Poly (UK) Real Estate Management Limited is a company incorporated in England and Wales with company number 11013205 (“Poly UK“). Poly UK, alongside its parent company and the subsidiaries of Poly UK and those of its parent company (the “Poly Group”) are engaged in the business of developing and selling properties in the United Kingdom. Full details of the relevant subsidiaries are set out at plaza-collection.co.uk/corporate-structure. This includes the special purpose vehicle which is a member of the Poly Group and is responsible for the development this URL relates to (“Developer”). Both Poly UK and the Developer’s (together or respectively “we“, “us” or “our“) registered office address is at 5 New Street Square, London, United Kingdom, EC4A 3TW.
Any reference to “you” or “your“, means you as a customer of our products and / or as a user of this website (“Website“).
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.
Our Website is not intended for children and we do not knowingly collect data relating to children.
For the purpose of United Kingdom data protection laws, Poly UK is a data controller. Poly UK are registered as a data controller with the Information Commissioner’s Office under number ZA645058.
2. What Information do we Hold About you and How it is Collected?
2.1 We are committed to respecting your privacy. We aim to minimise the use of your personal data.
Information you give us
2.2 We may collect and process the following personal data about you:
2.2.1 details regarding our properties you express an interest in through our Website or in person and of the fulfilment of any purchases;
2.2.2 information that you provide via our Website, when participating in our social media, when posting messages on our Website, if reporting a problem with our Website or when entering into any contractual documentation with us such as your name, address, telephone number, email address. This includes information provided at the time of registering in relation to our Website or buying properties at this development;
2.2.3 if you contact us by phone, e-mail or otherwise, we may keep a record of that correspondence;
2.2.4 we may also ask you to complete surveys / feedback forms that we use for research purposes, although you do not have to respond to them;
2.2.5 details of your visits to our Website including, but not limited to, traffic data, location data and other communication data.
Personal data you provide us in sections 2.2.1-2.2.3 may include your name, address, email address and telephone number.
Information we collect about you
2.3 With regard to each of your visits to our Website we will automatically collect the following information:
2.3.1 technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
2.3.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), 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. This is statistical data about our users’ browsing actions and patterns, and will not be used by us to identify any individual.
2.4 We operate CCTV in and around our marketing suite and may operate CCTV and other surveillance systems in (and around) our developments which capture images of you. We may be able to identify you from the CCTV data. We will only use this data to prevent, detect, deter and report on crime, to protect buildings and assets from crime, to protect the health and safety of customers, prospective customers, staff and other visitors and/or to assist with criminal investigations and support law enforcement bodies.
2.5 We use CCTV systems in this way for our legitimate interests (to prevent and detect crime), to comply with legal or regulatory obligations (to law enforcement bodies) and/or to protect the vital interests of you or another individual.
2.6 Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes or requested by a law enforcement body, data will be kept by them for as long as they need it. In all other cases, recorded images will be kept for no longer than 90 (ninety) days. We will maintain a comprehensive log of when data is deleted.
Information we receive from other sources
2.7 We may receive information about you from third parties when you use the Website or as part of any potential or actual purchase, including sales agents, managing agents, new build warranty provider, our identity, anti-money laundering and / or credit checking providers, introducers, other business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers.
2.8 In addition, in common with many other online services, the Website may contain third party integration cookies (such as Google analytics) and we may use other devices to store and sometimes track information about you (see section 12 below).
Special categories of personal data
2.9 We do not generally process any special categories of personal data, meaning personal data revealing:
2.9.1 racial or ethnic origin;
2.9.2 political opinions;
2.9.3 religious or philosophical beliefs or trade union membership;
2.9.4 genetic or biometric data that uniquely identifies you; or
2.9.5 data concerning your health, sex life or sexual orientation.
2.10 Nor do we generally collect data relating to criminal convictions or offences or related security measures.
2.11 However, we may process certain special categories of personal data and/or information about criminal offences in the event you:
2.11.1 seek to buy a plot built for disabled people. We are obliged by planning conditions and building regulations at a number of our developments to sell or let a set number of plots suitable for disabled people;
2.11.2 have an accident in or near one of our developments that is captured by CCTV and / or then logged in our accident record book;
2.11.3 are involved in carrying out criminal activity that is captured on one of our CCTV systems; and
2.11.4 include such information in your CV which you (or a third party) send to us about employment opportunities with us.
2.12 Generally we will require your explicit consent to process such special categories of data. Otherwise, we may need to process such personal data to protect your vital interests if you are incapable of consent or to comply with specific laws requiring us to collect such personal data or to establish, exercise or defend legal claims. The legal basis for processing data regarding your disability in section 2.11.1 is that it is necessary for reasons of substantial public interest as we would need to verify you are disabled so that we are comply with our planning conditions and building regulations when selling or letting wheelchair accessible plots.
2.13 We do not use your personal data to carry out automated decision-making.
3. BASIS FOR PROCESSING PERSONAL DATA
3.1 We set out in sections 3.1.1-3.1.10 below why we process your personal data, as well as the legal basis on which we carry out this processing:
3.1.1 to process and deal with your request, enquiry or registration of interest form. The legal basis on which we process their personal data in these circumstances is our legitimate interest to see if we can enter into a contract for the sale of property that you have expressed an interest in to us;
3.1.2 to enter into contracts with you and carry out our obligations arising from any contracts entered into between you and us, including to process the sale of property to you as requested and to manage the buildings and estate. Our use of personal data in this way includes sharing your personal data with our sales agents and managing agents. The legal basis on which we process your personal data in this way is the necessity to be able to enter into and perform the contract for the sale of property and / or the supply of services you have requested from us. If you do not wish to provide us with your personal data in this way, you will be unable to buy our properties or use our services;
3.1.3 to check your identity. In accordance with money laundering regulations and in order to carry out credit reference checks, we may be required to undertake checks on your identity. To do so, we (and our sales agent pursuant to section 3.2.3 below) will process your personal data. The legal basis on which we process your personal data in this way is the necessity for us to comply with legal obligations;
3.1.4 for internal record keeping. The legal basis on which we process personal data in these circumstances is to perform our contract with you or our legitimate interest to provide you with the best customer experience we can;
3.1.5 to monitor, support, improve and develop our products and services and to monitor, develop and improve the Website and your experience. The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with the best customer experience we can;
3.1.6 to contact you directly or by one of our appointed agents by e-mail, phone or mail. The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with the best customer experience we can or to perform our contract with you;
3.1.7 to notify you of products, information or services which we feel may be of interest to you, where you have consented to be contacted by Poly UK or there is a legitimate interest for us to contact you for such purposes. The legal basis on which we process your personal data in these circumstances is your consent or legitimate interests;
3.1.8 to ensure that content from our Website is presented in the most effective manner for you and the device you are using to access the Website. We also use various cookies to help us improve our website (more details are set out in section 12), and share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our Website. We will also use your personal data to make the Website more secure, and to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. The legal basis on which we process your personal data in these circumstances is our legitimate interest to provide you with the best client experience we can, and to ensure that our Website is kept secure;
3.1.9 to deal with any complaints made by or against you. The legal basis on which we process your personal data in these circumstances is our respective legitimate interests in dealing with customer service requests and responding to communications or to comply with legal obligations. If you do not provide us with the personal data we request from you for these purposes, we may not be able to appropriately deal with the relevant complaints;
3.1.11 to comply with any legal or regulatory obligation.
3.2 We may (depending upon what you have requested us to do) share your personal data on a need to know basis with the following parties to progress your request:
3.2.1 our enquiry line;
3.2.2 our customer service team;
3.2.3 our marketing, sales and / or managing agents. Our sales agents will need to share your personal data with various third parties that provide identity, anti-money laundering and / or credit checking services and (where relevant) their payment system provider, solely in connection with your prospective purchase of property from us;
3.2.4 our property management contractors or agents and our new build warranty provider;
3.2.5 our service providers acting as processors who provide IT, software and system administration services;
3.2.6 your advisors or authorised legal or mortgage representatives;
3.2.7 our payment system provider;
3.2.8 our leasing services provider; and / or
3.3 In other certain circumstances we may disclose your personal data to third parties:
3.3.1 if one or both of us or substantially all of our assets are acquired by or merged with a third party or enter into a joint venture, in which case personal data held by us about our customers or prospective customers will be one of the transferred or disclosed assets. In each case, the legal basis on which we process data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser or the merged entity. If you object to our use of personal data in this way, the relevant buyer of our business or merged entity may not be able to provide goods and/or services to you;
3.3.2 if one or both of us are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply our terms and conditions and other agreements; for tax or other purposes; or to protect the rights, property, or safety of us, our customers, or others; or to investigate or prevent a crime, suspected or actual fraud or tax evasion;
3.3.3 to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; and / or
3.3.4 to obtain any professional advice.
We may also pass aggregate information on the usage of our Website to third parties but this will not include information that can be used to identify you.
Information for marketing purposes
3.4 Where we have processed your personal data to provide you with marketing communications with consent pursuant to section 3.1.7, we may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications.
3.5 If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please email us at PolyUKOffice@polyglobal.com or, where relevant, by following the unsubscribe link displayed on every communication you receive from us. Your personal data will be removed from our marketing lists but will be added to a “do not contact” list and you may still receive messages for other purposes (such as providing services to you). If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.
3.6 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 information indefinitely without further notice to you.
3.8 As advised above, you can change your mind at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at PolyUKOffice@polyglobal.com.
4. Disclosure of Your Personal Data
4.1 There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law or regulation and for the purposes listed above. These scenarios include disclosure:
4.1.1 to our subsidiaries, parent or group companies;
4.1.2 to our outsourced service providers or suppliers to facilitate the provision of our services, for example, the disclosure to any sales agents we appoint of your contact details where you indicate that you are interested in this development and / or other developments undertaken by entities who are part of the Poly UK group of companies;
4.1.3 to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
4.1.4 to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
4.1.5 to legal advisors who may need to manage or litigate a claim;
4.1.6 to public authorities where we are required by law or regulation to do so; and
4.1.7 to any other third party set out in section 3 above or where you have provided your consent.
5. Period of Storage
5.1 We will keep your details on record until we have completed dealing with your request, enquiry or transaction and then for a reasonable period afterwards, in accordance with applicable data protection legislation in the United Kingdom. We do not share personal data with third parties except as necessary to carry out our business or your request or as required by law, regulation or other legal processes or as set out in section 3 above – we never sell personal data. By submitting data electronically you are providing consent to the transmission of data collected via our Website, as stated above.
5.2 To determine the appropriate retention period for personal data, we consider 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 requirements.
5.3 Where you purchase a property from the Developer, we will retain generally your data for a period of the later of (i) no less than 11 (eleven) years after the property was purchased as new properties we sell come with a 10 year new build home warranty and (ii) seven (7) years after the last services were performed, to ensure that we are able to assist you should you have any questions or feedback in relation to the property and/or services or to protect, or to defend our legal rights. However, we will process certain of your personal data for the duration of any lease we grant you and a short period thereafter.
6. Your Right TO OBJECT under UK Data Protection LAWS
6.1 You have the right to object to us processing your personal data where we are processing personal data:
6.1.1 based on our legitimate interests (as set out at sections 2.5, 3.1.1, 3.1.4–3.1.10 inclusive and 3.3.1 above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws and regulations; and
6.1.2 for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
In each case please do so by making contact with us directly (please see section 15 below).
7. Your Other Rights with regards to your Personal Data
7.1 Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal data. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal data is not being processed in accordance with the law. Further information about your rights is set out below:
7.1.1 Right of access. You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. You can exercise this right by making contact with us directly (please see section 15 below).
7.1.2 Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal data, including by means of providing a supplementary statement. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy. Requests for corrections or supplements to all other personal data should be made to us at PolyUKOffice@polyglobal.com, though we may need to verify the accuracy of the new data you provide to us. We will respond to your request to correct or supplement your personal data within a reasonable time period and, in any event, within any time period specified in relevant laws and regulations.
7.1.3 Right to restriction. You have the right to restrict our processing of your personal data where:
22.214.171.124 the accuracy of the personal data is being contested by you;
126.96.36.199 the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;
188.8.131.52 we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or
184.108.40.206 we are processing your data on the basis of our legitimate interest (as set out at sections 2.5, 3.1.1, 3.1.4-3.1.10 inclusive and 3.3.1 above) and you:
220.127.116.11.1 object to our processing on the basis of our legitimate interest under section 6.1.1 above; and
18.104.22.168.2 want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides their legitimate interest.
Where any exercise by you of your right to restriction determines that our processing of particular personal data are to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
7.1.4 Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
7.1.5 Right to object to processing. You may, as permitted by law, request that we stop processing your personal data where our processing is based on our legitimate interests or carrying out a task in the public interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
7.1.6 Right to data portability. You have the right to receive the personal data you have provided us in a structured, standard machine readable format and the right to transmit such personal data to another controller where we process such personal data based on consent or performance of a contract.
7.1.7 Right to erasure. You may request that we erase your personal data which we are processing where one of the following grounds applies:
22.214.171.124 the processing is no longer necessary in relation to the purposes for which your personal data was collected or otherwise processed;
126.96.36.199 our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;
188.8.131.52 you object to the processing in your personal data as set out in section 6.1.1 above and we have no overriding legitimate interest for our processing;
184.108.40.206 the personal data have been unlawfully processed; and
220.127.116.11 the erasure is required for compliance with a law to which we are subject.
We will comply, unless there is a lawful reason for not doing so.
7.1.8 Exercising your rights. If you wish to exercise any of your rights set out above, please contact us directly (please see section 15 below).
7.1.9 Your right to lodge a complaint with the supervisory authority. We would appreciate if you contact us about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales (www.ico.org.uk).
7.1.10 No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
7.1.11 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.
7.1.12 Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may 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.
8. Links to other websites
9. Safeguarding Information
We recognise our responsibility for protecting the online privacy of your personal data. If you have questions or comments about our administration of your personal data in relation to this development, or would like to opt out of receiving any marketing material from us, please contact us at PolyUKOffice@polyglobal.com.
10.1.1 We have tried to create a secure and reliable Website for you. We have put in place appropriate organisational and technical safeguards and security measures given the nature of the information processed by us.
10.1.2 You should note however that email enquiries are transmitted by insecure means and stored off-line. You recognise that the use of the Internet and the Website is entirely at your own risk. We accept no responsibility or liability for the security of personal data transmitted via the Internet. The Internet is not completely secure and we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10.1.3 All information we receive from you is stored securely. Any payment transactions will be encrypted using SSL technology. In the event that we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You must not share their password with anyone.
11. Where we store your Personal Data
11.1 Our clients or individuals who access our website may be based outside the European Union (or, following the United Kingdom’s departure from the European Union, the United Kingdom and the European Union) so the processing of their personal data will involve the transfer and storage of data outside the European Union (or, following the United Kingdom’s departure from the European Union, the United Kingdom and the European Union). Some of our suppliers are based outside the European Union (or, following the United Kingdom’s departure from the European Union, the United Kingdom and the European Union). We will also store personal data in Australia.
11.2 Any transfer of your personal data (other than to clients and individuals in section 11.1 above) made by us to a location outside of the European Union (or, following the United Kingdom’s departure from the European Union, the United Kingdom and the European Union) will be in accordance with our obligations under the relevant data protection legislation in the United Kingdom by providing an adequate level of protection to any such personal data that is transferred. This will be achieved by:
11.2.1 the use of specific contracts approved by the European Commission which give personal data the same protection it has in the European Union;
11.2.2 where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US;
11.2.3 transferring personal data to countries outside the European Union where the processor is bound by a set of Binding Corporate Rules which have been approved by a national data protection authority in the European Union (or, following the United Kingdom’s departure from the European Union, the United Kingdom and the European Union).
12. Cookies and other such devices
12.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of their computer. Whilst no cookies are set by us for this Website, we use a number of suppliers who set cookies on this Website on their behalf in order to deliver the services that they are providing. We cannot prevent such suppliers from collecting information about your usage of their services on our Website. If you would like more information about the cookies used by these suppliers, as well as information on how to opt-out, please see their individual privacy policies listed below.
Used to distinguish users.
Two (2) years.
See this link for how to reject or delete this cookie:: https://policies.google.com/privacy?hl=en
Two (2) years from set/update
Full explanation of Google Analytics cookie usage available here:https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
12.3 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) they may not be able to access all or parts of our website.
12.4 Except for essential cookies, all cookies will expire as outlined under the expiration column in the table included in section 12.2.
15. Contact/address details