Privacy Policy

Exchange Street Buildings Ltd. (ESB) is the owner and operator of leased real estate in the United Kingdom.

ESB takes the privacy of its customers and users seriously. We take care to put measures in place to comply with relevant data protection and privacy laws, and preserve the security and integrity of all the information provided to us and/or collected from those who use our services.

ESB is registered with the UK Data Protection Authority (the ICO) under number ZB562557.

This policy explains how and why we use or share your personal information, and your choices and rights regarding that information.

What Data do we collect?

In order to provide our services, we collect the following information:

• Information received in the course of general enquiries via webform, email, telephone, or post from potential customers. Personal data may include names, email addresses, and contact details, along with information that the user submits within their enquiry.
• Information entered into our systems for the use of our facilities, which may include names, email addresses, contact details, and payment information.
• Information captured by cookies for essential services, as well as analytics, and advertising purposes. Personal data may include Unique Online Identifiers, IP Addresses, and Mac Addresses.
• CCTV is used within and around the building for the security of all tenants. Cameras will capture and record images in real time.

ESB is the Data Controller for these types of data and processes the data based on contractual arrangements, having gained affirmative consent, or our legitimate interest to provide our products and services.

How do we use your data?

In general, customer data is used to facilitate their use of our buildings and services. Data may be used by ESB for the following purposes:

• To communicate with out customers or prospective customers via email, telephone, and post.
• To facilitate the use of our services, including access to our premises, connecting to network infrastructure, and administration of payments.
• To filter information available at the ESB website, or optimise its presentation to improve, speed up, or streamline the experience of using it.
• To carry out direct marketing activities to customers and prospective customers.
• To ensure the security of our tenants and customers.

Data that has been submitted to us may be combined with other information for the above purposes.

All data is stored and processed within the UK or EEA.

For how long do we keep your data?

All information and user data relating to our tenants, customers, and prospective customers, is retained only for as long as is contractually agreed, required by law, or required in order for it to be used for its intended purpose.

Data submitted by prospective customers via our dedicated webform is automatically deleted after 2 years.

IP Addresses and Device IDs are pseudonymized as soon as we receive them.

Cookies are typically deleted from user devices after 30 to 60 days.

CCTV footage is stored securely for 30 days before being permanently deleted, unless circumstances require that it be kept for longer, in which case, all reasonable endeavors will be taken to notify affected subjects.

With whom do we share your data?

We keep your information confidential, but there are some circumstances in which we may be required to share it:

• We may disclose information to our personnel in so far as is reasonably necessary for the purposes described in this policy.
• We may disclose information to any law enforcement agency that requests it in connection with the commission of an offence, or to comply with applicable laws and lawful government and/or regulatory requests.
• In the event of a corporate transaction, such as the purchase or sale of our business or assets, we may disclose relevant information to the purchaser involved.

We may also share your information with some third-part suppliers and subcontractors to assist in the provision of services to our customers. In all cases, we will ensure that your information is safeguarded to the minimum standards outlined in this policy, and that it is not used for any unauthorised purposes. Activities carried out by third party service providers include:

Your Rights

We will honour your rights under applicable data protection laws. These rights are not absolute, and they do not always apply in all cases. You may:

• Request access to your information and information related to our use and processing of your information.
• Request the correction or deletion of your information.
• Request that we restrict our use of your information.
• Request a machine-readable copy of your information or that your information be transferred to other IT systems.
• Object to the processing of your information for certain purposes.
• Withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

If you wish to make a request regarding any of these rights, you should contact our Data Protection Officer at hello@exchangestreetbuildings.com. We will assist with all requests but may charge an administration fee in some instances. We will always make you aware of this in advance.

Keeping your data safe

ESB takes all reasonable measures to ensure that user and customer information is stored as securely as possible and not lost, misused, or altered.

Our infrastructure is hosted in an enterprise-level, highly secure data centre with UPS, fire detection and suppression systems with a sophisticated environment management system. Fortigate Firewalls at all our sites provide site-to-site VPN tunnels. Strong encryption and DG group, short key life, and the latest VPN technologies (PFS, replay detection) ensure the highest level of security. Access to user data is restricted to those members of staff who must use it in order to carry out their responsibilities.

Data transmission over the internet is inherently insecure, and despite our best efforts, it is impossible to guarantee the security of data sent over the internet. Users are reminded to be cautious when sending particularly sensitive data and to consider additional security measures, such as file encryption and SFTP services.

Getting in touch

We hope that you’ll never need to make a complaint, but if you do, or if you have any questions about how we use your personal data, please don’t hesitate to get in touch.

Our Data Protection Officer (DPO) is Richard Savelli, and you can reach him at hello@exchangestreetbuildings.com.

You may raise a compliant about how we use your personal information directly to the Commissioner’s Office by visiting https://ico.org.uk/concerns.

Children’s Data

We do not intentionally collect personal data from children (under 13) for any reason. If you have reason to believe that we have, please get in touch and we’ll delete it.

Revision

We may revise this policy at any time in order to reflect changes to our services, or to comply with changes to relevant legislation. We reserve the right to do so without notice. We advise you to check this page often in order to ensure you are aware of any recent revisions.

Cookie Policy

A cookie is a piece of information that a website puts on your computer so that it can remember something about you or your device at a later date. ESB use several cookies and online identifiers to distinguish you from other users of our website, and to ensure that our facilities and business services function properly.

This policy explains what cookies (including third-party cookies) we use on our website, and how you can refuse or withdraw your consent to cookies. You can find more information about cookies at www.allaboutcookies.org, and www.youronlinechoices.eu.

What type of Cookies and Identifiers do we use?

How do you opt out of using cookies?

When using our website, you may choose to opt out of the use of non-essential cookies by selecting the ‘reject’ option on the cookie consent notice, or by altering the settings of your internet browser or device. For more information about how to do this, look at your browser or device ‘help’ section.

Please note, if you reject non-essential cookies, some aspects of our website or services may not function as efficiently, or at all. If you have selected this option and find that you are having difficulty using the website, you may need to opt back in. You can do this by refreshing the page and selecting ‘Agree’ on the cookie consent notice.

To opt out of cookies provided by third parties, or to view relevant privacy information and details, please see the links below:

Cookie Details

Cookie Table

The following table provides information about the cookies that we use, including their domain, purpose, and retention policies.