Our Policy
Privacy Statement
At General People, we hold an unwavering commitment to safeguarding the privacy of individuals with whom we engage in various capacities. This privacy policy applies to an array of individuals, including but not limited to: (a) Visitors to our website; (b) The personnel of our esteemed clients, prospective clients, fellow landlords, tenants, and business partners; (c) The personnel of our valued suppliers and service providers. This policy governs instances where we function as a data controller, exercising control over the purposes and means of processing personal data. For the purposes of this policy, references to "General People," "we," "us," and "our" pertain to General People RE Limited. A detailed overview of our entity is provided in Section 12.
2. Personal Data Collection
Within this section, we delve into the comprehensive categories of personal data we process, providing insights into sources and specific data categories. Marketing Data: Our processing may encompass marketing data, including but not limited to names, business email addresses, business telephone numbers, business fax numbers, and business postal addresses. This data is sourced directly from you and/or your employer. Client and Business Partner Data: Information pertaining to client relationships, prospective client relationships, supplier relationships, service provider relationships, and various business associations ("client and business partner data") may include personal data such as names, employer names, job titles, contact details, classifications within our CRM system, transaction-related data, contract-related data, and communication information. This data is sourced from you and/or your employer. Tenant Data: Tenant data, concerning individuals for whom we provide services, may encompass contact names and details. The source of this data is you and/or the relevant landlord. Usage Data: Usage data related to your interactions with our website and services may include IP addresses, geographical locations, browser types, versions, operating systems, referral sources, length of visit, page views, and website navigation paths. This data is sourced from our analytics tracking system.
3. Purposes of Processing and Legal Bases
This section articulates the multifaceted purposes for which we may process personal data, elucidating the legal bases underpinning such processing. Operations: We engage in the processing of personal data for negotiating and entering contracts, delivering services, managing our business operations, including the management of suppliers, services providers, contractors, agents, and consultants. Additional purposes encompass the publication of testimonials on our website, generating invoices, bills, other payment-related documentation, and credit control. The legal basis for these processes lies in our legitimate interests, specifically the proper administration of our services and business. Relationships and Communications: We may process marketing data, client and business partner data, and/or tenant data for the purpose of managing relationships, communication (excluding direct marketing communications), and complaint handling. The legal basis for these activities is our legitimate interests in business communications with our website visitors, clients, prospective clients, and tenants, as well as the general maintenance of our business relationships. Direct Marketing: Our processing of marketing data and client/business partner data may extend to creating, targeting, and sending direct marketing communications through email, SMS, post, and/or fax, as well as making contact by telephone for marketing-related purposes. The legal basis for this processing is either consent or, if consent is not sought, our legitimate interests in promoting our business and communicating marketing messages to our clients and prospective clients. Research and Analysis: Usage data and client/business partner data may be processed to facilitate research and analysis concerning the use of our website and services, as well as other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our services and business overall. Record Keeping: Personal data may be processed for the purposes of creating and maintaining our databases, back-up copies of our databases, and our business records in general. The legal basis for this processing is our legitimate interests in ensuring access to all necessary information for the proper and efficient operation of our business in accordance with this policy. Security: The processing of personal data for security purposes and the prevention of fraud and other criminal activities is conducted based on our legitimate interests, specifically the protection of our website, services, business, and others. Insurance and Risk Management: Personal data may be processed when necessary for obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice. The legal basis for this processing is our legitimate interests, which include the proper protection of our business against risks. Legal Claims: In cases where processing personal data is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, the legal basis for this processing is our legitimate interests. This includes the protection and assertion of our legal rights, your legal rights, and the legal rights of others. Legal Compliance and Vital Interests: Processing of personal data may occur when necessary for compliance with a legal obligation to which we are subject or to protect vital interests, whether yours or another natural person's.
4. Providing Personal Data to Others
We may disclose your personal data to our insurers and/or professional advisers to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice. Personal data may be stored and processed by our suppliers and service providers falling into the following categories: (a) Hosting services providers; (b) Communications, marketing, and customer relationship management system services providers; (c) Productivity application services providers.
4.1 Sharing with Business Partners
Marketing data, client and business partner data, and/or tenant data may be shared with our business partners. These partners generally act as independent controllers with respect to your personal data and may, in certain circumstances, disclose your personal data further in accordance with their own privacy policies and practices.
4.2 Legal Obligations and Legal Claims
Beyond the specific disclosures of personal data outlined in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect vital interests, whether yours or another natural person's. Additionally, personal data may be disclosed where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International Transfers of Personal Data
Our analytics services provider, Google LLC (1600 Amphitheatre Parkway, Mountain View, California 94043, USA), operates globally with facilities located around the world. We ensure that, where required by applicable law, international transfers of data to Google, are protected by appropriate safeguards. These may include the use of standard clauses approved by competent data protection authorities. It's important to acknowledge that personal data you submit for publication through our website or services may be accessible globally via the internet. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and Deleting Personal Data
Personal data processed for any purpose or purposes shall not be retained beyond what is necessary for that purpose or those purposes. (a) Marketing Data: Retained for a minimum of 6 years following the date of the most recent marketing communication, and for a maximum of 7 years following that date; (b) Client and Business Partner Data: Retained for a minimum of 6 years and a maximum of 7 years following the end of the relevant client or business partner relationship, or the end of a tenancy with which the relevant data is associated, whichever is later; (c) Tenant Data: Retained for a minimum of 6 years following the end of the relevant tenancy, and for a maximum of 7 years following that date; (d) Usage Data: Retained for 3 years following the date of collection.
6.1 License-Granted Data
If you grant us a license to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section, in accordance with the applicable license terms and subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section, that personal data will be retained for a minimum period of 6 years and a maximum period of 7 years following the date that publication ceases.
6.2 Legal Obligations and Vital Interests
Notwithstanding other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect vital interests, whether yours or another natural person's.
7. Your Rights
Principal rights under data protection law include: (a) The Right to Access: You can request copies of your personal data. (b) The Right to Rectification: You can request us to rectify inaccurate personal data and to complete incomplete personal data. (c) The Right to Erasure: You can request us to erase your personal data. (d) The Right to Restrict Processing: You can request us to restrict the processing of your personal data. (e) The Right to Object to Processing: You can object to the processing of your personal data. (f) The Right to Data Portability: You can ask that we transfer your personal data to another organization or to you. (g) The Right to Complain to a Supervisory Authority: You can complain about our processing of your personal data. (h) The Right to Withdraw Consent: To the extent that the legal basis for our processing of your personal data is consent, you can withdraw that consent.
7.1 Limitations and Exceptions
These rights are subject to certain limitations and exceptions. Further information about the rights of data subjects can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights
7.2 Exercising Your Rights
You may exercise any of your rights concerning your personal data by written notice to us, using the contact details set out in Section 14.
8. Third-Party Websites
Our website may contain hyperlinks to third-party websites. While we strive to ensure the privacy and security of our users, we do not have control over, nor are we responsible for, the privacy policies and practices of third parties.
9. Updating Information
Please inform us if the personal information we hold about you requires correction or updating.
10. Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session when the web browser is closed. While cookies may not contain information that personally identifies a user, personal data that we store about you may be linked to the information stored in and obtained from cookies. We utilise cookies for the following purposes: (a) Analysis: Cookies aid us in analysing the use and performance of our website and services. (b) Cookie Consent: Cookies store your preferences concerning the use of cookies more generally. Most browsers provide options to refuse acceptance of cookies and delete existing cookies. Information on blocking and deleting cookies can be obtained through the browser websites. If you block cookies, you may not be able to utilise all features on our website.
10.1 Google Analytics
Our reliance on Google Analytics involves the use of cookies. Google Analytics gathers information about the utilisation of our website through cookies, subsequently utilised to generate reports about website usage. Further details regarding Google’s use of information can be found here, while Google's privacy policy is available here.
10.2 Facebook Pixel
Additionally, we may employ a Facebook pixel on our website. This pixel allows Facebook to collect information about users and website use, contributing to the personalization of Facebook advertisements and analysis of website usage. More information about the Facebook pixel and Facebook’s use of personal data is detailed in the Facebook cookie policy and Facebook privacy policy.
10.3 LinkedIn Insight Tag
A LinkedIn Insight Tag (pixel) may also be incorporated on our website. This tag enables LinkedIn to collect information about users and website use, facilitating the personalization of LinkedIn advertisements and analysis of website usage. For additional insights into the LinkedIn Insight Tag and LinkedIn’s use of personal data, refer to the LinkedIn cookie policy and LinkedIn privacy policy.
11. Amendments
We may update this policy periodically by publishing a new version on our website. We recommend checking this page occasionally to ensure you are satisfied with any changes to this policy.
12. Our Details
This website is owned and operated by General People RE Limited. We are registered in England and Wales under registration number 13356415 and our registered office is at 30 City Road, London, United Kingdom, EC1Y 2AB.
13. Complaints
Should you wish to make a further enquiry or complain about how your Personal Information is being handled, you may raise your concern with the Information Commissioner’s Office (the “ICO”). Further details on reporting a concern can be found on the ICO’s website at https://ico.org.uk/concerns/handling/.
14. Contact Us
Questions, comments, and requests regarding our Privacy Policy are welcomed and should be addressed to: general@generalpeople.com