1. Who are Town Centre Securities PLC / TCS?

Town Centre Securities PLC is a leading UK property investment company and with more than 50 years’ experience, a commitment to sustainable development and a reputation for quality and innovation, TCS create outstanding mixed use developments close to transport hubs in Leeds, London, Manchester, Edinburgh and Glasgow.
You can find more information and a copy of this privacy policy on our website.
https://tcs-plc.co.uk/privacy-notice

Town Centre Securities PLC processes data as a Data Controller as defined in the General Data Protection Regulation (GDPR) (EU) 2016/679.

Our IT and Data Governance Committee is responsible for compliance and can be contacted here:

• ITDGC@tcs-plc.co.uk
• 0113 222 1234

2. Purpose of this Policy?

Town Centre Securities PLC collects personal information about you in the day to day operation of the business and is committed to protecting your information and your privacy. The purpose of this policy is to explain how we collect, process and safeguard your personal information. This policy covers where we collect information through providing a lease, through visiting our website and in other ways in which you might interact with us. CitiPark is a parking operator, operating throughout the UK and is a subsidiary of Town Centre Securities PLC. Their privacy notice can be found at https://citipark.co/privacy.

3. The personal data we may collect.

The information we collect may vary depending on how you engage with us, however we will only request the minimum amount of data from you that we require. We may ask for any of the following personal information;

• Name, address, email address, telephone numbers and other contact details;
• Payment history, credit scoring and proof of identity
• Bank account details or other payment or financial information
• Curriculum Vitae
• Device Name, MAC address, Public Wifi/Internet use
• CCTV Images

To enable us to monitor and improve the website, we gather and record on our servers certain information about all users who visit the website, including without limitation, details of the operating system, browser version, internet service provider, domain name and IP address of the user, the URL which a user has come from, the parts of our website visited and the date and length of each visit (“collected information”).
We use certain cookies (small files containing information about you which are stored on your hard drive by our browser)
to monitor your use of the website.

We use the following cookies on our website:

Cookie	Name	Typical Content	Expires	Purpose
Google Analytics	utma	randomly generated number	2 years	This cookie is used to identify unique visitors to our sites. The results are sent to our Google Analytics account so that we may see how many unique visitors come to this site based over a period of time.
Google Analytics	utmb	randomly generated number	30 Minutes	This cookie is used by Google Analytics to determine the visitor session times on our sites. Each time you visit a new page on the site the cookie is set to expire within 30 minutes, if it does not find an existing cookie, a new one is created.
Google Analytics	utmc	randomly generated number	when user exits browser	This cookie is used by Google Analytics in conjunction with _utmb to determine visitor sessions. Unlike _utmb this cookie does not have an expiry date, it determines whether a new session should be created based on whether you have previously closed your browser, re-opened it and come back to the site.
Google Analytics	utmz	randomly generated number, plus information on how the site was reached (for example, directly or via a link, organic search)	6 months	This cookie is used by Google Analytics to determine the type of referral used by each visitor to arrive at our site. The cookie determines if the user has come directly to the site or via a search engine, email or email campaign. We use this data to understand how our users arrive at the website.
Laravel	laravel_session	Session ID	1 hour	We use a platform called Laravel to let our server know who you are between page loads. This cookie stores a session which links your device to your session on our website. It is only used to authenticate you between requests, not to track your behaviour or for advertising.

Most web browsers allow some control of most cookies through the use of browser settings. If you want to find out more information about cookies including how to control what cookies are put on your computer and how to delete them then visit http://www.allaboutcookies.org/

If you would like to opt out of being tracked by Google Analytics then visit http://tools.google.com/dlpage/gaoptout.

4. How and why do we collect your information?

We collect your information in order for you to use our website, engage with our property related activities and to carry out marketing activities (see consent section below).
This information will be provided by you and in some cases we will receive information from 3rd parties

Where we are required by law, we will also collect other information including proof of identity as part of the “know your client” compliance.

5. How we use your personal information?

The personal data we collect will be used for the following purposes:

• When you are a tenant or enquiring about leasing space;
  Contact details for viewings
  Financial details, credit scoring, payment history as part of our due diligence
  Proof of Identity
  Name for registration of Door Access Card into secure buildings
• When you sign up to our Newsletters via the website;
  Your name and email address in order to send the Newsletter
• When you use any of our Public Wifi services;
  Your name, email address, your device name, MAC address and use of Internet services for legal compliance.
• When you visit our website;
  We use the technical data for statistical purposes providing insight to how our website is used.
• When you apply for a position at Town Centre Securities PLC;
  We use the information provided in your covering letter and/or Curriculum Vitae as part of our recruitment process.
• When you purchase Shares in Town Centre Securities PLC;
  We maintain a register of Shareholders containing your name and address.
• When you are working with TCS which may provide access to inside information;
  We maintain a register called Insider list as required by Market Abuse Regulation.

6. Do we share your Personal Information?

We may pass your personal data on to third-party service providers contracted to Town Centre Securities PLC in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to us.
We may disclose your information to the following third parties;

• Service providers we use to help us run our business. Examples of such may include;
  • Providers of our property management software which may be hosted by them.
  • Credit Reference agencies in order to obtain the credit scoring.
  • Insurance companies regarding any claims.
  • Solicitors to process leases.
  • Provider of email processing services.

• Any person with legal or regulatory power over us (such as HMRC or the police) that may require disclosure on legal grounds.

7. How do we keep your information safe?

We take the security of data and your privacy seriously and take appropriate security measures to protect your personal information from unauthorised access. All our staff undergo annual training on data Security at a level relevant to their role. Our IT and Data Governance committee, who meet regularly, take responsibility for data security and compliance of the General Data Protection Regulation (GDPR) (EU) 2016/679.

8. How long do we keep your information for?

The below table details how long we keep your personal information.
There may be circumstances where we keep your data for longer than our standard retention period as per our Data Retention Policy.

Data Ref.	Type of Data	Purpose of Data	Review Period	Retention Period or Criteria
PT01	Name, Address, Email address and Telephone number.	Perform Credit Check	None	6 Months
PT02	Name, Address, Email address and Telephone number.	To facilitate viewing of vacant space	As Required	2 Years
PT03	Name, Address, Email address, Telephone number, payment history and credit scoring.	To process offers on Vacant space.	None	2 Years
CT01	Name, Address, Email address, Telephone number, payment history, credit scoring and Proof of identity.	Enable performance of the lease, sending rent demands and correspondence with tenant. Money Laundering/Know your customer	As Required	3 months post all outstanding matters are disposed of.
PB01	Name, Address, DOB, Employment, Personal health data	Processing of Legal Claim	As Required	3 years
CN01	Name, email address and contact details	Receiving Contractors bids / Work Instruction	As Required	6 month post all warranty matters are disposed of.
PB02	Name, Email Address	Receive Newsletters	End User Maintains or upon request	When Consent is Withdrawn
PB03	Name, Email Address, Postal Address, Telephone number	Communicate with competition winners	None	30 days
TN01	Name, Email Address	Receive Tenant only Newsletters	End User Maintains or upon request	When Consent is Withdrawn
PB04	Name, Email Address, MAC address, Device name	Provision of Free Wifi	None	30 days since last activity.
PB05	Identifying Image	Use of CCTV	None	45 Days without incident marker
SH01	Name, Address	Register of Shareholders	As Required	12 years
EM01	Name, Address, Telephone, Email Address	Process of Recruitment	None	Depends on stage reached in recruitment process. Max 24 months

9. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Town Centre Securities PLC refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

10. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Town Centre Securities PLC please speak to a member of our IT and Data Governance Committee.

ITDGC@tcs-plc.co.uk
0113 222 1234

If you wish to complain about how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority, the details for the supervisory authority are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
casework@ico.org.uk 0303 123 1113