Privacy and Cookie Policy

Privacy Notice 

1. Introduction

This website (“Website”) is operated by Auriens Chelsea Management Limited (“we”, “our”, “us”). We are committed to protecting and respecting your privacy. This Website Privacy Notice (“Notice”), together with our Cookie Policy sets out what personal data we collect when you visit and use this Website, how we may use and manage your personal data and the rights you have in relation to your personal data. Please read this Notice carefully to understand our policies and practices regarding your personal data. This Notice may change from time to time and you should review it periodically. 

Personal data means any information that directly or indirectly identifies or otherwise relates to a living individual, which is in the possession or under the control of Auriens (or its representatives or service providers). It includes, for example: names, addresses, email addresses, job applications, photographs, CCTV images, employment records, customer files, bank details and correspondence to and from an individual. It also includes web browsing information (e.g., cookie data) and IP addresses.

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation, Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (“DP Laws”), the relevant Auriens entity that is collecting, handling, storing, disclosing and otherwise processing personal data is the data controller. 

Any changes we may make to this Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Notice. 

This Notice was last updated in July 2023

2. Whose personal information do we collect and how?

We collect personal data when you visit and/or use this Website and / or complete one of our web forms (e.g., to contact us); submit a subscription request to us (e.g., for a newsletter); and communicate with us via social networking websites or other platforms.

If you choose to provide personal data to us about someone else (such as one of your relatives) you must ensure that you are entitled to provide that personal data to us and that, without our taking any further steps, we may collect, use, disclose and otherwise process that personal data as described in this Notice. In addition, you must ensure the individual concerned is aware of the various matters detailed in this Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our information disclosure practices, the individual’s rights and the consequences if the personal data is not provided (such as our inability to provide services).

3. The personal data we collect

The personal data we collect and process may include information submitted as part of subscribing to our newsletters (and other marketing) or completing online forms on this Website (e.g., your name, address, e-mail address and phone number) and technical information collected by cookies (please refer to our Cookie Policy, which can be found below which forms part of this Notice) that is sent by your browser to our Website (stored as log files). This includes your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses. We may also collect information about your visit to the Website, including: the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); services you viewed or searched for; and page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We may also collect and process any personal data you chose to disclose as part of a general enquiry, and personal data you chose to submit in a ‘free text’ box (such as on the Website’s ‘Contact’ page).  Please do not provide any personal data you do not wish us to have. Please do not provide any ‘special category’ i.e. sensitive personal data such as medical information, religious or philosophical beliefs or similar, or bank account details or other financial information via the Website. 

We may receive personal data about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including social networking sites, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them. You can control what personal data is shared with us from third party websites, using the controls provided on those websites. We may also collect personal data about you from credit reference agencies where we have informed you this will take place.

Please note that if you do not provide certain personal data to Auriens when requested (and where relevant, provide your consent), we may not be able to provide you with some or all of our services (including those set out in this Notice or in other agreements we enter into with you).

4. The purposes for which we process your personal data

Depending on how you use our site, your interactions with us, and the permissions you give us, the purposes for which we use your personal information include:

(a) to provide you with any information or services that you request from us (e.g. to keep you up-to-date with the progress of a development you are interested in, or other similar information which relates to your enquiry);

(b) to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;

(c) to understand your needs and interests and to assess your application for Auriens services, where applicable;

(d) where permitted, to provide you, or enable selected third parties to provide you, with marketing information about services we feel may interest you;

(e) to analyse and improve our services and to notify you about changes to our services;

(f) for the management and administration of our business;

(g) to administer and improve this Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep this Website safe and secure;

(h) to comply with and in order to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation), industry codes, voluntary codes we decide to adopt, or good practice and internal policies and procedures;

(i) to confirm and verify your identity and to conduct due diligence, background and related checks;

(j) to detect, investigate and prevent fraud and other crimes or malpractice;

(k) for the purpose of, or in connection with, any legal proceedings;

(l) to obtain legal advice or to establish, exercise or defend legal rights;

(m) the administration and maintenance of databases storing personal data;

(n) to comply with our contractual obligations;

(o) where we receive personal data from other sources, we may combine this personal data with any personal data we collect about you. We may use this combined personal data for the purposes set out above (depending on the types of personal data we receive), including marketing.

5. Our legal basis for processing your personal data

We are entitled to use your personal data for these purposes because one or more of the following legal bases applies:

(a) your consent, e.g., when you subscribe to our magazine or request to receive marketing from us and our third parties. Note that you can withdraw this consent at any time;

(b) to take steps to enter into or perform a contract with you or other individuals, e.g., providing quotes and other information to help you make a decision on whether to use our services;

(c) compliance with our legal obligations;

(d) in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings or

(e) ours or our third parties’ legitimate interests, where these are not overridden by your privacy and data protection rights. Our legitimate interests include: fulfilling your requests for information about our services, conducting surveys and other research projects, personalising and tailoring the content of our Website and our promotions to you, maintaining and improving our Website so that users can get the information they need from the Website quickly, allowing Auriens to effectively and efficiently administer and manage the operation of its business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials,  offering optimal, up-to-date security solutions for mobile devices and IT systems, and for internal research purposes.

6. Sharing your personal data

We may share or provide access to your personal data with any member of our group, among our affiliates and business units and third-party agents, service providers and contractors outside of Auriens including:

(a) for the purpose of the management and administration of our business;

(b) to facilitate the provision and enhancement of services to you;

(c) for the purpose of the administration and maintenance of the databases storing personal data;

(d) for the purposes of us receiving services (e.g., our accountants, auditors, service providers, professional advisors, IT and communications providers or any entity we reasonably consider necessary for the purposes outlined above). These third parties will be expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use your personal data as described above;

(e) to the extent required by law (e.g., if we are compelled by an obligation or a duty to disclose your personal data where we believe it is necessary or appropriate to comply with any legal obligation, rule, regulations or internal policies and procedures, including (without limitation) in order to comply with tax reporting requirements and other statutory reporting and disclosures to regulatory authorities), or to establish, exercise or defend our legal rights. This may include disclosure to regulatory bodies or government agencies and in order to investigate unauthorised attempts to modify the Websites, install harmful files or cause damage to the Websites;

(f) as part of a transaction, financing, or for other business needs (e.g., if we sell any of our businesses or assets, in which case we may need to disclose your personal data to the prospective buyer and their respective professional advisers, as the case may be, as part of certain due diligence processes); or

(g) if we or any of our affiliates, divisions or business units is acquired by a third party, including in the unlikely event of a bankruptcy, in which case the personal data held by us about you will be accessible to, and may be acquired by, the third party buyer.

We may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-personal information of numerous people together so that the data does not relate to any individual. “De-identify” means that we attempt to remove or change certain identifiers that may be used to link data to a particular person.

7. International transfers of personal data outside UK/EEA 

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA working for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. If we transfer personal data to a third party outside of the UK or EEA, we will, as required by DP Laws, ensure that your data protection rights are protected by appropriate safeguards, such as the UK IDTA or the European Commission’s Standard Contractual Clauses for the transfer of personal data to controllers or processors established in third countries. Please contact us (using the information in Section 13 below) if you would like more information about these safeguards.

8. How we safeguard your personal data

We have implemented commercially reasonable controls and appropriate technical and organisational measures to protect personal data, as well as to maintain the security of our information and information systems in respect of personal data. Appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to personal data is limited to authorised employees. 

When you contact us about your personal data, you may be asked to provide evidence of your identity (e.g., driver’s licence or passport). These types of safeguards are designed to ensure that only you, or someone authorised by you, has access to your file.

Your personal data is kept for as long as it is necessary for the purposes for which it was collected. Therefore, after this period data is destroyed, erased or anonymised. All personal data you provide to us is stored on our secure servers. Any payment transactions will be encrypted. 

9. Retention of personal data

The period for which we will hold your personal data will vary and will be determined by the following criteria:

(a) The purpose for which we are using it. We are required to retain the personal data for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and

(b) Legal Obligations. Laws or regulations may set a minimum period for which we must retain your personal data.

We take reasonable steps using appropriate technical methods in the circumstances to delete or destroy your personal data when we no longer have a legal basis to retain it or to ensure that the personal data is anonymised or irrecoverable.

10. Marketing

Depending on your preferences, we may send you marketing communications where we think that these are relevant and interesting. We send emails to your provided email address, such as our magazine or our brochures.  Some of these emails may be tailored to you, based on your interests and any other information we may hold.

We also send you information through the post, such as our magazine and our brochures, and if you have provided your phone number we may contact you by telephone for the purposes for which you have provided this (e.g., to keep you updated on our developments).

If you no longer wish to receive marketing communications from us (or would like to start receiving marketing communications), you can change your preferences (‘opt-out’) at any time by writing to us or emailing us (using the information in Section 13 below). You can also click the ‘unsubscribe’ button which is included in the emails we send you, or you can tell us over the phone not to call you anymore. We may continue to send you service related emails if you opt out of marketing, such as information about our service and information about your legal rights/conditions of use of the service.

You may also see ads for our Website on third-party sites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Website). Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.

Your option not to receive promotional and marketing material shall not preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (e.g., your account status and activity or our responses to questions or inquiries you pose to us); shall not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal data for our internal business purposes; and shall not preclude us from disclosing your personal data as described in this Notice for purposes other than sending you promotional and marketing materials.

11. Your rights

In certain circumstances, DP Laws may give rights to individuals in respect of personal data that Auriens hold about them, e.g., to:

(a) the right to refuse to provide any personal data and the right to object at any time to the processing of their personal data;

(b) the right to confirm whether we process their personal data and to obtain information regarding the processing of their personal data and access to the personal data about them that Auriens holds;

(c)    where consent was provided for certain processing activities, the right to withdraw their consent to the collection, processing, use and/or disclosure of their personal data at any time. Please note that this will not affect the lawfulness of any collection, processing, use or disclosure undertaken before such withdrawal and that Auriens may still be entitled to process the personal data if it has another legitimate reason (other than consent) or a consent exception for doing so;

(d)    the right to receive a copy of some personal data in a structured, commonly used and machine-readable format and/or request that Auriens transmit that data to a third party where this is technically feasible;

(e)    the right to request that Auriens rectify or correct their personal data if it is inaccurate or incomplete;

(f)    the right to request that Auriens erase their personal data;

(g)    the right to request that Auriens restrict, anonymise or block its processing of their personal data; and

(h)    where applicable, the right to lodge a complaint with the UK data supervisory authority, the Information Commissioner’s Office (“ICO”) if they think that any of their rights have been infringed by Auriens.

You can exercise your rights at any time by contacting us; see contact information set out in Section 13 below. Please note that the exercise of certain of your rights may prevent us from providing services to you. 

We are typically able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may have the option to escalate concerns to the ICO. 

12. Links to third-party websites

Please note that this Website may contain links to other websites. These third-party sites are not subject to this Notice, and we recommend that you check the privacy and security policies of each website that you visit. We are only responsible for the privacy and security of the personal data that we process as a data controller and have no responsibility for the actions of other third party data controllers in relation to your personal data.

13. Links to third-party websites

Questions, comments and requests regarding this Notice are welcomed and can be provided to us at: FAO: Auriens DPO, 18 Culford Gardens, London, United Kingdom, SW3 2ST, you can email us at: DPO@auriens.com, or you can call us on: 020 3870 7970. 

Cookie Policy 

This policy explains how Auriens Chelsea uses cookies on this website (the “Site”). 

1. What are cookies?

A cookie is a small text file that is downloaded and stored on your device when you access a website. Cookies can be used for various purposes, including to recognise your device and remember choices you have made about how you would like to view a website or past actions.

Cookies can be either “persistent”, which means that they are stored on your device between visits, or “session” cookies, which means that they are deleted from your device at the end of your visit. We use both types of cookies on our website.

Most websites use cookies, and the law requires us clearly to explain how we use cookies and why. The use of cookies is regulated by:

• PECR - The Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended); and
• The General Data Protection Regulation (2018) (known as the “GDPR”).

The Privacy and Electronic Communications Regulations (PECR) sit alongside the Data Protection Act and the UK GDPR. They give people specific privacy rights in relation to electronic communications.

There are specific rules on:

• marketing calls, emails, texts and faxes.
• cookies (and similar technologies).
• keeping communications services secure; and
• customer privacy as regards traffic and location data, itemised billing and directory listings.

2. Use of cookies by Auriens Chelsea

Necessary or 'essential' cookies

Some of the cookies used on this Site are essential for its operation. These are placed on your device when you visit the Site. These include cookies which regulate the number of requests being made to our Site (otherwise known as “load balancing”).

Analytical cookies

We use analytics cookies to monitor how visitors arrive at and interact with our Site. We use this information to improve our Site. We will ask for your consent before these cookies are stored on your device:

• Google Analytics: We use Google Analytics to recognise and count the number of visitors our Site, and to understand how visitors move around it. These cookies allow us to improve the way our Site works, for example by making sure users are finding what they need more easily.  The cookies collect information including IP addresses, device identifiers and other online identifiers. To opt out of being tracked by Google Analytics across all websites, visit tools.google.com/dlpage/gaoptout.
• ActiveDEMAND: We use cookies, pixels and tracking scripts provided by ActiveDEMAND to collect information about the use of our Site, as well as tracking and target the interests of visitors of our Site to give a more personalised experience. Your IP address and device identifiers will be collected in order to facilitate this. You can find out more about how ActiveDEMAND uses information by visiting engage.activedemand.com.
  
• YouTube: We use YouTube to store and track interaction, provide ad delivery or retargeting, store and track a visitor's identity, store and track interaction. You can find out more about how YouTube uses information, and how to opt out, by visiting policies.google.com/technologies/partner-sites.

3. Targeting and marketing cookies

We use targeting and marketing cookies to track how you arrive on our Site and to serve relevant adverts to you, including when you visit other websites. We will ask for your consent before these cookies are placed on your device:

• Google DoubleClick: We use the DoubleClick “floodlight” pixel to measure how many visitors have arrived on our Site after clicking on one of our adverts. This allows us to measure the effectiveness of our adverts. Your IP address and device identifiers will be collected in order to facilitate this. We do not use the information that we collect through this pixel in order to personally identify you. You can find out more about how Google DoubleClick uses information, and how to opt out, by visiting policies.google.com/technologies/partner-sites.
• Google AdWords: We use cookies provided by Google AdWords to retarget adverts through use of a unique identifier. These cookies allow us to serve adverts to individuals that have previously visited our Site. Your IP address and device identifiers will be collected in order to facilitate this. You can find out more about how Google AdWords uses information, and how to opt out, by visiting policies.google.com/technologies/partner-sites.
• Facebook: We use cookies, pixels and web beacons provided by Facebook in order to collect information about the use of our Site, including whether a visitor has come to our site as a result of being shown an advertisement by Facebook. Your IP address will be collected in order to facilitate this. You can find out more about Facebook ads by visiting en-gb.facebook.com/help/568137493302217.

4. How we collect consent for the use of cookies

When you first visit our Site, and every ninety days thereafter, we will ask if you consent to us placing cookies and similar technologies such as pixels on your device. You have the option to reject all of the non-essential cookies that we use on our Site. You can alter these settings at any time.

5. More about cookies

Most internet browsers are automatically set to accept cookies. If you want to change your cookie preferences at a browser level, you can manage this through your browser settings. Please remember that if you use your browser settings to prevent any cookies from being dropped, you may not be able to use some functions on our Site that rely on essential cookies being used.

You can also remove cookies that have already been set on your device by going to your browser settings. If you are having trouble doing this or would like more information, the website www.allaboutcookies.org has information on how to do this across a range of browsers.