Privacy Notice

The personal information we collect depends on how you interact with us and the nature of our relationship with you.

We may collect the following categories of information:

• your name;
• company or organisation name;
• job title and business role;
• email address, telephone number and other contact details;
• information contained in correspondence or communications with us;
• information relating to enquiries, projects, transactions or business opportunities;
• contractual, financial and billing information where relevant;
• information provided through forms on our website;
• marketing and communication preferences;
• information required to comply with legal or regulatory requirements; and
• technical information relating to your use of our website, such as device, browser, IP address and usage information, where applicable.

We do not normally seek to collect special category personal data or information relating to criminal convictions and offences. If it becomes necessary to process such information, we will do so only where there is an appropriate legal basis and applicable safeguards are in place.

We may collect personal information:

• directly from you when you contact or communicate with us;
• through our website;
• from the organisation that you represent or work for;
• from Haseko Corporation or other companies within the Haseko Group;
• from professional advisers, service providers and business partners;
• in connection with potential or existing business relationships; and
• from publicly available sources where appropriate.

Where we receive personal information about you from another source, we will use that information only where permitted by applicable law.

We may process personal information for a number of business purposes, including:

• responding to enquiries and requests;
• communicating with clients, prospective clients, suppliers and business partners;
• evaluating and pursuing potential business opportunities;
• managing commercial and contractual relationships;
• managing real estate investments, projects and related business activities;
• processing payments and maintaining financial and transaction records;
• administering and improving our website and services;
• maintaining the security of our systems, premises and information;
• managing complaints, disputes and legal claims;
• complying with legal, regulatory, accounting and reporting obligations;
• conducting internal administration, reporting and business planning;
• protecting HASEKO UK, the Haseko Group and third parties against fraud or other unlawful activities; and
• sending relevant business communications and marketing where permitted by law.

We will not use personal information for purposes that are incompatible with the purposes for which it was originally collected unless permitted or required by law.

UK data protection law requires us to have a lawful basis for processing personal information.

Depending on the purpose and circumstances, we may rely on one or more of the following:

We may process personal information where this is necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests.

These interests may include:

• developing and managing our business;
• managing relationships with clients, suppliers and business partners;
• evaluating investment and business opportunities;
• improving our operations and services;
• protecting our business, systems and information; and
• communicating with relevant business contacts.

We may process information where this is necessary to enter into or perform a contract with you.

We may process information where necessary to comply with applicable legal, regulatory, tax, accounting or reporting obligations.

In certain circumstances we may ask for your consent before processing personal information. Where we rely on consent, you may withdraw it at any time. Withdrawal of consent will not affect processing that took place before consent was withdrawn.

Where permitted by law, we may use business contact information to provide information about HASEKO UK or relevant Haseko Group activities, services or business developments.

Where consent is required by applicable law, we will obtain consent before sending such communications.

You can ask us to stop sending marketing communications at any time by contacting us at contact@haseko.co.uk or by using any unsubscribe method provided in the communication.

We may retain limited information about your preference to ensure that we continue to respect your request.

We may share personal information where necessary with:

• Haseko Corporation and other Haseko Group companies;
• our employees, officers and authorised personnel;
• professional advisers, including lawyers, accountants, auditors and consultants;
• IT, hosting, communications and other technology service providers;
• property, investment and other professional service providers;
• contractors and suppliers supporting our business activities;
• financial institutions, insurers and payment providers;
• prospective counterparties and advisers involved in investments, transactions, reorganisations, acquisitions or disposals; and
• regulators, courts, government authorities and law enforcement bodies where required or permitted by law.

We require service providers that process personal information on our behalf to use appropriate security measures and to handle that information only in accordance with our instructions and applicable law.

We do not sell personal information to third parties.

HASEKO UK is part of the wider Haseko Group, whose parent company, Haseko Corporation, is based in Japan.

As a result, it may sometimes be necessary to transfer or provide access to personal information outside the United Kingdom, including to Japan, for management, reporting and business coordination purposes.

Personal information may also be processed in other countries where our service providers or business partners operate.

Where UK data protection law treats such a transfer as a restricted international transfer, we will ensure that an appropriate legal mechanism is in place.

Depending on the destination and circumstances, this may include:

• UK adequacy regulations;
• the UK International Data Transfer Agreement;
• the UK Addendum to the EU Standard Contractual Clauses; or
• another safeguard recognised under applicable UK data protection law.

We may also implement additional contractual, organisational or technical safeguards where appropriate.

You may contact us at contact@haseko.co.uk if you require further information regarding the safeguards applied to international transfers of your personal information.

We take reasonable and appropriate technical and organisational measures to protect personal information against:

• unauthorised access;
• accidental or unlawful disclosure;
• alteration;
• loss;
• destruction; and
• other forms of unauthorised processing.

Access to personal information is limited to individuals who require it for legitimate business purposes.

We also maintain procedures for dealing with suspected personal data breaches and will notify affected individuals and the Information Commissioner's Office where required by law.

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected.

The appropriate retention period depends on factors including:

• the nature of the information;
• our relationship with you or your organisation;
• legal and regulatory requirements;
• accounting and tax requirements; and
• whether information may be required in connection with a dispute or legal claim.

Contractual, financial and transaction records may generally be retained for up to six years following the end of the relevant business relationship where appropriate.

Other information may be retained for shorter periods.

When personal information is no longer required, we will delete it, anonymise it or otherwise securely dispose of it in accordance with our applicable retention procedures.

Under UK data protection law, you may have rights in relation to the personal information we hold about you.

Depending on the circumstances, these may include the right to:

• request access to your personal information;
• ask us to correct inaccurate or incomplete information;
• request deletion of your information in certain circumstances;
• request restriction of processing;
• object to certain processing based on legitimate interests;
• object to direct marketing at any time;
• request transfer of certain information in a portable format;
• withdraw consent where processing is based on consent; and
• raise concerns about the way we process your information.

These rights are subject to certain legal conditions and exemptions.

If you wish to exercise any of these rights, please contact our Data Privacy Contact at contact@haseko.co.uk.

We may ask you for information to confirm your identity before dealing with your request.

We do not currently make decisions about individuals solely by automated means where those decisions would have legal or similarly significant effects.

If our practices change, we will provide information about the relevant processing and applicable safeguards as required by law.

If you have any concerns about how we handle your personal information, please contact us at contact@haseko.co.uk so that we have an opportunity to address the matter.

You also have the right to make a complaint to the UK supervisory authority for data protection:

Information Commissioner's Office (ICO)
Telephone: 0303 123 1113
Website: www.ico.org.uk

We may update this Privacy Notice periodically to reflect changes to our business, website, systems or legal requirements.

The current version of this Privacy Notice will be published on our website.

Where a change is significant and materially affects how we use personal information, we may take additional reasonable steps to bring that change to the attention of affected individuals.