INTRODUCTION

Fortune Green Capital (FGC) is the trading name of Fortune Green Capital Limited, a company incorporated in England and Wales with registration number 08912416 and Data Controller registration number ZA260547.

FGC is the “data controller” for the purposes of the applicable Data Protection Laws, and is referred to in this notice as “Fortune Green Capital”, “we”, “our” or “us”.

In this notice, “Data Protection Laws” means the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR), each as amended or replaced from time to time.

This Privacy Notice explains:

• Who we are
• How we collect, share and use your personal data
• Where we obtain your personal data when it does not come from you directly
• How you can exercise your privacy rights

We build solid, long-lasting relationships based on trust and clarity.

Protecting your personal data and respecting your choices is part of that.

CONTACT US

If you have questions about this notice, about how we use your personal data, or if you wish to exercise any of your rights, contact us:

By email:   info@fortunegreencapital.co.uk

By post:  Fortune Green Capital Limited, 37-39 Maida Vale, London, W9 1TP

MAKING A DATA PROTECTION COMPLAINT

You have the right to complain about how we handle your personal data.

If you have concerns about the use of your personal data, or about the way we have handled a request relating to your rights, raise it with us at info@fortunegreencapital.co.uk.

We will investigate and respond to you.

If you are not satisfied with our response, you can complain to the UK Information Commissioner’s Office (ICO) using the details on their website at ico.org.uk.

We encourage you to raise the matter with us first, so we have the opportunity to put it right.

PERSONAL DATA WE COLLECT FROM YOU

We collect personal data directly from you:

• When you contact us by telephone, email, post, text message or other means of communication
• When you contact us through our website
• When you provide us with your details in connection with a property, investment or other business enquiry
• When you communicate with us in connection with a property or transaction
• When you provide us with information in connection with our services or business activities
• When you attend or participate in events or activities organised or attended by us
• When you subscribe to, or otherwise request, marketing communications from us

PERSONAL DATA WE COLLECT FROM OTHER SOURCES

We do not always obtain your personal data directly from you.

In the property and investment sector, information about property ownership and business contacts is frequently held in public registers or supplied by specialist data providers.

The table below sets out the sources we use and the data we obtain from each.

Source	Categories of personal data we may obtain
Publicly available sources and registers, including HM Land Registry, Companies House, London Gazette, EPC register and the Valuation Office Agency (VOA)	Identity Data, Contact Data, Property Data, Professional Data
Property owners, buyers, sellers, landlords and tenants	Identity Data, Contact Data, Property Data, Transaction Data
Property agents and managing agents	Identity Data, Contact Data, Property Data, Transaction Data
Business contacts and referrals	Identity Data, Contact Data, Professional Data
Independent data providers, list brokers and contractors. The datasets provided to us by these organisations may in some cases be compiled from, or informed by, information originating from credit reference agencies and other reference sources.	Identity Data, Contact Data, Property Data, Professional Data
Social media platforms and professional networking platforms	Identity Data, Contact Data, Professional Data
Third-party service providers supporting our systems and business activities	Identity Data, Contact Data, Communications Data, Technical Data

Where the information we hold about you originated from, or was informed by, a credit reference agency, you may wish to refer to that agency’s own privacy information to understand how they collect and use personal data.

WHEN WE WILL TELL YOU WE HOLD YOUR DATA

Where we obtain your personal data from a source other than you directly, we will provide you with this privacy notice, or a link to it, within one month of obtaining your data.

If we contact you before that point, we will provide it at the time of that first communication.

If we intend to share your data with someone else before either of those points, we will provide it to you then.

THE PERSONAL DATA WE PROCESS

The categories of personal data we process are:

• Identity Data includes your first name and last name
• Contact Data includes your email address, telephone number or numbers, postal address and business address
• Property Data includes information relating to properties and your relationship with, or interest in, a property
• Transaction Data includes information relating to property transactions, investments and other dealings with us
• Financial Data includes payment and banking information, and information required to manage financial transactions
• Professional Data includes information about your role, organisation and professional activities
• Communications Data includes your correspondence with us by email, telephone, post, text message or other contact channels
• Marketing and Communications Data includes your preferences in receiving marketing from us
• Technical Data includes information about how you use our website and other online services, including your internet protocol (IP) address

It is important that the data we hold about you is accurate and up to date.

Please keep us informed of any changes to your personal data, for example a change to your contact details.

HOW WE USE YOUR PERSONAL DATA

We use your personal data only where the law allows us to.

The table below sets out what we use it for, the categories of data involved, and the lawful basis we rely on.

Where we rely on legitimate interests, the interest is stated.

Purpose or activity	Type of data	Lawful basis for processing
To identify and contact potential clients, property owners, investors and other business contacts	Identity, Contact, Property, Professional	Legitimate interests: Identifying and developing property and investment opportunities, and growing our business
To communicate with you about your properties, investments and business opportunities	Identity, Contact, Property, Transaction, Communications	Legitimate interests: Maintaining commercial relationships and discussing opportunities of mutual benefit
To identify and assess potential property and investment opportunities	Identity, Contact, Property, Transaction, Professional	Legitimate interests: Researching, evaluating and pursuing opportunities as part of our core business
To provide our services and manage our business relationships	Identity, Contact, Property, Transaction, Financial, Communications	Necessary to enter into or perform a contract
To manage properties and related activities	Identity, Contact, Property, Transaction, Communications	Necessary to enter into or perform a contract
To manage property transactions and related legal, financial and administrative matters	Identity, Contact, Property, Transaction, Financial, Due Diligence	Necessary to enter into or perform a contract   Legal obligation
To verify identity and carry out appropriate checks in connection with a transaction or business relationship	Identity, Contact, Due Diligence	Legal obligation   Legitimate interests: Confirming who we are dealing with and protecting our business against fraud and error
To manage invoices, payments and other financial matters	Identity, Contact, Transaction, Financial	Necessary to enter into or perform a contract   Legal obligation
To promote our services and maintain business relationships	Identity, Contact, Professional, Marketing and Communications	Legitimate interests: Promoting our services to relevant business contacts and keeping them informed   Consent, where required
To manage enquiries and respond to requests	Identity, Contact, Communications	Legitimate interests: Responding to those who contact us
To administer, protect and improve our website and online services	Technical, Communications	Legitimate interests: Keeping our systems secure, available and working properly
To comply with our legal and regulatory obligations	Identity, Contact, Property, Transaction, Financial, Communications	Legal obligation
To establish, exercise or defend legal claims	Identity, Contact, Property, Transaction, Communications	Legitimate interests: Protecting our legal position and enforcing or defending our rights   Legal obligation

Where we process your personal data on the basis of our legitimate interests, you have the right to object at any time.

See the section on your rights below.

PROVIDING YOUR PERSONAL DATA TO US

Where we need to collect personal data to comply with a legal obligation, or under the terms of a contract we have with you, and you do not provide it when we ask, we may not be able to proceed with the transaction or provide the services in question.

We will tell you at the time if that is the case.

SHARING YOUR PERSONAL DATA 

We share your personal data only where it is necessary.

Recipients include:

• our subsidiary companies
• our investors and other business contacts
• property owners, buyers, sellers, landlords and tenants
• managing agents and property service providers
• solicitors and other professional advisers
• accountants, bookkeepers and financial advisers
• independent contractors, consultants and other suppliers
• service providers supporting our systems, communications and business activities
• third parties involved in property transactions and investments
• regulators or authorities, where required by law
• prosecuting authorities, courts and other relevant third parties connected with legal proceedings or claims
• other third parties, where we are required to share your data by law

Where we engage a third party to process personal data on our behalf, we put a written agreement in place requiring them to keep your data secure, to use it only on our instructions, and not to use it for their own purposes.

KEEPING YOUR PERSONAL DATA SECURE

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration and disclosure.

Access is limited to those with a genuine business need for it.

 INTERNATIONAL DATA TRANSFERS

Some of the third parties and service providers we work with may be based outside the United Kingdom, or may store or access personal data from outside the United Kingdom.

This means your personal data may be transferred internationally.

Where personal data is transferred outside the UK, we take steps to ensure it continues to be protected to a standard consistent with UK data protection law.

Depending on the destination, this may be because the country is covered by UK adequacy regulations, or because we put in place an appropriate transfer mechanism, such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses.

For more information about the safeguards that apply to a particular transfer, contact us using the details in the Contact Us section of this notice.

RETAINING YOUR PERSONAL DATA

We keep personal data for as long as it is required for:

• the purposes described in this notice
• the fulfilment of our legal or regulatory obligations
• the exercise or defence of any legal claims

The retention period depends on the type of data and why we hold it.

For example, records relating to a transaction or contractual relationship are kept for a period of years after the relationship ends, so that we can deal with any questions, obligations or claims that arise afterwards.

Records held for tax and accounting purposes are kept for the period required by law.

Where we hold contact details for business development or marketing purposes, we review them periodically and remove those that are no longer relevant or accurate.

When personal data is no longer needed, we securely delete or anonymise it.

DIRECT MARKETING

We may use your contact details to send you updates and information about our services, property and investment opportunities, events and other activities that may be of interest to you.

Where we are required to obtain your consent before sending you marketing communications, we will do so.

You can ask us to stop sending you marketing communications at any time, either by using the unsubscribe option in any message we send you, or by contacting us using the details in the Contact Us section of this notice.

We will action your request promptly.

PROFILING AND AUTOMATED DECICION-MAKING

We do not carry out profiling that produces legal effects concerning you, or that similarly significantly affects you.

We do not make decisions about you based solely on automated processing that produce legal effects concerning you, or that similarly significantly affect you.

As set out above, some of the information we hold may have been supplied to us by data providers and list brokers, whose datasets may in some cases be compiled from, or informed by, information originating from credit reference agencies and other reference sources.

To understand how a credit reference agency collects and uses personal data, you may wish to refer to that agency’s own privacy notice, which is usually available on its website.

YOUR DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

You have a number of rights in relation to the personal data we hold about you.

These rights may be subject to certain exceptions and limitations.

You can exercise your rights at any time by contacting us using the details in the Contact Us section of this notice.

We will not charge you for making a request, and we will respond within one month, or tell you if we need longer.

RIGHT OF ACCESS

You have the right to ask us to confirm whether we are processing your personal data and, if we are, to be given a copy of that data.

You also have the right to be told the purposes we are using it for, who we share it with, how long we expect to keep it, and, where the data did not come from you, the source it came from.

RIGHT TO rectification

If you believe we hold personal data about you that is inaccurate or incomplete, you have the right to ask us to correct or complete it.

RIGHT TO erasure

You may ask us to delete or remove your personal data where there is no good reason for us to continue processing it.

We may not always be able to comply with a request for erasure, for example where we are required to keep the data by law.

If that applies, we will explain why.

RIGHT TO restrict processing

You may ask us to suspend the processing of your personal data in certain circumstances, for example while we check the accuracy of data you have told us is wrong.

We will still hold the data, but we will not process it further while the restriction applies.

RIGHT TO object

You have the right to object to our processing of your personal data where:

• the processing is based on our legitimate interests, or
• the processing is for the purposes of direct marketing

Where you object to direct marketing, we will stop using your data for that purpose.

RIGHT to withdraw consent

Where we are relying on your consent to process your personal data, you may withdraw that consent at any time.

This will not affect any processing carried out before you withdrew your consent, or any processing carried out on another lawful basis.

RIGHT to complain to the Information Commissioner’s Office

You have the right to lodge a complaint with the ICO, the UK supervisory authority for data protection, at ico.org.uk.

When you ask to exercise any of your rights, we may need to request specific information from you to confirm your identity.

This is a security measure to make sure your personal data is not disclosed to anyone who does not have a right to receive it.

CHANGES to This Notice

We keep this privacy notice under review and may update it from time to time, for example to reflect changes in how we use personal data or changes in the law.

Where a change is significant, we will take reasonable steps to bring it to your attention.

The date at the top of this notice shows when it was last updated.