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This privacy policy explains how The Fitzrovia Partnership, Business Improvement District Limited (08235892) of 29/30 Fitzroy Square, London W1T 6LQ (“TFP, our, we, or us”) uses any personal information we collect about you. TFP has two brands; The Fitzrovia Partnership which provides services to businesses and their employees, and Enjoy Fitzrovia which provides services to individuals, consumers and the general public.

TFP may change this policy at any time in which case we shall notify you of any changes to this policy by noting this on this page of our website. The changes will apply to your use of our services after we have given notice. If you do not wish to accept the new policy you should inform us and not continue to use our services. If you continue to use our services after the date on which the change comes into effect, this indicates your agreement to be bound by the new policy.

This policy was last changed on 12 October 2018.

TFP is on the Information Commissioner’s Office (“ICO”) Register of Data Controllers; Registration Number ZA013659.

What information do we collect about you?

We collect information about you when you either register with us through Enjoy Fitzrovia programmes or if your company becomes a member of The Fitzrovia Partnership. As part of this, we may collect information when you are representing your organisation in events, projects, meetings, or when you voluntarily complete surveys, provide feedback, participate in events and training. We do not collect information through the use of cookies on our website.

Why do we collect this information

Data Protection law says that TFP is allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:

     

      • When it is in our legitimate interest

      • When you consent to it

      • When it is necessary to fulfil contractual obligations

      • When it is necessary to comply with the law

      • When it is necessary to protect someone’s life

      • When it is necessary to perform a public task in the public interest or for our official functions and the function has a clear basis in law

    A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

    Where we rely on our legitimate interest, we have detailed what it is below. For clarity, we have also detailed where consent is required.

       

        1. If you are a business or an individual acting in a business capacity, we rely on our legitimate interest to process your information in the following way:

      What we use your personal information for Our reasons Our legitimate interests
      Travel news and street news updates for businesses Legitimate interest Fulfilling membership requirements for keeping you up to date on Shaping Change
      Security issues and alerts for businesses Legitimate interest Fulfilling membership requirements on Cleaner and Safer Streets
      Inviting to security groups such as FitzBac Legitimate interest Fulfilling membership requirements on Cleaner and Safer Streets
      Business event invitations, business briefings, talks, training, savings programmes, employee wellbeing programmes Legitimate interest Fulfilling membership requirements on Reducing Costs, Events and Promotion, Sustainability, Insight
      Collecting opinions from feedback forms Legitimate interest To gain information about how to improve our services and learn what appeals to our members
      Insight updates for businesses Legitimate interest Complying with membership requirements on Insight
      Local business activities and member businesses’ offers Legitimate interest Fulfilling membership requirements on Events and Promotion
      Our loyalty scheme Legitimate interest To allow you to participate in exclusive offers if you choose to sign-up to our partner, LoyalFree

         

          1. If you are a consumer/member of the general public, we rely on legitimate interest and consent to process your information in the following way:

        What we use your personal information for Our reasons Our interests
        Recording reported issues on a local basis, including security issues Legitimate interest Being efficient in delivering customer services
        To carry out direct marketing activities to keep you informed of offers and consumer-focused activities in Fitzrovia ConsentIn line with PECR (Privacy and Electronic Communication regulations) Promoting the local area to people with an expressed interest

         How will we use the information?

        We collect information about you to provide membership services through The Fitzrovia Partnership and requested services through Enjoy Fitzrovia, and if you agree or we are otherwise permitted to do so by law, to email you about other products and services we may think of interest to you.

        TFP will not share your information for marketing purposes with third party companies other than for transactional processing.

         Using your information Your name and contact details

        How we use your name & contact details Why?
        Send you information by email, SMS, or post on membership and business activities such as meetings, briefings and updates, training, events We keep you up to date to be able to perform our contract with you
        Process membership and business activities such as training, events, meetings We do this to be able to perform our contract with you
        Send you alert messages by text, e-mail or by phone regarding security, travel, local information We do this to be able to perform our contract with you
        Fraud prevention and detection To prevent and detect fraud against either you or Fitzrovia Partnership Business Improvement District Limited – unfortunate, but absolutely essential
        Keep you informed of exclusive member offers and events We do this to be able to perform our contract with you
        Including you in security reporting groups (if necessary) To identify, detect and prevent crime in the area
        Keep you informed of local area activities, offers, events Should you opt in to receive this information including via our loyalty scheme, we do this as per your request

         Your industry, sector, occupation and job information

        How we use your industry, sector, occupation and job Why?
        Provide information, business introductions, meeting invites that are suitable to your industry, occupation and job We do this to be able to perform our commercial and membership obligations
        Offer services that are suitable for your organisation We do this to be able to provide you with relevant services to your business and its employees as part of your Fitzrovia Partnership membership
        To provide business continuity We do this to be able to perform our commercial and membership obligations

        Your membership activity information

        How we use your membership activity information Why?
        Contact with relevant information and meeting invites to business specific activities We do this to be able to provide you with information that is relevant to the business areas you may represent such as Business Watch, Sustainability, Sector Groups, FitzBAC
        Keep you informed of activities that may be of interest to you at the relevant levels, for example, training and wellbeing We do this to be able to provide you with relevant information
        Analysis based on usage and take up We do this to assess the popularity of services and activities to help develop new ones

        Your loyalty activity information (if appropriate)

        How we use your loyalty activity information Why?
        Trend analysis based on usage, points collected, redemptions We do this to help develop the programme and to provide products you like and value

         Your contact history with us

        What you’ve said to us — for example, on phone calls, during meetings and briefings, at events

        How we use your contact history Why?
        Provide customer service and support We’ve got to do this to perform our contract with you, so you receive the best service from us
        Tailor training, events, meetings, briefings Adapting our services and provisions to meet your needs

        Attendance history

        How we use your attendance history Why?
        Provide customer service and support We’ve got to do this to perform our contract with you
        Finding out what you, and other customers/members, like To ensure we are giving you what you want.
        Finding out which event, training, meeting you attended To enable analysis on what is the most successful/least successful

        Marketing

        Users of Enjoy Fitzrovia Consumer

        We would like to send you information about our services, which include offers and rewards of third-party entities within our community, by email that may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please click here or email marketing@fitzroviapartnership.com.

        Users of The Fitzrovia Partnership

        We may send you information about our services, which include offers and rewards of third-party entities within our community, by email. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please click here or email marketing@fitzroviapartnership.com.

        How long do we keep hold of your information  

        We hold on to your information for as long as is needed to be able to provide the services to you, or for as long as is necessary to provide trend analysis or business continuity only.

        If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or left your company or it is no longer needed to provide the services to you. In any event we will delete your personal data on the date within one month after the date on which you end your relationship with us.

        Your rights

        You have many rights concerning your personal information. Please quote your name and organisation (where applicable) together with your telephone number and/or email address on any requests. We would be grateful if could clearly indicate what you would like to know or what information you want a copy of (this helps us to more readily locate your data.) Your rights include:

           

            • The right to be informed about whether, where and how your personal information is being used (like this notice)

            • The right to access the personal information we hold about you

            • The right to access with whom the data may be shared

            • The right to request the period for which the data will be stored (or the criteria to determine that period)

            • The right to request the correction of inaccurate personal information we hold about you

            • The right to request that we delete your data, or stop processing it or collecting it, in some circumstances

            • The right to stop direct marketing messages, which you can also do through ‘unsubscribe’options, and to withdraw consent for other consent-based processing at any time

            • The right to request that we transfer or port elements of your data either to you or another service provider

            • The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office (ico.org.uk)

          If you would like a copy of some or all of your personal information, please email marketing@fitzroviapartnership.com or write to us at the following address:

          Fitzrovia Partnership Business Improvement District Limited

          13 Fitzroy Street

          London

          W1T 4BQ

          As part of this request, we will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.

          We will respond to all enquiries/subject access requests within 30 days. This may be extended to 90 days in exceptional circumstances for highly complex requests. You have the right to make as many access requests as you would like, however frequent and repeated requests may incur reasonable charges to cover the administrative time required. Should this arise, it will be discussed with you. You have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioners Office (ICO) and you can find out how to do this online here: https://ico.org.uk/concerns/

          Information Security

          TFP recognises that its customers are increasingly concerned about how companies protect personal information from misuse and abuse and about privacy in general. We are constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.

          We use industry standard TLS certificates to provide encryption of data in transit, for example, all access to our website, internal systems and management portals is covered by HTTPS.

          Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

          Third party service providers working on your behalf

          We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. When we use third party service providers, we only disclose the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep the information secure and not for use it for their own direct marketing purposes.

          Should we need to pass your information on to a third party, in order to deliver products and services. Our third parties include: First Mile for waste collection, Meercat for the savings programme, BloomSpace and 52 Club for room hire, Dynamo Concise Training for training, The Building Centre for working space, Arup, Transport for London (TfL), Cross River Partnership for consultations on behalf of businesses and for Insight reporting, Camden Climate Change Alliance for sustainability reporting, where we pass on your information in accordance with the foregoing or for other purposes for which you have provided consent, we will ensure that the information is transferred securely and that the third party is aware of their obligations under our privacy policy.

          Third parties will be required to remove your information from their systems as soon as it is no longer needed for the purposes it was shared for (for example providing services for an event).

          Data Storage and Security Systems

          TFP stores all personal data securely on either CRM cloud storage systems or its own internal storage systems. All our cloud storage is kept in EU based or EU GDPR compliant data centres which are managed with sophisticated high-level security systems. These storage services have their own data protection policies which we can provide you with on request. We choose storage providers with excellent security policies and systems to ensure minimal risk of data breaches and unauthorised access.

          Our internal storage and communications systems are protected by high level, managed security systems, which are updated regularly.

          Our IT infrastructure is managed by experts and is regularly reviewed to ensure security is constantly up to date.

           Other websites

          Should our website contain links to other websites, this privacy policy only applies to our website so when you link to other websites you should read their own privacy policies.

          How to contact us

          You can contact us using the details below if you wish to exercise any of your rights listed above or if you have any questions about our privacy policy or information we hold about you generally:

           Email: marketing@fitzroviapartnership.com

          Address:

          Fitzrovia Partnership Business Improvement District Limited

          13 Fitzroy Street

          London

          W1T 4BQ