami.com and request that we cease processing data about your Child.

  1.     What is Personal Data and what do we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.

Data we collect from you when you use the Website

Voluntary Provision of Data

When you voluntarily supply your personal data to us, for example where you; use the Website to upload or send personal data (by filling out a form, subscribing to our updates and publications concerning our property development projects or similar activities in which you volunteer data about yourself), contact us by post, telephone, email or SMS; report a problem with our Website; we may collect, store and use the personal data that you disclose to us.

More particularly, we may collect information about your contact details if you subscribe to receive update e-mails from us about our projects and plans.The personal data we collect from you may include your email, first name, surname, address and telephone number – but this will depend on precisely what details you volunteer to us as you interact with the Website.

Should you become a client of Savile Bay Management LLP as a result of your interest in our projects and property developments, we will require you to sign an engagement letter which sets out the terms of our engagement with you.   This engagement letter will also contain terms which set out how we may use your personal data in order to enable us to deliver our services to you.

Automated Collection of Data

We may also collect personal data about you when you visit the Website through the use of technologies such as cookies. The following are examples of data we may collect:

We use the data described above for several different reasons. Firstly we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.

Third Party Resources

We also use the services of third parties such as Google Analytics Solutions to help us to collect various data about you and the way that you use the Website in order to enable us to monitor website traffic and to better understand how users use our website.

Where we use cookies to deliver these kind of general traffic-monitoring services, the delivery of those cookies will not be subject to your consent – as we have a legitimate interest in monitoring user activity in this way. However, if you wish to remove the Google Analytics cookie from your computer you can do so manually at any time.

For details of the cookies that we use on the Website, what those cookies do, and the privacy policies of the third parties which provide them (where relevant) please see our Cookies Policy.

  1.     How and why do we use/share your personal data

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

We will not routinely share your personal data with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a joint venture property development) ) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.

We may also disclose your personal data to third parties in the following events:

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.  The following is a list of our major service providers:

Links to third party sites

Where we provide links to third party websites that are not affiliated www.savilebaymiami.com such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies.  Please check these policies before you submit any personal data to those websites.

  1.     For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.

Where you sign up to receive e-mail marketing from us we will retain your e-mail address on file should you ever ‘opt-out’ of receiving e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

  1.     Security

Savile Bay Management LLP takes the protection of your personal data very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the data provided to us is stored on secure servers once we receive it.

Savile Bay Management LLP may store your personal data on secure servers either on our premises or in secure third party data centres.

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”).  These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services to assist us in sending compliant e-mail marketing communications. By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about how the mechanism via which your personal data is transferred, please contact www.savilebaymiami.com

If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

  1. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

Savile Bay Management LLP may process your data on the basis of a legitimate interest in the following ways:

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at www.savilebaymiami.com and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

  1.     Contact Details

If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at:

Savile Bay Management LLP

18 Savile Row

London

W1S 3PW

Alternatively, you can email us at: info@savilebay-capital.com

 

SAVILE BAY MANAGEMENT LLP COOKIES POLICY

 

Last updated: 6 August 2018

INFORMATION ABOUT OUR USE OF COOKIES

  1.              Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse our Website, you are agreeing to our use of cookies.
  2.               A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive.
  3.              We use the following cookies:

3.1.         Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website..

3.2.         Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

3.3.         Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  1.             You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Essential Cookies

These cookies will be automatically deployed onto your computer when you use the Website

Cookie Name Purpose of Cookie and Information Collected Cookie Duration

 

Non-Essential Cookies

These cookies will be offered to you when you use the Website – you may accept or decline them depending on whether you are happy for them to be deployed onto your computer or not.

Google Analytics: These allows us to track user engagement including how users are interacting with each page of the website, how long users are spending on each, from what device and browser, users estimated demographics:

Cookie Name Cookie Duration
_ga 2 years
_gid 24 hours
_gat 1 minute
AMP_TOKEN 30 seconds to 1 year
_gac_<property-id> 90 days
__utma 2 years from set/update
__utmt 10 minutes
__utmb 30 mins from set/update
__utmc End of browser session
__utmz 6 months from set/update
__utmv 2 years from set/update
__utmx 18 months
__utmxx 18 months
_gaexp Depends on the length of the experiment but typically 90 days.

Mailchimp: This is used for data capture via email marketing such as users activity related to the emails we send as attached to their email address:

Cookie Name Cookie Duration
_mcga Until removed or expiry
_mc Until removed or expiry
PHPSESSID Until removed or expiry
_new-status-app_session Until removed or expiry
JSESSIONID Until removed or expiry
mc_blog_Session Until removed or expiry
_mcid Until removed or expiry
KB_ID Until removed or expiry
_integrations_session Until removed or expiry
_AVESTA_ENVIRONMENT Until removed or expiry
_experts_session Until removed or expiry
PHPSESSDATA Until removed or expiry
whatsNewLastVisited Until removed or expiry
KB_HIS[e369e2fc-2e5a-c7b0-e18c-f3aceadae113] Until removed or expiry
KB_HIS[83ca6c2f-deff-0e5e-6863-b2d0de144b6d] Until removed or expiry
zte2095 Until removed or expiry
_TEST_COOKIE Until removed or expiry
__zlcmid Until removed or expiry
  1.             Please note that third parties (including, for example, advertising networks and providers of external services like Google Analytics Solutions who provide us with web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
  2.              You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Alternatively, you can visit www.allaboutcookies.org which provides general information about cookies and how you can manage cookies on your computer. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.