Third-Party Privacy Notice - Logicor Group

LOGICOR GROUP

THIRD PARTY PRIVACY NOTICE

This Privacy Notice sets out what personal data is collected by Logicor, how it is used and what rights you have in relation to your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE

Logicor is committed to respecting your privacy and protecting your personal data. This privacy notice, together with our Terms of Use and any other documents referred to in it, informs you how we collect and process your personal data within the European Economic Area and the United Kingdom, including through your use of our website, regardless of where you visit it from. This privacy notice also tells you about your privacy rights and how the law protects you. This privacy notice is made available for information purposes only and does not create any contractual rights or obligations for us or you.

Our website is not intended for children and we do not knowingly collect data relating to children.

Controllers

Logicor Group comprises Eurocor II S.à r.l. (incorporated in Luxembourg with registration number B215.464) and Eurocor III S.à r.l. (incorporated in Luxembourg with registration number B215.465) with registered offices at 2A, rue Eugène Ruppert, L-2453 Luxembourg, and the respective direct and indirect subsidiaries of these two entities.

The following Logicor Group companies are the data controllers and are responsible for your personal data: Eurocor II S.à r.l., Eurocor III S.à r.l. and the respective direct and indirect subsidiaries of these two entities, including, without limitation, the following employing entities: Logicor Europe Limited, Eurocor Treasuryco S.à r.l., Logicor Treasuryco S.à r.l., Italian Logistics Pledgeco S.à r.l., Logicor (Scorpion) Pledgeco S.à r.l., Logicor Europe Holdings S.à r.l., Logicor Europe Holdings II S.à r.l., Logicor Management S.A., Logicor Gestion SAS, Logicor Deutschland GmbH, LOG-IQ GmbH, Logicor (Space) Manco Oy, Terminal Real Estate Sweden AB, Harbour (Logistics) Pledgeco S.à r.l., Logicor Denmark, Logicor Italia S.r.l., Logicor Management (Polska) Sp. Z o.o., Logicor Management Czech Republic s.r.o, Logicor Beheer B.V., Logicor España S.L., Logicor Portugal Sociedade Unipessoal LDA, Logicor Management Hungary Kft and Logistic Contractor S.r.l.

This privacy notice is issued on behalf of the Logicor Group so when we mention "Logicor", "we", "us" or "our" in this privacy notice, we are referring to the relevant entities in the Logicor Group responsible for processing your data.

Contact details

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Logicor Group’s General Counsel:

Full name of legal entity:	Logicor Europe Limited
Name of data privacy contact:	Sheena Singla
Email address:	[email protected]
Postal address:	Fourth Floor, 30 Broadwick Street, London, W1F 8JB, United Kingdom of Great Britain and Northern Ireland

You have the right to make a complaint at any time to the supervisory authority in your country of residence. A list of EEA supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en, and in the UK, this is the Information Commissioner's Office (“ICO”): ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority so please contact us in the first instance.

Informing us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

For the purposes of this notice, personal data, or personal information, means any information relating to an identified or identifiable natural person. It does not include anonymised data.

We may collect, use, store and transfer different kinds of personal data about you depending on the relationship we have with you. We process the following categories of personal data:

Identity Data may include your first name, maiden name, last name, username or similar identifier, title, job title, photograph, personal data contained on a copy of your passport or another ID document provided to us for verification of identity purposes.
Contact Data may include your billing address, delivery address, email address, telephone numbers, social media account/handle.
Financial Data may include bank account and other payment related information.
Technical Data may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data may include your username and password, your interests, preferences, feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include a record of your preferences in receiving marketing from us and our third parties, your communication preferences, your photograph and any video recordings you partake in for our marketing purposes.
Know Your Customer or Supplier Data may include your Identity Data, Contact Data, date of birth, gender, whether or not you are or have been a politically exposed person (“PEP”) or connected to such a person, whether or not you are or have been a person subject to any sanctions, and whether or not any negative publicity is or has been associated with you, in each case, globally. In certain jurisdictions where we are under a legal obligation to conduct customer due diligence for anti-money laundering and anti-terrorist financing purposes, further categories of data may be processed, such as personal data contained on a copy of your passport or another ID document, his or her place of birth, nationality, tax number (or equivalent), home / habitual residence address, details of directorships held. PEPs are also requested to provide a description of the public office(s) they hold/have held, their source of wealth and certain other information.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or criminal offence data about you, except where relevant to a politically exposed person or sanctions check carried out on a customer of business partner (see above) or with respect to measures implemented to protect against serious cross-border threats to health (such as pandemics).

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods, including:

Direct interactions: You may provide data by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

apply for or enquire about our products or services;
enter into any agreement with us;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us some feedback via a satisfaction survey conducted by Logicor or otherwise; or
log-in to a secure area of our website.

Automated technologies or interactions: As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following sources:
- analytics, advertising or search information providers such as Google based outside the EU;
- advertising networks such as Google Ads based outside of the EU;
- search information providers such as Google based outside the EU.
Identity and Contact Data from publicly available sources such as Companies House, Royal Mail and the Electoral Register.
Identity and Contact Data from your own employer or someone you work with; third party professional advisers (such as external lawyers, etc.), brokers, building contractors, consultants, agents; property managers; asset managers; leasing agents; and other similar providers of property services.
Identity and Contact Data from a third party seller and/or purchaser of asset(s) or share(s) we are considering purchasing and/or selling.
Know Your Customer or Supplier Data from providers of screening and associated due diligence purposes.

Please contact us if you have any questions regarding the source of your personal data.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

Performance of contract - we process your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation - we process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legitimate interest - we process your personal data where it is in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where required by law in relation to sending third party direct marketing communications to you via email or text message, or when collecting personal data from non-essential cookies. You have the right to withdraw consent to marketing at any time by emailing us at [email protected], and can reject non-essential cookies using the consent management tool on our website.

Purposes for which we will use your personal data

We have set out below a description of all the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also identified what our legitimate interests are, where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you, or an entity of which you are a director or employee, as a new customer, including through use of internet-based tele- and videoconferencing platforms necessary for remote meetings	(a) Identity (b) Contact (c) Know Your Customer or Supplier	(a) Performance of a contract with you (for customers who are natural persons) (b) Necessary for our legitimate interests (to register a representative of a business customer)
To process and deliver your order, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts owed to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition, complete a survey or participate in our marketing materials	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our advertising	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Consent (to the extent we rely on non-essential cookies or similar technologies) (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Consent (where required by electronic marketing laws) (b) Necessary for our legitimate interests (to develop our products/services and grow our business)
To enter into a business relationship with you to provide you with services and/or goods, or to receive any services and/or goods from you	(a) Identity (b) Contact (c) Financial (d) Know Your Customer or Supplier (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to provide or to receive goods and/or services)
To manage our customer, intermediary and other business relationships, including when we need to comply with a requirement to verify the identity of individuals we do business with, whether remotely or in person	(a) Identity (b) Contact (c) Financial (d) Know Your Customer or Supplier (e) Marketing and Communications	Necessary for our legitimate interests (to seek to ensure our business is conducted and managed appropriately, efficiently and with a view to enhancing client service and/or the service being received by us) (b) Necessary to comply with a legal obligation
To implement measures to protect against serious cross-border threats to health (such as pandemics)	(a) Identity (b) Contact (c) Health	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to protect our staff, customers, suppliers and visitors from serious threats to their health) (c) For health data additionally reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health
To meet all legal, regulatory and ethical obligations applicable to the Logicor Group	(a) Identity (b) Contact (c) Financial (d) Know Your Customer or Supplier (e) Marketing and Communications	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to ensure we meet all legal, regulatory and ethical obligations incumbent on us)

Marketing communications

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may, subject to applicable local laws, receive marketing communications from us if you have:

requested information from us or purchased goods or services from us; or
if you provided us with your details when you entered a competition or registered for a promotion, downloaded a guide or subscribed to a newsletter; and
in each case, you have not opted out of receiving that marketing.

To the extent required by law, we will obtain your consent before sending you electronic marketing communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.

You can ask us to stop sending you marketing messages at any time by either:

following the opt-out links on any of our marketing messages;
sending us an email to [email protected].

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchased, warranty registration, product/service experience or other transactions. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Service providers who provide IT and system administration services.
Service providers based in the UK, Luxembourg, France, Germany, Finland, Sweden, Denmark, Italy, Poland, the Netherlands, Spain, Portugal, Hungary, Romania, Czech Republic, Austria, Belgium, Slovakia, Cyprus, Guernsey, Jersey and Russian Federation who provide any property or asset-related services (including corporate and other support services), or third party screening and associated due diligence services.
Other companies within the wider Logicor network, which includes our shareholders in China and in the United States of America, lenders and other investors.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Professional and other advisers, including (but not limited to) lawyers, bankers, auditors, accountants, notaries, insurers, property managers, asset managers, marketing agencies, voice-of-customer research and customer experience consultancies and other consultants, business partners, suppliers and subcontractors acting as processors or controllers, in each case, based in the UK, Luxembourg, France, Germany, Finland, Sweden, Denmark, Italy, Poland, the Netherlands, Spain, Portugal, Hungary, Romania, Czech Republic, Austria, Belgium, Slovakia, Cyprus, Guernsey, Jersey and Russian Federation.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and in other jurisdictions within the EEA where Logicor has presence who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not knowingly permit our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may share your personal data with other companies within the wider Logicor network, which includes our shareholders in China and in the United States of America, lenders and other investors. This may involve transferring your data outside the UK and the European Economic Area (“EEA”).

Many of our external third party suppliers of various services to the Logicor Group are based outside the UK and the EEA (including the United States of America, Canada, Russian Federation, Guernsey and Jersey) so their processing of your personal data will also involve a transfer of data outside the UK and the EEA.

Whenever we transfer your personal data out of the UK and the EEA, unless a specific derogation applies, we seek to ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where possible, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK government;
Where we use certain service providers which are outside of the EEA and where they are in jurisdictions where there is not deemed to be an adequate level of protection of personal data, we may use specific contractual clauses or contracts approved by the European Commission or the UK government which give personal data the same protection it has in Europe ("model clauses"); and
Transfers within the Logicor group of companies use model clauses.

Additionally, Logicor will, where necessary, implement supplementary measures with respect to the transfer of your Personal Data to countries that may not offer a level of protection of personal data equivalent to that offered within the EEA or the UK in order to ensure an adequate level of data protection.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA or to obtain a copy of any model clauses in place, although some details may be redacted for confidentiality reasons.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those members of staff, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

With respect to our website, the security of your information depends in part on the security of the computer you use to communicate with us (including using an up-to-date browser and appropriate anti-virus software), and the steps you take to protect the confidentiality of your account information, including your password.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise (so that it can no longer be associated with you) or, where permitted by law, pseudonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Subject to certain exemptions, and in some cases dependent upon the legal basis we rely upon (see section 4 above), you have certain rights in relation to your personal data:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us at [email protected]. We may provide additional ways for you to exercise your rights from time to time.

You will not normally have to pay a fee to exercise a right. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

In Italy, in the event of your death, the rights relating to your personal data set out above can be exercised by anyone having an interest, or acting to protect you as your representative, or for family reasons worthy of protection (the "Interested Party"). You can expressly prohibit the exercise of some of the above rights by the Interested Party by sending a written declaration to Logicor to the email address indicated above. The declaration may be revoked or amended later in the same manner.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if, for example, your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. COOKIES

When you first visit our website you can choose whether or not to consent to all non-essential cookies. If you disable or refuse essential cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy here.

11. CHANGES TO THIS NOTICE

Any changes we may make to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

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