Mirastar (“we”; “us”; “our”) respect your privacy and are committed to protecting your personal information at all times. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or you otherwise deal with us, and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
1. Data Controller and how to contact us
2. Third-party links
3. Information we hold about you
4. How we collect information about you
5. Purposes for which we use your information
6. Informational Materials
7. If you fail to provide information
8. How long we will retain your information
9. Third parties with whom we share your information
10. International data transfers
11. Your rights in relation to your information
Our website and our services are not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Please note that we may update this privacy notice at any time.
Data Controller and how to contact us
Mirastar Real Estate Investment Management Limited (a company registered in England and Wales with company number 11763106 and its registered office at 10 Queen Street Place, London, United Kingdom, EC4R 1AG) is the data controller in respect of the personal information which we hold about you. This means that we are responsible for deciding how we hold and use personal information about you.
If you have any questions about how we use your personal information or you wish to contact us about your rights or if you have any complaints about our use of your information, please contact us at our main trading address:
Mirastar Real Estate Investment Management Limited
Swan House
17-19 Stratford Place
London
W1C1BQ
Or email us at: info@mirastar.eu
You have the right to complain at any time to the Information Commissioner’s Office (the regulator for data protection issues in the United Kingdom) (www.ico.org.uk) or other equivalent local data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO and will do our best to do so to your satisfaction, so please contact us in the first instance.
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 also have a social media presence for the purpose of engaging with you.
If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, or interact with us on social media, we encourage you to read the privacy policy of each website or forum that you visit or use.
Information we hold about you
To enable us to operate our business and promote our services effectively, it is necessary for us to hold and process your personal information.
Accordingly, we may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
• Identity Data includes first name, last name title, date of birth, gender, passport details (or other equivalent ID details) (and where you are the representative or employee of a business or organisation) job title and employment details.
• Contact Data includes billing address, and business or personal contact information which his your address, email address and telephone numbers.
• Financial Data includes bank account details and financial details.
• Transaction Data includes details about payments to and from you or your employer (where you are the contact) and other details of investments you or your employer (where you are the contact) have made with us, services you or your employer (where you are the contact) have purchased from us and/or contracts or leases you or your employer (where you are the contact) have entered into with us, as well as investments you or your employer (where you are the contact) have made into Mirastar-managed or sponsored vehicles.
• Technical Data includes 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 this website and other systems operated by us.
• Profile Data includes details of any interests, preferences, complaints or feedback you have communicated to us.
• Usage Data includes information about how you use our website and services.
• Informational Material / Communications Data includes your preferences in receiving informational materials and newsletters from us and your communication preferences.
We may also be required to process additional information about you in order to enable us to appropriately operate our business and promote our services effectively.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
We do not collect any Special Categories of Personal Data about you (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). Nor do we collect and information about criminal convictions and offences.
How we collect information about you
We will collect personal information directly from you. For example, you may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you: (i) apply for our services or make investments with us; (ii) provide us with any personal details in connection with your tenancy at any of our properties; (ii) subscribe to receive our services, newsletters, informational materials or other publications; or (iii) provide us with any feedback or other communications.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
In addition, we may also collect information about you from other entities in our group and from other third parties, which are third party providers or sub-contractors of technical services and payment services, analytics providers, business partners, fund administrators, professional advisers, property managers, estate agents, credit reference agencies, background check agencies and other third parties which provide services in connection with the operation of our business.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Purposes for which we use your information
We will only use your personal information where we have lawful grounds for doing so. In most cases, we will use the information we hold about you in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you or your employer.
• Where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation, any regulatory requirement and/or any other applicable law.
We have set out below a description of the ways we may use your personal information and the relevant lawful grounds for processing which we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one lawful ground has been set out below.
1) Purpose: Registering you or your employer as a new investor / customer, including carrying out due diligence on you where this is required by law.
Type of Data: Identity Data, Contact Data, Financial Data
Lawful grounds for processing
• Necessary for the performance of a contract with you
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary to comply with our legal obligations.
2) Purpose: Registering you or your employer as a new tenant at any of our properties, including carrying out due diligence on you where this is required by law.
Type of Data: Identity Data, Contact Data, Financial Data
Lawful grounds for processing
• Necessary for the performance of a contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary to comply with our legal obligations.
3) Purpose: Providing you or any relevant fund with services in connection with any contract which you or the relevant fund have entered into with us.
Type of Data: Identity Data, Contact Data, Financial Data, Transaction Data
Lawful grounds for processing
• Necessary for the performance of our contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary for our legitimate interests in operating our business effectively and providing services to you or to any relevant fund.
4) Purpose: Performing our obligations in connection with any lease which you or your employer have entered into with us in relation to any of our properties.
Type of Data: Identity Data, Contact Data, Financial Data, Transaction Data
Lawful grounds for processing
• Necessary for the performance of our contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
5) Purpose: Communicating with you for the purposes of providing services to you or any relevant
fund or in connection with making any investment with us.
Type of Data: Identity Data, Contact Data, Profile Data
Lawful grounds for processing
• Necessary for the performance of our contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary for our legitimate interests in operating our business effectively and promoting our services.
6) Purpose: Communicating with you in connection with any lease which you or your employer have entered into with us in relation to any of our properties.
Type of Data: Identity Data, Contact Data, Profile Data
Lawful grounds for processing
• Necessary for the performance of our contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary for our legitimate interests in operating our business effectively and promoting our services.
7) Purpose: Managing our relationship with you, including but not limited to reviewing and responding to any communications or feedback submitted by you via our website or by post, phone, email or otherwise.
Type of Data: Identity Data, Contact Data, Profile Data
Lawful grounds for processing
• Necessary for the performance of a contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary for our legitimate interests in operating our business effectively, promoting and improving our services and responding to any queries or complaints in relation to our services.
8) Purpose: Managing and collecting all applicable payments, fees and/or charges.
Type of Data: Identity Data, Contact Data, Financial Data, Transaction Data
Lawful grounds for processing
• Necessary for the performance of our contract with you.
• Necessary for our legitimate interests in order to perform a contract with your employer
• Necessary for our legitimate interests in processing payments made by customers / investors and ensuring that we are able to recover all sums due to us.
9) Purpose: Administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of Data: Identity Data, Contact Data, Technical Data, Usage Data
Lawful grounds for processing
• Necessary to comply with our legal obligations.
• Necessary for our legitimate interests in running our business, ensuring the provision of administration and IT services, maintaining network security and preventing fraud.
10) Purpose: Providing you with informational materials and suggestions and recommendations about our services that may be of interest to you, as well as information about events that we may organise that may be of interest to you.
Type of Data: Identity Data, Contact Data, Profile Data
Lawful grounds for processing
• Necessary for our legitimate interests in developing and promoting our services and growing our business.
Informational Materials
In the event that you request informational material from us, or you have purchased services from us or engaged in negotiations with us in connection with our services and we have information that may be of interest to you that relates to those services and, in each case, you have not opted out of receiving such materials, we may use your personal data to send you such informational material.
You can ask us to stop sending you informational materials at any time by contacting us using the details set out below:
Mirastar Real Estate Investment Management Limited
Swan House
17-19 Stratford Place
London
W1C1BQ
info@mirastar.eu
If you fail to provide information
Where we need to collect personal information by law, or under the terms of a contract we have with you or your employer and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you or your employer (for example, to provide you with services). In this case, we may have to cancel a service which we provide to you but we will notify you if this is the case at the time.
How long we will retain your information
We will retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Third parties with whom we share your information
We may need to share your information with third parties who act on our behalf or provide services to us. Your personal information will be kept secure at all times and will only be shared with such third parties when necessary. Your information may be disclosed to the following third parties:
• Other entities in our group which are based in and out of the UK, for the purpose of shared group functions.
• Professional advisers (including but not limited to legal advisers and financial advisers), insurers, bankers, auditors, financial organisations and administrators based in and out of the UK.
• Providers of certain services and functions such as hosting and cloud services, production of investor notices and financial statements, providers of client relationship management, investment management, administration and domiciliation agency services, reporting software and other software used to meet business operation needs based in and out of the UK.
• Providers of certain services and functions such as property management services, estate agency services and other services and functions in connection with the management, administration and/or maintenance of any of our properties.
• Other third parties which provide services in connection with the operation of our business and the business of our managed / sponsored vehicles, including but not limited to IT and system administration services.
• Trade associates and business partners.
• Third parties with whom we may enter into negotiations in respect of a commercial agreement, e.g. a business sale or joint business venture.
• The UK Government or any other public authorities or regulatory authorities where we are obliged to do so by any applicable laws.
International data transfers
Please note that there may be instances where it may be necessary for us to transfer your information outside the European Economic Area, e.g. if we use third party service providers from another country. In these circumstances we shall put in place suitable safeguards to ensure that your information is held securely, such as specific contracts approved for use in the UK which give personal data the same protection as it has in the UK. If you require further information about the safeguards put in place you can request it from us by contacting our Data Privacy Team using the details set out below:
Mirastar Real Estate Investment Management Limited
Swan House
17-19 Stratford Place
London
W1C1BQ
info@mirastar.eu
Your rights in relation to your information
Under the GDPR, you have a number of rights in relation to your information which we respect and aim to uphold in everything we do. These include the following:
• You can ask us for a copy of the information we hold about you and a description of how we use that information (“subject access right”).
• If you believe any information we hold on you may be inaccurate or incomplete, and you are unable to correct this information yourself, you can require us to rectify these inaccuracies (“right to rectification”).
• You can require us to erase your information in certain limited circumstances (“right to erasure” or “right to be forgotten”).
• Where we process your information using automated means on the basis of either your consent or to perform a contract, you can request that we supply such information to another party (“right to data portability”).
• You can require us to restrict our use of your information or object to how it is used in certain limited circumstances (“right to restriction of processing”).
• Where we process your information on the basis of our legitimate interests, you have the right to object to us processing your information in certain circumstances (“right to object to processing”).
• If we process your personal information for the purposes of providing you with direct marketing, you have the right to object at any time to the processing of your personal information for such purposes (“right to object to processing – direct marketing”).
In circumstances where we process your information on the basis of your consent, you have the right to withdraw your consent to the processing of your information at any time (“right to withdraw consent”).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 a 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 could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.