Privacy policy

The Earls Court Development Company takes your privacy seriously where we deal with your personal information.

The Earls Court Development Company is bringing forward the redevelopment of part of the Earls Court Opportunity Area as part of a joint venture with Transport for London (“TfL”). This privacy policy describes how The Earls Court Development Company will collect, store and use your information.

References to “The Earls Court Development Company”, “us”, “we”, “our” in this privacy policy mean [EC Properties Management Ltd] who is the data controller of information processed under this privacy policy, a company registered in England and Wales with company no. 08742449. Our registered office is at [Lansdowne House, Berkeley Square, London, United Kingdom, W1J 6ER].

You have the right to object to us using, sharing or carrying out processing of your information in certain circumstances, including using your information for direct marketing. Please contact us at any time using the contact details provided below for more details and to exercise this right where applicable.

WHAT INFORMATION DOES The Earls Court Development Company COLLECT?

We collect and may process your information in the following ways:

Information you give us directly

  • You give us information about you when you complete or confirm your details in any forms we may ask you to complete. This is generally details of your interest in the proposed redevelopment of the Earls Court Opportunity Area.
  • You give us information about you when you participate in any of our community events, consultation events or feedback initiatives. This information includes questionnaire responses [(which may include health related data)], written notes, electronic transcripts and reports containing identification details (name), demographics information ([age, gender, race, marital status, number of children, occupation, annual income, education level]) and views on our proposed redevelopment of the Earls Court Opportunity Area. We may also take photographs and/or video footage at these events where appropriate, so your image and/or audio may be captured if you choose to attend these events.
  • You give us information about you when you register to receive any kind of marketing communications or updates from us, including our newsletters and invitations to attend or participate in any of our events. This is generally your contact details (particularly your email address).
  • You give us information about you when you visit our premises, including the Earls Court Project Rooms. This is generally [your name, a contact number and your car registration details (if applicable)] which you will confirm when you sign in at reception. We also ask all visitors to show a form of ID, but this is for verification purposes only – we don’t record a copy of your ID.
  • You give us information about you when you like, post or otherwise interact with our social media pages such as [Facebook, Twitter or Instagram]. This is generally the contents of your public profile and any messages or comments you post, share or send to us.
  • You give us information about you when you contact us or otherwise interact with us, including via e-mail, letter, phone call or chat function.

Information we collect from other parties

  • [We collect information about you from our trusted service providers and consultants, who are acting on our behalf. For example, you may ask enquiries or provide feedback to our third party communications agency.
  • We collect information about you from publicly available sources of information, such as HM Land Registry and other publicly available websites
  • This information generally includes:
    • Identity details (including your name (which can include, if applicable, your previous names and/or alternative names), gender, date of birth and address);
    • Contact details (including your telephone number, email address, and postal address);
    • Details of your property (including your interests in land (including but not limited to details of tenants, details of occupiers, details of mortgages and/or other charges, details of easements, details of manorial rights, and/or details of rent charges)).
  • We collect information from other group companies listed below for internal reasons, primarily for business and operational purposes, and we ensure your information is used in line with this privacy policy:
    • EC Properties Management Limited (registered in England and Wales under company registration number 08742449); and
    • [Delancey Real Estate Asset Management Limited] (registered in England and Wales under company registration number 04517621).

Information we collect automatically

  • We collect certain information by automated means, such as cookies and web beacons, whenever you visit our website. This could include IP address, browser type, operating system, referring URLs, information on actions taken on our website, and dates and times of website visits. Please see our cookie policy.

HOW DOES The Earls Court Development Company USE MY INFORMATION?

We may use your information for the following purposes:

To provide a requested service or carry out a contract with you

  • To perform any contract entered into between you and us.

Where we have your consent

  • To contact you, including by email, SMS and telephone to send you marketing communications or updates from us, including our newsletters and invitations to attend or participate in any of our events. This is where we are under no legal obligation to keep you updated but you have given us your consent to receiving our updates. We will contact you consistent with your preferences and you can opt-out of receiving these communications at any time.
  • To process special categories of personal data (sensitive data) contained in demographic information you provide to us with your explicit consent, for example health related data and information revealing ethnic or racial origin.

Where we have a legitimate interest

  • To contact you, including by post, telephone and/or in person, to provide you with marketing communications or updates from us, including our newsletters and invitations to attend or participate in any of our events. This is where we are under no legal obligation to keep you updated but our updates are relevant to you. We will contact you consistent with your preferences (including the mail preference services and telephone preference services) and you can opt-out of receiving these communications at any time.
  • To contact you, including by post, telephone, email and/or in person, to gain access to your property for environmental surveys.
  • To include details of your interests and your views concerning the proposed redevelopment of the Earls Court Opportunity Area.
  • To conduct community events, consultation events and feedback initiatives in relation to the redevelopment of the Earls Court Opportunity Area, including to collect photographs and/or video footage at these events where appropriate.
  • To ensure that our events and sites are safe and secure.
  • To make decisions regarding the relevance and suitability of your interest and views concerning the proposed redevelopment and to prepare and manage our application for the redevelopment of the Earls Court Opportunity Area (this includes drafting the statement of community involvement, however this statement will contain aggregated statistics).
  • To investigate and address enquiries, questions and complaints and respond to any feedback.
  • To compile statistics about the behaviour of our website visitors and other users of our services.
  • To assist in the effective resolution of disputes.
  • To develop and improve our engagement with you.
  • To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

Where we have a legal obligation

  • To protect, investigate and deter against fraudulent, unauthorised or illegal activity, including undertaking necessary security and identity verification checks.
  • To communicate with you for the purposes of statutory consultations and engagement as required by planning law.
  • To include details of your interests and your views concerning the proposed redevelopment in our application for the redevelopment of the Earls Court Opportunity Area as required by planning law.
  • To make decisions regarding the relevance and suitability of your interest and views concerning the proposed redevelopment and to prepare and manage our application for the redevelopment of the Earls Court Opportunity Area as required by planning law.

Where we rely on legitimate interest as a ground for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request and can find out more by contacting us using the details below.

Please note that it is not compulsory to provide any information to us, however providing this information allows you to make the best of the consultation process and have your views taken into account.

DOES The Earls Court Development Company SHARE MY INFORMATION?

We share your information in the following circumstances:

  • We share your information with other group companies listed below for internal reasons, primarily for business and operational purposes, and we ensure your information is used in line with this privacy policy:
    • EC Properties Management Ltd (registered in England and Wales under company registration number 08742449); and
    • Delancey Real Estate Asset Management Limited (registered in England and Wales under company registration number 04517621).
  • We share your information with TfL, our joint venture partner, in order to assess feedback and consultation responses. Where possible, we will aggregate or pseudonymise your information before it is shared with TfL.
  • We share your information with third parties who perform services on our behalf, such as consultants (including our property advisory consultants, and construction and project management consultants), service providers (including our communications agency and website design agency), professional advisors (including our lawyers and accountants), those that carry out consultation and community engagement processes on our behalf, IT consultants carrying out testing and development work on our business technology systems, and analytics and search engine providers that assist us in the improvement and optimisation of our services.
  • We share information with our trusted suppliers to provide technical support and enable us to interact with you effectively.
    We share your information where you give us express permission to share your information in the course of your relationship with us from time to time.
  • We share your information if we are under a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal obligation; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of The Earls Court Development Company, third parties, users of our services or the public.
  • As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your information will be disclosed to such entity.

HOW LONG DOES The Earls Court Development Company KEEP MY INFORMATION?

Information that we collect will be retained only for as long as is necessary to fulfil the purposes outlined above in this privacy policy. This will generally be until the completion of our application and proposed redevelopment and may be either longer or shorter depending on the factors set out below. When determining the relevant retention periods for your information, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • our legal obligation(s) under applicable law to retain data for a certain period of time;
  • our legitimate interests where we have carried out balancing tests (see section ‘How does The Earls Court Development Company use my information?’ above);
  • statute of limitations under applicable law(s);
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we will securely erase or anonymise your information where we do not have a legitimate reason for keeping it.

DOES The Earls Court Development Company TRANSFER MY INFORMATION ABROAD?

Your information is generally stored and processed in the UK and the EU, including where it is hosted in Microsoft Azure data centres in the EU. In certain circumstances we may transfer your information to the US. Where we transfer your information to the US, we rely on the EU-US Privacy Shield Framework. This framework is approved by the European Commission as providing a level of protection equivalent to that in the EU in relation to data protection. Further information on the Privacy Shield Framework can be found at https://www.privacyshield.gov/welcome.

If we intend to transfer your information to any additional countries, we will update this privacy policy to reflect such overseas transfer.

WHAT ARE MY PRIVACY RIGHTS?

By law, you have a number of rights (subject to certain conditions) when it comes to your information. You can exercise any of these rights by contacting us through our details in the contact section below.

  • Rights
  • What does this mean?
  • The right to object to processing
  • You have the right to object to certain types of processing, including processing that relies on legitimate interest as a lawful basis, processing for direct marketing purposes (i.e. if you no longer want to receive direct marketing newsletters and updates from us).
  • The right of access
  • You have the right to obtain access to your information (if we are processing it), and certain other information (like the information provided in this privacy policy).
    This is so you are aware and can check that we are using your information in accordance with data protection law.
  • The right to rectification
  • You are entitled to have your information corrected if it is inaccurate or incomplete.
  • The right to erasure
  • This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  • The right to restrict processing
  • You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
  • The right to data portability
  • You have the right to receive your information in a structured, commonly used and machine readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.
  • The right to lodge a complaint
  • You have the right to lodge a complaint about the way we handle or process your information with your relevant national data protection regulator. See details of the UK data protection regulator in the contact section below.
  • The right to withdraw consent
  • If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

CHANGES TO OUR PRIVACY POLICY

We may periodically make changes to this privacy policy. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions on our website at www.theearlscourtdevelopmentcompany.com. We recommend that you revisit this privacy policy regularly.

CONTACT US

If you have any queries or requests concerning this privacy policy or how we handle your information more generally, please get in touch with us using the following details:

If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the UK data protection regulator who can be contacted as set out below:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/