Privacy Notice

Cardiff Parkway Developments Limited
Privacy Notice
Last updated: 18 November 2019

It is important that our customers read this privacy notice in full. It explains who we are, how and why we collect personal data from you, how and why it will be processed by us and our commitment to protecting your data.

However, if you do not have time to read it in full we have summarised the key points for you in our ‘speed read’ section below.

SPEED READ

• Cardiff Parkway Developments Limited (we, our or us) are registered as a data controller with the Information Commissioner’s Office and our registration number is ZA557299.
• We process (i.e. handle) your personal data to provide our services to you. Under data protection laws, we are only permitted to process your personal data where we have a legal basis for doing so. We will only ever process your personal data in compliance with applicable law.  
• We may share your personal data with our third party suppliers to enable the efficient and secure provision of services to you. Except as explained in this privacy notice, we will not share your data with third parties without your consent unless required to do so by law.
• We will keep your personal data for as long as we need it. How long we need your personal data depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests (described below) or so that we can comply with the law. We will actively review the information we hold and when there is no longer a legal or business need for us to hold it, we will either delete it securely or in some cases anonymise it.
• We do not transfer your personal data outside of the European Economic Area.
• You have important rights under laws aimed at protecting your personal data. This policy sets out your rights and how can you exercise them. For more information, please see section 11 of this privacy notice. You also have the right to make a complaint to the Information Commissioner’s Office if you are unhappy with how we have handled your personal data. For more information, please see section 13.

1. About Cardiff Parkway Development
   • Cardiff Parkway Developments Limited (“we”, “us”, “our”) is a company registered in England and Wales under company number 10358878 whose registered office is at Summers House Pascal Close, St. Mellons, Cardiff, United Kingdom, CF3 0LW.
   • We are registered as a data controller with the Information Commissioner’s Office and our registration number is ZA557299.

2. About this privacy policy
   • We are committed to protecting and respecting your personal data and privacy. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
   • This privacy notice applies to any personal data we collect about you when you visit our website, submit an enquiry through our contact centre (Freephone: 0800 123 4567; communityrelations@cardiffhendrelakes.com; FREEPOST HENDRE LAKES) and when you communicate with us by telephone, by post, by email or in person.
   • This privacy notice may change from time to time and, if it does, the up-to-date version will be available on our website (www.cardiffhendrelakes.com). We will also tell you about any important changes.

3. What personal data do we collect about you?
   • 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).
     • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
     • Contact Data includes postal address, email address and telephone numbers.
     • Technical Data includes 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, and other technology on the devices you use to access our website.
     • Profile Data includes your username, preferences, feedback and survey responses.
     • Health Data includes information about your accessibility requirements.
     • Usage Data includes information about how you use our website, and services.
   • We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
   • In some cases, we may collect Special Categories of Personal Data about you (this includes information about your health). We will only collect such data if you provide it to us in response to any of our consultations or engagement activities.  
   • We do not collect any information about criminal convictions and offences.

4. How is your personal data collected?
   • We use different methods to collect data from and about you including through:
   • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
     • submit an enquiry to us;
     • subscribe to our newsletters;
     • give us feedback or contact us.
   • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our section 12 for further details.
   • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
     • Technical Data from the following parties:
       • Cookie data from Google, WordPress and WPML; Identity and Contact Data from publicly available sources such as Companies House, Land Registry Records and the Electoral Register.
       • We are also working closely with third parties, (including, for example, our consultants supporting us with stakeholder consultation and engagement) and may receive information about you from them. In addition, we may receive information about you from third parties who provide it to us (e.g. law enforcement authorities).

5.     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:
     • you have given us consent to do so for the specific purpose which we have told you about;
     • 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; or
     • where we need to comply with a legal obligation.

Where we process your personal data on the basis of our legitimate interests, these are our interests in managing the Cardiff Hendre Lakes and Cardiff Parkway project and responding to your enquiries.

We have set out below a list of the ways we may 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.

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 using the contact details in section 13 if you require further information.

• Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Communications
   • Newsletters  

You will receive newsletters from us if you have requested information from us or signed up to our mailing list and you have not opted out of receiving those newsletters. If you have consented to receiving our newsletters and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel, or by contacting us using the contact details in section 13.

• Marketing  

We will not use your personal data to send direct marketing communications.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

7. DISCLOSURES OF YOUR PERSONAL DATA  
   • We may share your personal data with the parties set out below for the purposes set out in the table above.
     • Internal third parties such as our shareholders
     • External third parties such as:
       • ARUP, our design and planning consultants;
       • Copper Consultancy, our communications and marketing advisors;
       • SLC Rail, our commercial and technical rail consultants;
       • IT service providers;
       • professional advisers; and
       • other consultants/service providers.
     • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
   • 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.

8. International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

9. Data Security
   • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
   • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data Retention  
    • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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.
    • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    • Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
    • In some circumstances you can ask us to delete your data: see your legal rights below for further information.
    • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11.  Your legal rights 
    • Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to request that we:
      • provide you with a copy of the information we hold about you;
      • update any of your personal information if it is inaccurate or out of date;
      • delete the personal data we hold about you – if we are providing services to you and you ask us to delete personal data we hold about you then we may be unable to continue providing those services to you;
      • restrict the way in which we process your personal data;
      • stop processing your data if you have valid objections to such processing; and
      • transfer your personal data to a third party.

If you wish to exercise any of the rights set out above, please contact us using the details provided in section 13.

No fee usually required  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Cookies
    • Our website uses cookies. Please see our separate Cookie Policy for more information.  (www.cardiffhendrelakes.com/cookies-policy)

13. Contact us
    • If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Email address: communityrelations@cardiffhendrelakes.com

Postal address: FREEPOST HENDRE LAKES

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.