Privacy Policy

In this Privacy Policy, “we“, “us” and “our” refers to:

  • Langham Estate Management Limited, having its registered office at London House, 9A Margaret Street, London, W1W 8RJ; and
  • Gilmoora House Limited, having its registered office at London House, 9A Margaret Street, London, W1W 8RJ.

We are a data controller for the purpose of Data Protection Legislation (as defined below).

In this Privacy Policy, references to “you” and “your” are references to a user of our website, a user of our services, our contacts, suppliers and/or other external parties; and, where you are a corporation, “you” and “your” includes any of your employees, officers, directors, agents, contractors or consultants or other relevant individuals (“Personnel“).

Introduction

We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner in accordance with Data Protection Legislation.

This policy (“Privacy Policy“) explains what information we collect from you, or that you provide to us, what we will use it for and with whom we share that information.  The policy also sets out your rights and who you can contact for more information. Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.

Before providing us with any information you are responsible for ensuring that your Personnel or other relevant individuals are aware of this Privacy Policy and the provisions of such Privacy Policy are clearly communicated to them.

In this Privacy Policy, your information is sometimes called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data.

In this Privacy Policy the term “Data Protection Legislation” means the UK General Data Protection Regulation, the Data Protection Act 2018, the EU General Data Protection Regulation, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all other similar or related legislation relating to privacy or data protection that is applicable to us from time to time.

What information we collect about you

We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Privacy Policy.

The personal data we collect and process may include:

Identify and contact information:

    • When contacting or visiting us, whether online, via phone, in writing, in person or otherwise, You may provide personal data about yourself, including your name, your contact information such as your email address and telephone number (or any telephone number used to call our customer services), date of birth, passport number, and other identification we may need to identify you;
    • We may also be required by law to collect your information that is required for “know your client”, anti-money laundering and other necessary personal data which the law requires us to collect, including copies of your passport. We will only use such information for the purpose of verifying your identity in connection with our legal requirements;

Financial and Payment Information:

  • you may provide us with your payment details / financial data i.e. your bank name, account number and sort code, and other data necessary for processing payments and fraud prevention, including credit / debit card numbers, security code numbers and other related billing information;
  • your IP address, your browser type and language;
  • your image (via CCTV);
  • Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page;
  • Information we obtain from the services we provide you with or (where you are our supplier) you provide us with, including your name, contact details, copies of ID documents or similar information and details of the services we or you receive as applicable; and
  • Information we collect when you, your Personnel or other relevant individuals communicate with us, or when each of we or you apply to receive products or services from the other, or any other time you or your Personnel contact us.

If you do not provide us with any, or all, of your personal data, we may be unable to provide you with any, or all, of our services.

In relation to any processing of special categories of personal information such as information about your health, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

How we collect information about you

  • Information you give to us when you use our services. If you use our services, including renting office space or meeting rooms, you will need to provide certain information including your identification information, address and payment details.
  • Information you give to us when you visit our premises. If you visit our premises, you will need to provide information, including your name. your image may also be captured on our CCTV.
  • Other information you give to us. This is information about you that you give us by filling in forms on our website (e.g. the contact us section) or by corresponding or doing business with us by phone, e-mail or otherwise. It includes information you provide when you register on the site for us to contact you, when you report a problem with our site or when you do business with us. The information you give us may include your name and e-mail.

Information we collect about you

Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone / tablet). They improve website use and speed – for example by automatically filling your name and address in text fields. There are more details in our section on Cookies below.

In addition, with regard to each of your visits to our site we will automatically collect certain information e.g. your IP address used to connect your computer to the Internet.

How we use your information

Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience, to provide the services you have requested or to receive services from you. We may also use the information that you have provided to ensure that the content on our website is presented in the most effective manner for you and your computer.

We use your information for the following specific purposes:

  • to administer your account and carry out our obligations arising from any contracts entered into between you (or your employer) and us and to provide you with the information and services that you request from us;
  • for our reasonable commercial purposes to run our business affairs (including quality control and administration, assisting us to develop new and improved products and services, and administering goods and services provided to us);
  • to comply with any regulatory or legal requirement on us;
  • to manage access to our premises and for security purposes;
  • to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to enforce or apply our terms with you and/or any other agreement and to protect our (or others’) property or rights;
  • to notify you about changes to our service;
  • to respond to your queries;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer;
  • to send you marketing communications including information about our offers and other services that may be of interest to you, we may send you newsletters and contact you to let you know about any new services;
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • as part of our efforts to keep our premises safe and secure; and
  • to make suggestions and recommendations to you and other users of our site about services that may interest you or them.

Legal grounds for using your personal information

The law permits us to process your personal data in the way that we do because the processing is:

  • necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations to store and disclose information where necessary and to evaluate, develop and improve our services; and/or
  • necessary for the performance of our agreement to provide you with the services that you require and/or
  • necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) you have made the data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

Sharing your information

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:

We may disclose your personal data:

  • Where necessary for the performance of our contract with you, including to provide you with our services or receive services from you;
  • If we are under a duty to do so in order to comply with any legal obligation (such as anti-money laundering obligations);
  • to enforce our policies and any agreement we have with you or with a related party, and to protect our rights and property.
  • The personal information you provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our services or receive services from you, respond to your enquiries or for any other related purposes.

We may also share your personal information with:

    • our other group companies for our internal business purposes;
    • other companies we have instructed to provide services for us;
    • other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
    • other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
    • any successor in interest, in the event of a liquidation or administration of our company.

Sharing third party information with us

If any information which you, your Personnel or other relevant individuals provide to us relates to any third party, by providing us with such information you or they confirm that you or they have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with this Privacy Policy, or are otherwise permitted to give us this information on their behalf.

Links to Other Websites

Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

How we protect your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we keep your information

We will keep the information we collect about you for as long as reasonably required for the purposes set out above or as required to comply with any legal obligations to which we are subject. In any event, we will keep your personal data for as long as we reasonably require. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

We may send you direct marketing communications, and retain your contact information necessary for this purpose, (provided that you have consented to receiving them) for as long as you do not unsubscribe from receiving the same from us. 

Transferring data outside of the EEA

In processing your personal data, it may sometimes be necessary for us to transfer your personal data to a destination outside the UK or European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors.

When we, or our permitted third parties, transfer your information outside the EEA and in such circumstances, we will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with the privacy policy and Data Protection Legislation.

Where required by Data Protection Legislation, we may enter into contracts with entities based outside the UK or EEA relating to the transfer and processing of personal data.

Opting out

Where required by Data Protection Legislation, you will be given a choice when you provide us with your personal information to opt into certain uses we may intend to make of that information, such as sending you information or offers containing updated information about us, our services and promotions. you may also be asked if you would like to receive marketing from third party organisations. you will be able to indicate your consent to each specific proposed use by checking the relevant box to opt in. We will not send you direct marketing, or pass your details to third parties for the purpose of them sending you direct marketing, without your consent.

You also have the option of “unsubscribing” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you.

Details of how to unsubscribe from direct marketing will be included on each electronic mailing we send you. Alternatively, just send an email to marketing@langhamestate.com with “URGENT – UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.

We will action any opt out request from you without delay and as soon as we can.

Your rights

At any time, you have the right:

  • to request access to or a copy of any personal data which we hold about you;
  • to request rectification of your personal data, if you consider that it is inaccurate;
  • to ask us to delete your personal data, if you consider that we do not have the right to hold it;
  • to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
  • to ask us to stop or start sending you marketing messages at any time as described above in the “Opting out” section;
  • to request restriction of the processing of your personal data;
  • request data portability (moving some of your personal data elsewhere) in certain circumstances;
  • to object to your personal data being processed in certain circumstances; and
  • to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

When you request for access to or a copy of your personal data, we will endeavour to respond within a reasonable period and will always try to respond to your requests within one month. In some instances, it may take us longer than a month to respond to your request, if your request is particularly complex or if you have made a number of requests. If this is the case, we will notify you and keep you updated. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Cookies

Our use of cookies

We set and access cookies and similar technology on your device to obtain information about how you access and use our website. This helps us to provide you with a good experience and allows us to improve the website. Unless you have adjusted your browser settings so that it will refuse cookies, the website will set cookies when you load and navigate them.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the website and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. you can find more information about cookies at http://www.allaboutcookies.org/.

Cookies can be categorised in accordance with the categories found in the ICC UK cookie guide as set out below:

  • Strictly necessary cookies – these cookies are essential in order to enable you to move around a website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
  • Performance cookies – these cookies collect information about how visitors use a website (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
  • Functionality cookies – these cookies allow a website to remember the choices a user makes, such as a user name or language preference.
  • Targeting or advertising cookies – these cookies collect information about a user’s browsing habits and are usually placed by advertising networks with the website operator’s permission.

Cookies can also be categorised in accordance with how long they are saved on your device: “session cookies” are short-term cookies that are only saved on the device’s memory for the duration of a user’s visit to the website, whereas “persistent cookies” remain saved in the device’s memory for a set period of time, even after the browser session has ended.

Refusing or restricting cookies

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the website.

Changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@langhamestate.com. you may also use these contact details if you wish to make a complaint to us relating to your privacy or to contact our Data Protection Officer.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK at https://ico.org.uk/make-a-complaint/ or on the helpline at 0303 123 1113.

Modern Slavery Policy

THE LANGHAM ESTATE

MODERN SLAVERY ACT 2015 (“MSA”) STATEMENT

FYE 31 March 2025

  • Overview

This statement is published by STL UK Group Holdings Limited (“STL“) on behalf it and its subsidiaries, including (but not limited to): Mount Eden Land Limited (“MEL“) (which itself meets the qualification threshold for reporting under section 54 of the MSA) and Langham Estate Management Limited (which provides property management services to MEL and the rest of the Langham Estate). For the purposes of this MSA statement, STL and its subsidiaries are referred to collectively as the “Langham Estate“.

The Langham Estate recognises the importance of ensuring that our business is conducted responsibly. We welcome the MSA and the transparency it encourages and take a zero-tolerance approach to modern slavery occurring in our business or supply chains.

The Langham Estate is committed to ensuring that no one in its own organisation, or our external contractors and suppliers are involved in or profit from modern slavery or human trafficking in any way.

  • Business structure

The Langham Estate’s primary business in the UK is focused on the letting of commercial property and consists of the management of a number of commercial property interests in London. In addition to the primary business of letting commercial property, the Langham Estate also operates a boutique hotel and serviced office business.

While our business is not considered to be particularly high risk from an MSA perspective and our supply chains are relatively straightforward and our direct supplier relationships are mainly focused in the UK, the Langham Estate works with a number of different third parties as part of our operations, including our tenants, and is required from time to time to undertake refurbishments, redecorations, and occasional repairs across our portfolio. In doing so, we engage with external contractors and suppliers to carry out the work on our behalf.

  • Supply chain and due diligence

The Langham Estate’s upstream and downstream supply chains includes suppliers and contractors in the following sectors:

·       Professional services (lawyers etc.) ·       Building maintenance
·       Construction ·       Contractors
·       Finance ·       Security service providers
·       Telecoms ·       Local councils
·       Energy providers ·       Cleaning service providers

We have implemented a due diligence process that is designed to limit the risk of modern slavery or human trafficking from arising in in our supply chains. As part of this due diligence process, we review supplier’s responses as part of our procurement and supplier onboarding process, which considers specific country, sector, transaction, and business partnership risks and compliance related policies and procedures (including modern slavery, anti-bribery and health and safety).

Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent. Some contractors and suppliers are appointed to the Langham Estate’s approved list of contractors following additional due diligence carried out by the Langham Estate’s main external property consultant.

Our Supplier Code of Conduct clearly outlines the standards we expect of our suppliers when conducting business. We expect our suppliers to operate fair and ethical workplaces as set out in our ‘Supplier Code of Conduct’.

  • Policies and procedures

The Langham Estate maintains and adheres to a dedicated Modern Slavery policy (the “Policy“) which reaffirms our commitment to a zero-tolerance approach to modern slavery occurring in our business or supply chains.

  • Implementation

[STL’s board of directors (the “Board“)] take overall responsibility for implementing the objectives considered in this MSA statement.

The Chief Executive Offices (CEO) will monitor progress of our efforts in this area and issues (should they arise) and report back to our Board directly.

  • Training

Training is currently provided to employees on a regular basis through a dedicated e-learning module.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Langham Estate’s slavery and human trafficking statement for the financial year ending 31 March 2024.

This statement was adopted by the board of STL in September 2024 The statement was also approved by the board of MEL in September 2024.

Signed on behalf of STL:

Philip Hardie
Chairman
September 2024