1. Introduction

1.1 LSL Partners (“we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy and relevant data protection laws (which include the EU General Data Protection Regulation 2016/679, together with all applicable legislation relating to privacy or data protection). 

1.2 This policy describes the types of information we may collect from you and/or is provided by you when you visit our virtual dataroom’s website: https://londonstrategiclandfund.com in connection with the possible formation of a new real estate fund (the Fund) and our practices for collecting, using, maintaining, protecting and disclosing that information.

2. Important information and who we are

2.1 Purpose of this privacy policy

2.2 This privacy policy aims to give you information on how we collect and process your personal data. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.   

2.3 For the purposes of the data protection laws, we are the controller of the data.   

3. The data we collect about you

3.1 Personal data, or personal information, means any data which reIates to a living individuaI who can be identified from that data or from that data and other information which is in our possession, or is IikeIy to come into our possession (or the possession of the Fund, its general partner and the respective representatives or service providers). In addition to factuaI information such as a name or address, it couId incIude an expression of opinion about or an indication of intention in respect of an individuaI. It does not include data where the identity has been removed (anonymous data). 

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

3.2.1 Information that you provide to us: this information may include:

(a) basic personal data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title; bank details; ID documentation; date of birth; life events and family information; 

(b) sensitive personal data, which may include information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliations, or records of criminal offences and court proceedings.

We also process personal data about any person on whose behalf you are acting, for example investment beneficiaries, that you may have provided to us. By providing us with their personal data, you agree to provide them with the information set out in this privacy policy.

3.2.2 Information that we collect or generate about you. This may include:

(a) files that we may produce as a record of our relationship with our clients and prospective clients, including contact history; 

(b) any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements; or

(c) any personal data that we obtain in relation to your use of our site (but this will be limited to the situations where users make themselves known by establishing a secure, authenticated session).

3.2.3 Information we obtain from other sources. Some of this personal data may be sensitive and may include:

(a)information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources;

(b)information provided to us by independent financial advisors (IFAs), other professional advisers, product providers, events organisers, other agents and/or representatives, industry databases and other business intelligence tools we subscribe to; and

(c)information obtained from sanctions checking and background screening service providers.

3.3 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service but we will notify you if this is the case at the time. 

4. How we use your personal data

4.1 Your personal data may be stored and processed by us in the following ways and for the following  purposes:

4.1.1. to allow you to use and access certain of our products and services, such as the dataroom;

4.1.2. to set up / on-board you to use certain of our products and services, such as the dataroom;

4.1.3. to keep our records up to date;

4.1.4. to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;

4.1.5. to protect our premises from unauthorised access or use, or any unlawful activity;

4.1.6. to administer or maintain IT systems in order to uphold standards of service;

4.1.7. for ongoing review and improvement of the information provided on our site to make them user friendly and prevent potential disruptions or cyber attacks;

4.1.8. to understand feedback on our products and services and to help provide more information on the use of those products and services quickly and easily;

4.1.9. to communicate with and better understand your  interests; 

4.1.10. to effectively manage and strengthen relationships with you and understand your needs and interests;

4.1.11. for the management and administration of our business;

4.1.12. in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

4.1.13. for the administration and maintenance of databases storing your personal data.

4.2. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.2.1. we are performing our contractual obligations;

4.2.2. we have legal and regulatory obligations that we have to discharge;

4.2.3. we may need to do so in order to establish, exercise or defend our legal rights or those of our clients or for the purpose of legal proceedings;

4.2.4. we have obtained your consent;

4.2.5. the use of your personal data as described is necessary for our legitimate business interests, such as:

(a) allowing us to effectively and efficiently manage and administer the operation of our business;

(b) maintaining compliance with internal policies and procedures; or

(c) enabling quick and easy access to information on our products and services.

4.3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.4. Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

5.1. We may share your personal data within our group for the purposes described above.

5.2. We may share your personal data with the parties set out below.

(a) Where required by law, government agency or court of law; 

(b) Our IT and system administration service providers;

(c) Professional advisers including lawyers, bankers, auditors and insurers;

(d) HM Revenue & Customs, regulators and other authorities based in the United Kingdom; 

(e) Business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;

(f) The Fund, the general partner of the Fund, administrators or other parties relating to them; 

(g) Representatives, agents, custodians, administrators, intermediaries and/or other third party product providers appointed by us (such as accountants, professional advisors, custody service providers and product providers); 

(h) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

6. International transfers

6.1. The Fund operates and/or is anticipated to operate outside of the European Economic Area (EEA) and as such we may need to transfer your personal data out of the EEA.  

6.2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

(b) We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

(c) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield scheme which requires them to provide similar protection to personal data shared between Europe and the US. 

(d) The law may in some limited circumstances permit us to otherwise transfer your personal data outside the EEA

6.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

7. Data security

7.1. Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.

7.2. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 

7.3. We aim to ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non- public personal information. The effectiveness of these safeguards is periodically tested.

7.4. We have controls and mechanisms in place designed to detect, respond and recover in case of adverse events that may arise.

8. Data retention – How long will we keep your personal data for?

8.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8.2. To determine the appropriate retention period for personal data, we consider, among other things, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8.3. In some circumstances we will 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 information indefinitely without further notice to you. 

9. Your legal rights

9.1. In all the above cases in which we collect, use or store your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. In certain cases, we may not be able or obliged to comply with your request. These rights include: 

9.1.1. Request access to your personal data (commonly known as a “data subject access request”) and information regarding the processing of your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

9.1.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

9.1.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

9.1.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

9.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios, but we may be required or entitled to keep it: 

(a) if you want us to establish the data’s accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it; 

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.; 

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

9.1.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

9.1.7. Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain your personal data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;

9.1.8. Right to lodge a complaint with the relevant data protection regulator if you think that any or your rights have been infringed by us as further set out below. 

9.2. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

9.4. Contact details and Complaints 

If you have any questions or complaints about this privacy policy or our privacy practices, please contact us at [email protected]. 

UK residents also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

9.5. Changes to the privacy policy and your duty to inform us of changes

9.5.1. We may need to update this policy periodically. Any changes we make to our privacy policy will be posted on the site and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

9.5.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.