IE-Policy

Privacy Statement, effective as of March 31, 2018

Camelot Real Estate Management Ltd and Camelot Guardian Management Ltd. (“Camelot,” “Camelot Europe,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes Camelot’s privacy practices in relation to the use of the Company’s Web sites and the related services and products offered by Camelot (collectively, the “Services”),as well as individuals’ choices regarding use, access and correction of personal information.

In order to provide our services to you we need to collect and process personal information, including financial information about you. For the protection of your data we use physical, technical and organisational measurements. We reserve the right to amend or modify this Privacy Statement at any time and in response to changes in applicable data protection and privacy legislation.

Except as set out in this Privacy Statement, we will not disclose any of your information to other parties without your permission unless we are legally required to do so by, for example, a court order or for the purposes of prevention of fraud or other crime. By submitting information into our website, you consent to the processing of this data about you by us and the product providers

If you have questions or complaints regarding Camelot’s Privacy Statement or associated practices, please contact us privacynotices@cameloteurope.com

 

1. Web sites covered

This Privacy Statement covers the information practices, including how the Company collects, uses, shares and secures the personal information you provide, of Web sites that link to this Privacy Statement (collectively referred to as “Camelot’s Web sites” or “the Company’s Web sites”).

Camelot’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2. Information collected

Potential “Consumers” (What to be a Guardian):

When expressing an interest in obtaining additional information about the Services, or registering to use the Web sites or other Services, Camelot requires you to provide the Company with personal contact information such as name, current address, phone numbers, and email address (“Required Contact Information”), date or birth, nationality and current employment situation and whether you have a partner that you want to live with and the areas you are interested to live in.

When registering for an event, Camelot may also require you to provide the Company with financial information, such as credit card number, (“Billing Information”) and the number of interested parties coming to the event. Camelot may also ask you to provide additional information related to the event such as interests that you have which relate to the event etc.

Potential “Clients”:

When expressing an interest in obtaining additional information about the Services, or registering to use the Web sites or other Services, or registering for an event, Camelot requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services or registering for an event, Camelot may also require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Camelot may also ask you to provide additional information, such as company annual revenues, number of employees, job role, industry and service/event related questions (“Optional Information”).

Other Visitors:

When Visitors apply for a job with the Company, Camelot may also require you to submit additional personal information as well as a resume or curriculum vitae (“Applicant Information”). Required Contact Information, Billing Information, Applicant Information, Optional Information and any other information you submit to Camelot to or through the Services are referred to collectively as “Data.”

As you navigate the Company’s Web sites, Camelot may also collect information through the use of commonly-used information-gathering tools, such as cookies and Google Analytics. Google Analytics includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about the collection of Google Analytics by Camelot, please click here (page 6 below).

3. Use of information collected

The Company uses Data about Camelot Customers and Clients to perform the services requested.

For an “Consumer” example, if you fill out a “Application form for room” Web form, the Company will use the information provided to contact you about your interest in the Services.

For an “Client” example, if you want to receive a newsletter “Sign up for a Newsletter” Web form, the Company will use the information provided to send you information about what you have selected as your interests.

The Company also uses Data about Camelots Attendees to plan and host corporate events, host online forums and social networks in which event Attendees may participate, and to populate online profiles for Attendees on the Company’s Web sites. Additional information on the Company’s privacy practices with respect to Data about Camelots Attendees may be found in additional privacy statements on the event Web sites, as the case may be. Please go to the website for more information on bulletin boards, blogs or chat rooms provided by Camelot in connection with its corporate events.

The Company may also use Data about Camelots Customers and Clients and Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events. Camelot will only do this if you have agreed to this on one of our web forms.

Camelot may also receive information about Customers and Clients and Attendees from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you.  This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you

Camelot uses credit card information solely to collect payment from Attendees.

Camelot uses Google Analytics to operate and improve the Company’s Web sites. The Company may also use Google Analytics alone or in combination with Data about Camelot Customers / Clients and Data about Camelot’s Attendees to provide personalized information about the Company. For additional information about the use of Web Site Navigational Information, please click here.

4. Web Site Navigational Information

Cookies, Web Beacons and IP Addresses

Camelot uses commonly-used information-gathering tools, such as cookies and Google Analytics, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). As described more fully below, we and our partners use these cookies or similar technologies to analyze trends, administer Web sites and Services, track users’ movements around our Web sites and Services, serve targeted advertisements and gather demographic information about our user base as a whole.  This section describes the types of Google Analytics used on the Company’s Web sites and Services, and how this information may be used.

Cookies

Camelot uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Camelot’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Camelot, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Email Alerts” or a “sign up to a Newsletter” or “Application for a room” Web forms) or have previously identified yourself to Camelot, you remain anonymous to the Company.

Camelot uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Web sites or Services. 

The following sets out how Camelot uses different categories of cookies and your options for managing cookies’ settings:

Web Beacons 

Camelot uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site or Service tied to the Web beacon, and a description of a Web site or Service tied to the Web beacon. For example, Camelot may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Camelot uses Web beacons to operate and improve the Company’s Web sites, Services and email communications.

Log Files, IP Addresses, URLs and Other Data

As is true of most Web sites, we gather certain information automatically to analyze trends in the aggregate and administer our Web sites and Services.  This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, Camelot uses IP addresses to monitor the regions from which Customers/Cleints and Visitors navigate the Company’s Web sites. Camelot also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

Social Media Features and Single Sign-on

The Company’s Web sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Web site, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Web site to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Company’s Web site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features. Camelot also allows you to log in to certain of our Web sites and Services using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

Do Not Track

Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user's browser DNT preference setting. Camelot does not currently commit to responding to browsers' DNT signals with respect to the Company's Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Camelot takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Public forums, refer a contact, and customer testimonials

Camelot may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Camelot is not responsible for the personal information you choose to submit in these forums.

Customers/Clients and Visitors may elect to use the Company’s referral program to inform contacts about the Company’s Web sites and Services. When using the referral program, the Company requests the contact’s name and email address. Camelot will automatically send the contact a one–time email inviting him or her to visit the Company’s Web sites. Camelot does not store this information.

Camelot posts a list of Customers/Clients and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Camelot obtains the consent of each Customer/Client prior to posting any information on such a list or posting testimonials.

6. Sharing of information collected

Service Providers

Camelot may share Data about Camelot, Visitors, Customers and Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us.  Without limiting the foregoing, Camelot may also share Data about Camelot Visitors, Customers and Attendees with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web sites, such as Facebook, for marketing and advertising on those Web sites. Unless described in this Privacy Statement, Camelot does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Third Parties

Section 4 of this Privacy Statement, Google Analytics, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers.  We may also disclose your personal information to any third party with your prior consent.

Compelled Disclosure

Camelot reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7. International transfer of information collected

Camelot has a development team in India who may use your Data for testing purposes in an isolated IT environment.  This environment is not storied electronically in India but in Europe. Our development team in India comply with all the procedures and processed of Camelot.  No Data is stored in India.

8. Communications preferences

Camelot offers Visitors, Customers/Clients, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may unsubscribe  by contacting us using the information in the “Contacting Us" section below.

9. Correcting and updating your information

Camelot may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account (portal functionality) to use our Web sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Camelot to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s Web sites and Services.  If you have registered for an account with Camelot, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable Website or Service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of Your Data associated with your account, please review the “Contacting Us” section below. For other requests to access, correct, modify or delete Your Data, please review the “Contacting Us” section below.  Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a Camelot Client, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

10. Mobile applications

Without limiting the generality of this Privacy Statement, in addition to information gathered through its Web sites or submitted to its Services, Camelot may obtain information through applications (“Mobile Applications”) that Customers/Clients or their authorized individuals (“Users”) download to, and run on, their mobile devices (“Devices”). Mobile Applications provided by Camelot may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the call history on a User’s Device to enable the User to upload that information to the Services; access calendar information on a User’s Device to enable the User to match meeting attendees with contacts submitted by the User to the Services; access the geographic location of a User’s Device to enable the User to identify contacts submitted by the User the Services who are nearby; or access contact information on a User’s Device to enable the User to sync contact information between the information that is stored on the User’s Device and the information that is submitted to the Services. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services.

Mobile Applications may provide Camelot with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which Camelot may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). Camelot may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a Camelot Mobile Application after clicking on a third-party mobile advertisement for the Mobile Application or for Camelot, the third-party advertiser may provide Camelot with certain information, such as the User’s Device identification information, which Camelot may use to track the performance of its advertising campaigns.

Customers/Clients may configure Camelot Mobile Application services, and the information accessed or obtained by the Mobile Application on a User’s Device may be affected by the Customer’s/Client’s configuration. In addition, if a Customer/Client  purchases more than one Service from Camelot and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services. Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer/Client and its organization, depending on the intended functionality of the Mobile Application. Camelot may provide updated versions of its Mobile Applications. If your mobile device’s settings permit, those updates will be downloaded and installed automatically on your mobile device. By installing a Camelot Mobile Application on your mobile device, you consent to the downloading and updating of that Mobile Application.

In addition to Mobile Applications offered by Camelot, the Company may offer platforms for the creation of third-party Mobile Applications, including but not limited to the Camelot for Mobile  platform. Third parties may obtain information from, or access data stored on, Users’ Devices to provide services associated with any third-party Mobile Applications that Users download, install, use, or otherwise interact with over a Camelot platform. Camelot’ Mobile Applications may also contain links or integrations to other Mobile Applications provided by third parties. Third parties’ use of information collected through third-party Mobile Applications is governed by the privacy statements of such third parties. The Company encourages you to review the privacy statements of third-party providers of Mobile Applications to understand their information practices.

Notices and contractual terms related to a particular Mobile Application may be found in the End User License Agreement or relevant terms of service for that application. The Company encourages you to review the End User License Agreement or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s information practices. The Mobile Application’s access to information through a User’s Device does not cause that information to be "Customer Data" under Camelot’s Master Subscription Agreement with the Customer/Client or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer/ Client account on our Services pursuant to the Customer's Master Subscription Agreement with Camelot (or a similar agreement that governs the Customer’s subscription(s) to Camelot’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply.

11. Changes to this Privacy Statement

Camelot reserves the right to change this Privacy Statement. Camelot will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

12. Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites and Services should be directed to:

UKguardians <UKguardians@cameloteurope.com> =  Existing or previous Guardian Question

UKsales UKsales@cameloteurope.com = Client Question

UKenquiries UKenquiries@cameloteurope.com = potential guardian enquires and other enquires

privacynotices@cameloteurope.com = GDPR questions and this Privacy Statement

13. Data Collection Table