We, 20 Fenchurch Street (GP) Limited, are committed to protecting the privacy of
anyone who visits our website (the “Website”) or registers to use our services. As
part of our commitment, we have thus adopted certain measures in relation to the
collection, use, retention, disclosure, transfer, security and accessibility of your
personal data in order to comply with the requirements laid down in the UK Data
Protection Legislation and the UK Data Protection Act 2018.

This Privacy Policy (the “Policy”) applies to personal data and information regarding
guests and other individuals with whom we do business and to the management of
that data and information in any form, whether electronic or written.
Whilst we make every effort to protect your personal data, no security measures can
guarantee that your personal data and information will not be subject to interference,
misuse or hacking and we shall not be responsible for any loss, misuse or alteration
arising as a result of such incidents.

1. Your Use of this Website
Use of this Website constitutes your agreement to the terms of this Policy and the
application of any applicable laws and regulations. Whenever you submit Personal
Data and any other information via this Website, you acknowledge that data and
information will be collected, used and disclosed in accordance with this Policy.

2. Data Protection Legislation
It is our policy to comply with the UK Data Protection Act 2018 and the UK Data
Protection Legislation as described below to the extent it applies to the Personal
Data we process about you (the UK Data Protection Act 2018 and the UK Data
Protection Legislation jointly referred to as the “Data Protection Legislation”).
For the purposes of this Policy, “UK Data Protection Legislation” means all
applicable legislation relating to data protection in the United Kingdom, including the
UK General Data Protection Regulation (“UK GDPR”) introduced by the Data
Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit)
Regulations 2019 and all legislation implementing or made under or pursuant to or
replacing or superseding the UK GDPR. Where this Policy uses terms which are
defined in the UK GDPR, the definitions set out in the UK GDPR will apply.
“Personal Data” is data relating to you from which you can be reasonably identified.
Examples of Personal Data include your full name, email address, postal address,
telephone number, job title or the company you work for. We recognise that your

Personal Data is valuable and we process it in accordance applicable law, and to the
extent that it applies to your Personal Data, with UK Data Protection Legislation.

3. Data controller
We are responsible as data controller for the processing of your Personal Data
collected on the Website under the UK Data Protection Legislation (to the extent that
it applies to Personal Data collected about you) and other applicable law.

4. Types of Personal Information We Collect
When we need to collect personal data from you to provide you with our service, we
will ask you to voluntarily supply us with the information we need. The information
collected includes but is not limited to:
 Name
 Email address
 Mobile/contact phone number

5. Purpose of Personal Data Collection
You acknowledge and agree that such personal data will be used by us for the
following purposes:
 The provision of the services offered by us, including general administration
and record keeping. In these circumstances, we will use your Personal Data
to perform an agreement with you because we would be unable to provide
those services without that information;
 To respond to requests for information and services. We will do this because
it is in our legitimate interest to use your Personal Data to communicate with
you, to respond to your requests about the services and facilities you require
and to develop the relationship between us in the context of your use of our
services and facilities.
 To facilitate direct marketing, promotional and customer management
purposes, including sending you information about our services, promotional
communications or special offers, if you have consented to receive them as
further described under Section 9 (Direct Marketing).

6. Information we collect from you browser and your device
When you visit the Website, we may automatically collect information about your
interaction with the Website such as your IP address, traffic data, clickstream
information, time stamp, location data, web logs, other communication data and the
resources that you access. We automatically collect this data using various
technologies such as cookies, web logs and beacons as described below. This data
is primarily used for delivering and optimising services offered by us, such as:
(a)   authenticating your identity and remembering certain data for the purposes
described in “Purposes of Personal Data Collection” above;

(b)   providing you with relevant, personalised content in order to help us focus on
what you are most interested in; and
(c)   improving our services, whereby we may occasionally display different versions
of content to you and measure your usage of our Website pages. To the extent this
information constitutes Personal Data, we use it to ensure that content from the
Website is presented in the most effective manner for you and your device because
it is in our legitimate interest to improve our customers’ online experience in relation
to the Website.

Use of Cookies
If you would like to disable cookies, you can set your web browser to reject cookies.
However, if you disable the cookie function, you may not be able to access or
receive all the information contained on the Website. How to alter your cookie setting
will depend on the type of browser you use. We have provided examples of how to
disable cookies on the most popular browsers below:
Cookie List
A cookie is a small piece of data (text file) that a website – when visited by a user –
asks your browser to store on your device in order to remember information about
you, such as your language preference or login information. Those cookies are set
by us and called first-party cookies. We also use third-party cookies – which are
cookies from a domain different than the domain of the website you are visiting – for
our advertising and marketing efforts. More specifically, we use cookies and other
tracking technologies for the following purposes:
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be
used by those companies to build a profile of your interests and show you relevant
adverts on other sites. They do not store directly personal information but are based
on uniquely identifying your browser and internet device. If you do not allow these
cookies, you will experience less targeted advertising.
Cookies used
 _fbp
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the most
and least popular and see how visitors move around the site. All information these
cookies collect is aggregated and therefore anonymous. If you do not allow these
cookies we will not know when you have visited our site, and will not be able to
monitor its performance.
Cookies used
 _gid
 _ga

 _gat
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off
in our systems. They are usually only set in response to actions made by you which
amount to a request for services, such as setting your privacy preferences, logging in
or filling in forms. You can set your browser to block or alert you about these
cookies, but some parts of the site will not then work. These cookies do not store any
personally identifiable information.
Cookies used
 OptanonConsent
 OptanonAlertBoxClosed
Functional Cookies
These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose services
we have added to our pages. If you do not allow these cookies, then some or all of
these services may not function properly.
Cookies used
 has_js

Cookie settings
Microsoft Internet Explorer
choose the “tools” menu then “Internet Options”;
click on the “privacy” tab; and
select the appropriate setting.
Mozilla Firefox:
choose the “tools” menu then “Options”;
click on the “privacy” menu then “Options”;
click on the “privacy” icon; and
find the “cookie” menu and select the relevant options.

Please note that Google and other third parties (including, for example, advertising
networks and providers of external services like web traffic analysis services) may
also use cookies as a result of you visiting other websites, over which we have no
control.

7. Disclosure and Transfer
We do not sell, rent or lease your Personal Data to third parties without your
consent. However, we will share Personal Data to further our business operations
and as described below.  By visiting the Website, you agree to disclosures to the
following third parties:
 advertisers, which may collect aggregated statistics from the Website;
 other companies and individuals which we employ to provide certain services
such as email marketing services (e.g. analysing customer lists, deliverability
statistics, opens and clicks), marketing assistance or consulting services.
These third parties may have access to information needed to perform their
function but cannot use that information for any other purpose;
 our service providers and sub-contractors for the performance of any contract
we enter into with them or you;

 our business partners, but only to the extent you have purchased or
expressed an interest in a product or service of such business partner or
interacted with or otherwise authorised the sharing of your Personal
Information with such business partner;
 our professional advisers, such as our accountants, auditors and lawyers,
insurers and industry groups having a legitimate reason to receive such
information;
 a purchaser or successor entity in the event of a sale or other corporate
transaction involving some or all of our business or as needed to affect the
sale or transfer of business assets, or as needed for external audit,
compliance or corporate governance related matters;
 any of the affiliates and the parent company of 20 Fenchurch Street (GP)
Limited, and any company in which the same has a direct or indirect interest
or with which it is in joint venture or co-operation with or their respective
successors and assigns;
 any actual or proposed assignee or transferee of 20 Fenchurch Street (GP)
Limited; and
 any other person under a duty of confidentiality to 20 Fenchurch Street (GP)
Limited.
We reserve the right to disclose any personal data and information we have
concerning you if we are compelled to do so by a court of law or requested to do so
by a governmental entity or if we determine it is necessary or desirable to comply
with the law or to protect or defend our rights or property. We also reserve the right
to retain information collected and to process such information to comply with
accounting and tax rules and regulations.
In addition, we may make certain disclosures in answering your query or providing
you with our services.

8. Storage and transfer of your Personal Data to Other Countries
If you provide Personal Data to us, it may be transferred to, processed in, stored at
or accessible from a destination outside the UK, such as any country in which we,
our affiliates or our service providers maintain facilities. All practical steps are taken
to ensure that all data is treated confidentially, kept secure and protected against
unauthorised or accidental access, processing, erasure or other use and is
maintained and kept no longer that is necessary for the purpose for which it is
intended.
Where we pass your Personal Data from a location inside the UK to parties located
outside the UK that do not offer adequate protection as determined by the UK’s
Information Commissioner’s Office or any applicable legislation in the UK, and if
these parties are not subscribed to an approved data protection framework, we will
enter into agreements which enable us to transfer Personal Data to them and that
enable you to exercise your rights in accordance with the Data Protection

Legislation. A copy of these terms can be obtained by emailing us
at dataprotectionenquiries@20fenchurchstreet.co.uk .

9. Direct marketing
When you opt-in to receive communications from us, you are giving your consent for
your Personal Data to be used by us to contact you (depending on your selection) by
email, direct mail and telephone and to deliver personalized Website experiences, to
share information about relevant services, news and events and our offering,
including but not limited to residential, offices, commercial and industrial buildings,
shops, hotels, serviced apartments, shopping malls and events,  restaurants, bars,
food & beverage promotion, banquet and conference services, membership
programmes, surveys by e-mail or telephone on our service quality, educational,
recruitment, charitable and non-profitable causes.
We may not use your Personal Data for direct marketing purposes unless we have
received your consent. Your consent may also be communicated to us without
charge by checking the opt-in / consent box in this Website or by writing
to dataprotectionenquiries@20fenchurchstreet.co.uk or by post at 20 Fenchurch
Street, Level 23, London, EC3M 3BY. When you enter your contact details for the
purposes of receiving marketing communications and click “sign up”, you will be
consenting to us contacting you for these purposes.
You may opt-out from receiving marketing communications at any time with no
additional charges, by:
1. Following the “opt-out” instructions contained in the communications;
2. Contacting us by mail or email or phone at 20 Fenchurch Street Limited
address: 20 Fenchurch Street, Level 23, London, EC3M 3BY
email: dataprotectionenquiries@20fenchurchstreet.co.uk
(Please indicate “Opt-out from receiving marketing communications”)

Withdrawing your consent will not affect our use of the Personal Data prior to you
withdrawing that consent but it will mean that we will not be able to contact you about
the services we may be able to offer you or your business in the future. When your
opt-out request is received, your contact details will be “suppressed” rather than
deleted. This will ensure that your request is recorded and retained unless you
provide a later consent that overrides it.
We will let you know where you must provide us with Personal Data in order to
perform an agreement with you or to comply with a legal obligation. If you do not
provide us with the Personal Data in these circumstances, we will be unable to
respond to your enquiry and/or engage in further communications with you.

10. Data Retention and Security

We will only retain Personal Data from you for as long as needed to fulfil the
purposes for which we have initially collected it and to provide you with our services,
unless otherwise required by law. All Personal Data will be retained only as
necessary to comply with our legal obligations.

We will delete our copy of your Personal Data within 60 days.

from the end of our last contact with you
although we may retain a record of the existence of the relationship, to the extent
and for so long as we are required to do so by law. For example, if you have
contacted us to ask us for the processing of your Personal Data to be erased, we will
retain a record of your request in order to ensure we comply with your wishes.
To the extent that you have consented to receive marketing communications from
us, we will retain your personal data for a full year starting from our last contact with
you, unless you take any action to opt out of marketing communications in
accordance with Section 9.
We will take all practicable steps to ensure the data held by us are protected against
unauthorized or accidental access, process, erasure or other use.

11. Changes to the Policy
The Policy may be modified from time to time. Any changes to our Policy will
become effective upon posting of the revised policy on the Website. We encourage
you to periodically review our Policy so that you are always informed of the way we
collect and use your personal data.

12. Your rights
With respect to the Personal Data that we collect about you from the Website, to the
extent that you are located in the UK under UK Data Protection legislation, you have
the right to:
a)      request access to that Personal Data;
b)     receive a copy of the Personal Data that you have provided to us in a
structured, commonly used and machine-readable format so that you can share it
with others;
c)      request the transfer of your Personal Data to another party;
d)     ask that Personal Data be erased;
e)      object to us possessing your Personal Data by asking for the processing of that
Personal Data to be restricted or stopped. For example, if we use Personal Data for
marketing purposes; and
f)       make a complaint to a UK data protection authority about the manner in which
we process your Personal Data. Complaints should be addressed to the Information
Commissioner’s Office (ICO). The ICO can be contacted for complaints either at
https://ico.org.uk/make-a-complaint/your-personal-information-concerns, via live chat
at https://ico.org.uk/global/contact-us/live-chat or by telephoning 0303 123 1113.

Alternatively, please contact us in accordance with section 13 (Contact Information)
to exercise these rights or for additional information.

13. Contact Information
If you wish to contact us about the privacy-related matters described above or find
out more information about our privacy practices, please use the contact details
below:
The Data Protection Officer
The Data Protection Officer is contactable on 0207 337 2318 or by email at
dataprotectionenquiries@20fenchurchstreet.co.uk

20 Fenchurch Street (GP) Limited
(Registered no. 07243935)
20 Fenchurch Street, Level 23, London, EC3M 3BY
dataprotectionenquiries@20fenchurchstreet.co.uk

Last updated: May 2021