Hatstone Real Estate

Our Privacy Policy


Important Information and who we are

Introduction

The Hatstone Group comprises a number of businesses including law firms and investment fund and corporate services with offices in the Island of Jersey, the United Kingdom, South Africa, Panama and the British Virgin Islands (collectively the “Hatstone Group”). ‘Hatstone’ is the business name used by the various entities of the Hatstone Group.

The Hatstone Group respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data (including personal data in respect of individuals who are clients, intermediaries or other third parties or any individual connected to those parties) and summarises the key points about how we collect use, disclose, transfer and store your personal data, sets out your privacy rights and explains how the law protects you.

Should you have any questions on the content of this Privacy Notice or how we use your data, please contact us by email on dataprivacy@hatstone.com.

About Us

As mentioned above, the Hatstone Group is made up of different legal entities, details of which can be found here. This Privacy Notice is issued on behalf of the Hatstone Group so when we mention “Hatstone”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant entity in the Hatstone Group responsible for processing your data.

We will let you know which entity will be the controller of your data and this will be set out in our letter of engagement with you. Where you make use of our website, this is provided and maintained by our Jersey law firm and our servers are located in Jersey which is a jurisdiction which the European Commission has deemed to be “adequate” in relation to data protection.

Changes to the Privacy Notice and your duty to inform us of changes

This version of our Privacy Notice was updated in June 2018. Historic versions can be obtained by contacting us. We may update our Privacy Notice from time to time.

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.

Contact Us

If you have any queries, require further information or wish to exercise any of the rights set out in this Privacy Notice, please contact us at dataprivacy@hatstone.com or contact our Data Privacy Manager, Stephen Wauchope.

You have the right to make a complaint at any time to the relevant data protection authority in the jurisdiction in which the services are being provided to you. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority so please contact us in the first instance.

The data we collect about you

The data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and status as a politically exposed person.
  • Contact Data includes postal address, email address and telephone numbers.
  • Employment Data includes your employers name, address, work Contact Data, professional qualifications and details of any directorships or other offices you may hold.
  • Special Categories of Personal Data this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
  • Criminal Charges, Convictions or Offences, which shall include alleged convictions or offences and information about your health and social and economic background.
  • Financial Data includes bank account and payment card details, sources of wealth including any beneficial interests you may hold in various assets.
  • Transaction Data includes details about payments to and from you and other details of services we have provided to you.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect information about people connected to you such as family members or business connections.

If you fail to provide personal data

Where we need to collect personal data by law, for example to comply with anti money laundering and know your client legislation, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you and, in this case, we may be unable to act for you and provide you with our services but we will notify you if this is the case at the time.

How is your personal data collected?

Methods of collection

We use different methods to collect data from and about you including through:

  • Direct interactions. You may provide us with personal information by filling in forms or by corresponding with us by post, phone, email or otherwise.
  • Third parties or publicly available sources. We also may receive personal data about you from various third parties and public sources for example, to verify your identity. We may also receive information about you where you are connected to or named in a matter on which we act and we may collect information about you from our client.
  • Information we collect automatically. We collect some information automatically when you visit our websites or use our guest internet within our offices such as your IP address or device type. Further details are provided in the Use of Our Website section of this Privacy Notice.

Use of our Website

Contact Us, Enquiries and Careers

Where you contact us through our website by sending an email to enquiries@hatstone.com or careers@hatstone.com email addresses any personal information which you provide to us will be collected and may be shared amongst our offices. In respect of any potential job applicants, information may be collected from a number of sources and may include CVs, education and employment history, references and background checks. We will use this information to assess your suitability for any vacancy and to determine how to progress your application. This information will typically be retained on our systems for up to six months after which time it shall be destroyed unless we have a legitimate reason for retaining your information for a longer period.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

Cookies

For many websites to work properly, the website will collect basic information on its users in the form of a small text file which is known as a “cookie”. The cookies on our website link to Google Analytics and will identify which pages our users access most. This cookie does not identify you or give us access to your computer. You can choose to accept cookies or you can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly.

Marketing and Mailchimp

Where you have provided us with your consent and requested to be added to our marketing mailing list or have provided us with your business card in a marketing context we may contact you periodically with newsletters, legal updates and invitations to our events. You have the option to opt out from receiving such communications at any time. We currently use Mailchimp as our marketing automation platform. Where you provide us with information, information you provide will be transferred to Mailchimp, or such other platform as we may use from time to time, for processing in accordance with their Privacy Policy and Terms & Conditions. We may appoint a third party marketing consultant from time to time in any of the jurisdictions in which we operate, who may have access to our Mailchimp account of the purposes of assisting us with our communications.

Google Analytics

We use Google Analytics to provide us with information relating to footfall to our website to allow us to analyse this information in as part of our legitimate business interests. This means that we may be provided details of the type of device that is used to browse our website and the general location of the device. This cookie does not identify you or give us access to your computer. For further details on Google Analytics please refer to Google Analytics’ Privacy Policy and Terms & Conditions.

Use of our Guest Internet when attending Hatstone Offices

If you attend our offices and connect to our guest wifi you should be aware that we may receive information relating to your device. While we do not routinely collect or analyse this information such information will be retained on our systems and we may receive information relating to websites that you visit and the name of your device. We will not have access to any emails that you send.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • where we need to comply with a legal or regulatory obligation;
  • where the processing is necessary for legal proceedings, for obtaining legal advice or establishing, exercising or defending legal rights.

Generally we do not rely on consent as a legal basis for processing your personal data save in respect of matters where we collect data relating to Criminal Charges, Convictions or Offences or other than in relation to sending third party direct marketing communications to you via email or text message. We will only send this type of communication to you if you have provided us with your express consent. You have the right to withdraw consent to marketing at any time by contacting us. Please do so by emailing our Data Privacy Manager at dataprivacy@hatstone.com.

Purposes for which we will use your personal data

How we will use your data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.