Privacy Policy

Effective date: 11 September 2019

Tower 42 is committed to protecting your safety and privacy and takes its responsibilities regarding the security of personal data very seriously. This privacy policy explains what personal data we collect about individuals, how and why we use it, who we disclose it to, and how we protect your privacy.

  1. This policy

This policy sets out the basis on which we process data about individuals including tenants, visitors to our building or website or anyone who registers with our app.

Tower 42 reserves the right to make amendments to this policy from time to time. Any changes to this policy will be posted on this page.

  1. Who is responsible for your data

Our Privacy Policy applies to the personal data that Tower 42 collects and uses.

References in this Privacy Policy to “Tower 42”, “we”, “us” or “our” mean The Tower Limited Partnership (a limited partnership registered in England and Wales with registration no LP005833 and registered office at York Gate, 100 Marylebone Road, London, NW1 5DX) and its group affiliates. We control the ways your personal data is collected and the purposes for which your personal data is used by Tower 42. Tower 42 is the “data controller” for the purposes of the UK Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) (each as amended or replaced) and other applicable European data protection legislation (together the “Data Protection Legislation”).

  1. Personal data we collect about you

When using the term “personal data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include for example your name, your contact details and date of birth.

  1. How we collect data about you

We may gather data from our website or app in two main ways: (1) the data you give to us through the app; and (2) the data we collect about you using cookies and similar technologies via the app or website (see below) or in accessing the Tower 42 building.

We collect personal information from you at several different points, including but not limited to the following:

  • when we interact with you as a tenant or customer, prospective tenant or customer, or visitor;
  • when you visit our building or website or log-in through our app;
  • when you enter into an agreement with us;
  • when you contact us for help, including matters incidental to accessing the building or using the app such as event bookings, tenant co-ordination and community discussions; and
  • when you register your credit card and make a transaction through the app system;

Neither we nor our Third Party Providers (defined below) store your credit card information. Credit card information is stored by payment processors compliant with Payment Card Industry Data Security Standards (PCI DSS).

  1. Special categories of data

Tower 42 does not collect any “Special Categories of data” that could reveal sensitive information such as racial or ethnic origin, sexual orientation, political beliefs etc.

  1. Disclosure of your personal information

We may disclose your personal data, in various ways and for various reasons, with the following categories of people:

  • tax, audit, law enforcement or other authorities, when we believe that the law or other regulation requires us to share this data;
  • we may disclose your personal information to any member of our group, which means our affiliates, our ultimate holding company and/or its subsidiaries;
  • a third party who acquires us or substantially all of our assets;
  • third party service providers who perform functions on our or your behalf (including professional advisors such as security consultants, lawyers, auditors, accountants, technical support functions and IT consultants carrying out testing and development work on our systems) and in particular our cloud-based storage and app providers such as SpaceOS Limited (“Third Party Providers”).

  1. Transferring your information internationally

We do not transfer your personal data outside the European Economic Area (EEA), unless it is a country which conforms with the EU Commission’s “adequacy decision”.

  1. Retaining/Deleting your information

Your personal information is kept for as long as your Tower 42 app account is active or for as long as it is necessary to protect our legitimate business interests.

  1. Security

We will use technical and organisational measures to safeguard your information and ensure that our Third Party Providers are held to appropriate security measures. It is important that you keep your password secure when using our app.

  1. Cookies and other similar technologies

We or our Third Party Providers may use web cookies and other similar technologies in interacting with you. These include products from SpaceOS Limited, Google Analytics (Google, Inc.), HotJar Ltd and other technologies that collect data, such as names, IP addresses, locations and default language preferences.

  1. Third Party Properties

Our app and website may contain links to and from our Third Party Providers. If you use any links to these Third Party Providers, please note that they are subject to their own privacy policies and we cannot and do not accept any responsibility or liability for these policies or for any personal data that may be collected through these links.

  1. Your rights

You have a right to:

  • receive certain information about our processing activities;
  • request access to the personal data we hold about you;
  • request the rectification, erasure or withdrawal of your personal data;
  • restrict or object to the processing of your personal data;
  • prevent our use of your personal data for direct marketing purposes; and
  • in certain circumstances, request to transfer your personal data from us to another data controller.

If you would like to request any of the above, please contact us at info@tower42.com to make any such requests. We will comply with the Data Protection Legislation in responding to any such requests.

  1. Right to lodge a complaint

If you have any complaints about the way in which we collect, store and use your information, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns