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Privacy policy

WHO WE ARE

The pages on the website (the “Website”) are published by Investis Limited (“Investis”) on behalf of Regional REIT Limited (“Regional REIT”, “us” or “we”).

Regional REIT is committed to protecting your personal information when you use our services. This notice explains how we collect, retain and process your personal information.

Here we set out how the personal information that we collect about you will be used.

CONTACTING US

For the purposes of data protection legislation, Regional REIT is a “controller” meaning that we determine the purpose and means of processing the information we collect from you. If you have any questions concerning Regional REIT’s data privacy procedures please contact investor@regionalreit.com.

If you ever have any questions, comments or complaints about this notice, or any of its contents, please contact us via any of the following means and we will be pleased to assist you:

By Post

C/O Link Asset Services, Beaufort House, 51 New North Road, Exeter, England, EX4 4EP

By Email

investor@regionalreit.com

By Phone

0207 845 6100

INFORMATION THAT WE COLLECT

This section details the types of information we collect from you and use the following information about you. Personal data means any information about an individual from which that person can be identified. The personal data we will collect from you via your use of the Website includes:

  • Identity Data – First name, last name, any previous names, username or similar identifier, marital status, title,   of birth and gender;
  • Contact Data - billing address, delivery address, email address and telephone numbers;
  • Financial Data – bank account and payment card details;
  • Transaction Data – details about payments to and from you and other details of products and services you have purchased from us;
  • Technical Data – Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Website;
  • Profile Data – your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
  • Usage Data – Information about how you interact with and use our website, products and services; and
  • Marketing and Communications Data – your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with the Website to help improve the Website and our service offering.

HOW WE USE YOUR INFORMATION

General uses of information

We use information supplied by you:

  • to provide you with email updates and alerts as requested by you;
  • to improve the services that we offer;
  • to respond to your queries;
  • to carry out our obligations where you are a shareholder or have a contract with us for other purposes;
  • to notify you about any changes to our services and/or the Website;
  • to comply with legal and regulatory requirements that apply to us; and
  • for general statistical analysis.

Lawful processing

The law requires us to have a legal basis for collecting and using your personal data. In terms of the legal bases we rely on to process your information, these are::

  • where the processing is necessary for the performance of a contract with you for provision of services or to take steps at your request prior to entering into any contract;
  • where the processing is necessary to comply with our legal obligations;
  • where the processing is necessary for our legitimate interests in:
    • ensuring the quality of the services we provide to you;
    • collecting information for marketing purposes;
    • communicating with you; and
    • statistical analysis; or
  • where you have consented to such use.

If provision of your personal information is a legal or contractual requirement or a requirement necessary in accordance with any shareholding, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain services to you.

If you do choose to provide your consent you can withdraw it at any time by contacting us at the aforementioned email address.

Information used for marketing purposes

From time to time we will contact you by post and/or telephone to provide you with details of our other services and/or events that we think may be of interest to you. We will not contact you by email and/or SMS about those products and services and/or events, unless you have consented to such contact, or in the case of such products and services, where these are similar to those that we have already provided to you.

You have the right to ask us not to process your personal data for marketing purposes at any time. You can exercise your right to prevent such processing by:

  • checking certain boxes on the forms we use to collect your data
  • by replying directly to the marketing message
    • in case you wish to withdraw from all marketing communications, you can also unsubscribe from all marketing by clicking the appropriate link in any email you receive.
    • at any time by contacting the aforementioned email address.

SHARING YOUR INFORMATION

We will not pass your information on to third parties except where:

  • we provide your information to our service providers to allow them to assist us with carrying on and conducting our business functions. We may provide your information to the following categories of recipients:
    • accountants
    • auditors
    • payroll administrators
    • lawyers
    • administrator
    • company secretary
    • depository
    • asset manager
    • investment manager
    • information technology and information security providers
    • Investis Limited 24 Fashion Street, London, E1 6PX
  • law enforcement agencies and regulatory bodies where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect the rights, property, or safety of us, our customers or others;
  • if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC) or such government bodies, who may transfer it to the government or the tax authorities in another country where you may be subject to tax;
  • if we (or all or part of our assets) were to be acquired by a third party;
  • if you have consented to any disclosure to a third party.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please check their privacy notices.

WHERE WE STORE AND USE YOUR INFORMATION

We transfer, use and/or store your personal information outside of the European Economic Area (“EEA”) and the laws of some of these destination countries may not offer the same standard of protection for personal information as in the UK.

We currently transfer data to the following countries outside of the EEA:

  • USA; and
  • India.

We may update this list from time to time, and any changes will be communicated to you via an update to this privacy notice.

Transfers to our third party service providers are to enable them use and store your personal information on our behalf. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented

We also ensure that, where your information is transferred to any country outside the EEA this is done using specific legally-approved safeguards. You can request further details and a copy of these by contacting us at the aforementioned email address.

KEEPING YOUR INFORMATION

We will keep your information only for as long as necessary depending on the purpose for which it was provided , including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Details of retention periods for different aspects of your personal information are available in our retention policy which is available by contacting us at aforementioned email address.

When determining the relevant retention periods, we will take into account factors including:

  • the amount, nature and sensitivity of the personal data;
  • the potential risk of harm from unauthorised use or disclosure of your personal data
  • legal obligations under applicable law to retain data for a certain period of time
  • statute of limitations under applicable law(s)
  • (potential) disputes, and
  • your continued desire to receive communications from us and our ongoing relationship;
  • guidelines issued by relevant supervisory authorities.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes].

SECURITY

We have put in place measures to protect the security of your information. These measures are intended to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Unfortunately, the transmission of information via email is not secure. Therefore, if you use email for communicating with us, we cannot guarantee that it will remain confidential whilst in transit.

YOUR RIGHTS

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.

The various rights are not absolute and each is subject to certain exceptions or qualifications

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Fees

In some cases, we may charge a reasonable fee if your request for access to your data is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, contact us at the above contact details.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (“ICO”): https://ico.org.uk/global/contact-us/ 0303 123 1113.

CHANGES TO OUR PRIVACY NOTICE

We keep our privacy notice under regular review and any updates we make in the future will be posted on our website and the most recent version of this “Privacy Notice”. Where appropriate, changes may be notified to you by post or email.