This privacy notice describes how Countryside Properties plc and the companies that it owns and controls ('we', 'us') collects and processes personal information about you, how we use and protect this information, and your rights in relation to this information.
This privacy notice applies to all personal information we collect or process about our shareholders (that are individuals) and includes current and former shareholders. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
This privacy notice is effective from and including 03 June 2019. It may vary from time to time so please check it regularly.
1. Personal information we use
We process personal data in relation to our shareholders, such as name, postal address, email address, phone number, bank account details, number of shares and voting instructions.
We might be provided with this information directly by you or through your broker, agent, trustee, investment or other company that introduces you to us.
Failure to provide this information may prevent or delay the fulfilment of our obligations to you.
2. How we use your personal information and the basis on which we use it
We use your personal information:
- (a) to deal with your enquiries and requests;
- (b) to comply with legal obligations to which we are subject and cooperate with regulators;
- (c) to pay dividends, or other similar payments, to you;
- (d) to provide you with shareholder communications such as notices of meetings and circulars and process any proxy forms;
- (e) to provide you with copies of our annual report and accounts;
- (f) to maintain our share register and keep this up to date; and
- (g) to understand the composition of our shareholders.
We must have a legal basis to process your personal information. In most cases the legal basis will not be based on your consent but will be one of the following:
- (a)to comply with our legal obligations, for example in relation to keeping a register of members;
- (b)to comply with our legal obligations to you, for example in relation to dividend and other payments to you;
- (c)to meet our legitimate interests, for example to understand the composition of our shareholders to consider how we best serve them. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
3. Your rights over your personal information
You have certain rights regarding your personal information, subject to local law. These include the following rights to:
- access your personal information
- rectify the information we hold about you
- erase your personal information
- restrict our use of your personal information
- object to our use of your personal information
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
- lodge a complaint with your local data protection authority.
Where we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.
These rights are not automatic and depend on our exact relationship with you and the personal data involved. If you would like to discuss or exercise such rights, please contact us at the details below.
It is important that the personal information we hold about you is up to date at all times. Please keep us informed if your personal information changes during your relationship with us.
We will contact you if we need additional information from you in order to honour your requests.
4. Information Sharing
We may share your personal information with third parties under the following circumstances:
- Service providers and business partners. We may share your personal information with our service providers and business partners that perform data processing activities for us For example, our registrar is Equiniti Group plc (“Equiniti”) (company number 07090427) whose registered office is at Sutherland House, Russell Way, Crawley, West Sussex, RH10 1UH. Equiniti safeguards your personal data across all its computer systems, networks, websites and offices as much as possible through appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) and its Information Security policies are aligned to ISO27001, which is an internationally recognised security standard. Other processors with whom we may share your personal data from time to time include our professional advisers (including accountants, lawyers, brokers and other consultants) and printing firms.
- Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
5. Information Security and Storage
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
- Maintain business records for analysis and/or audit purposes or risk management purposes;
- Comply with our business record retention requirements; and
- Defend or bring any existing or potential legal claims.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
6. International Data Transfer
Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law / by the European Commission.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
7. Contact Us
Countryside Properties PLC and any companies that it owns and controls is the controller responsible for the personal information we collect and process.
Your normal point of contact for shareholder matters will be Equiniti, our registrar, and their details can be found in our Information Privacy Notice.
Our Data Protection Officer can be contacted at: DPO@cpplc.com. If you have questions or concerns regarding the way in which your personal information has been used, please contact the DPO.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the United Kingdom using their website: https://ico.org.uk/
8. Changes to the Policy
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.
04 July 2019