*PLEASE READ THIS POLICY CAREFULLY BEFORE REGISTERING FOR
AN ACCOUNT WITH US*
last revised: 11th May 2018
Academic Strategy Ltd trading as Bee Landlords (we/us/our)
are committed to protecting and respecting your personal data and your privacy.
We recognise that your personal data is your property and that you have
provided it to us for specific purposes.
Unless otherwise required by law, the Information Commissioner’s
Office (ICO) guidance or best practice, or in order to perform our
contract with you, we will only process your personal data in the way we tell
you or in the way you ask us to, and we will give it back to you at any time.
policy, together with the Investor Terms & Conditions, explains how any
personal data we collect from you, or that you provide to us, will be processed
by us or any processor on our behalf.
policy applies to our contract with you. You are therefore advised to read it
carefully. Terms used within it shall have the meaning(s) given in the Data
Protection Act 2018 (Act) and/or the General Data Protection Regulation
(Regulation), as applicable
visiting our website located at beelandlords.com (our Website), or by
registering for an account with us, you accept and consent to the practices
described in this policy.
changes we make to this policy will be posted on this page. You are advised to
check back frequently as any changes will be binding on you when you continue
to use the Website after the date of the relevant change.
more information relating to your rights under this policy, please see section 10.
you have any queries relating to this policy, please contact us at email@example.com
WHO WE ARE
Academic Strategy Ltd , 71-75 Shelton,covent Garden,London,England,WC2H 9JQ. We operate the Website and we are the data controller for the
purposes of the Act and the Regulation.
are registered with the ICO to process your personal data and our registration
number is ZA510346.
data will be processed on our behalf by Share In Ltd, a company registered in
Scotland (number SC408803) with its registered office at 5th Floor, 125
Princes Street, Edinburgh, EH2 4AD (ShareIn). ShareIn host our Website
and will be the data processor for the purposes of the Act and the Regulation.
data will be held by ShareIn on their secure servers located in the Republic of
Ireland, but will be processed by staff who work in the UK.
operate on the terms of a written agreement with ShareIn relating to your
payment transactions you make through our Website will be made through our
approved third party payment gateway, encrypted through SSL technology. Any of
By registering for Account and/or otherwise
using the Website, you expressly consent to:
us and and ShareIn with the personal data necessary to allow you to use the
Website and make Investments through it;
processing of your personal data by us and/or ShareIn, or those specifically
listed third parties, in accordance with this policy; and
transfer of your personal data to those third parties listed in this policy,
for the reasons specified.
may withdraw your consent under 3.1 at any time. However, where the withdrawal
of your consent prevents us or ShareIn from verifying your identity or
otherwise monitoring who you are, you will be unable to use your Account and
make Investments through our Website OR You may exercise your rights
under 3.1 at any time, which includes withdrawing your
consent to our processing of your personal data. However, where this withdrawal
prevents us from performing our contract with you, we may not be able to
provide our goods and services to you.
WHAT WE COLLECT
may collect all or some of the following categories of data from you:
Address (including postcode)
Date of birth
Bank account or credit card details
Passport (including passport number)
Driving licence (including driving licence number)
you make an Investment over and above €2,500 (or equivalent in Sterling at the
relevant date), you will be additionally required to provide your passport and
any associated personal data contained on that document will be retained by us
or our nominated payment gateway (from time to time).
addition to the above, we will also provide you with your Account Details,
which includes your username which is either created by, or assigned to, you.
The Account Details should be remembered by you, but will be stored by us in
case you forget them.
HOW WE COLLECT YOUR DATA
The data listed in section 4 is collected in the following
you registering for an Account – this is any information you give to us
that we request from you when signing-up for an Account to use our Website.
collected – each time you visit our Website, whether through your home,
work or a public network, your own computer or mobile device, ShareIn will
information – your IP address (used by your computer or device to connect
to the internet), and any internet browser type and version details; and
information – your URLs, Projects and Properties you viewed or searched
for, your clickstream through the Website.
from third parties – we and ShareIn work closely with our authorised
payment gateway, MangoPay to verify your eligibility to make an Investment
and any payment you wish to make.
Website will use the cookies listed in section 6.2 (alpha-numeric text files
placed on your computer) to:
you from other users;
your browsing experience;
necessary improvements to our Website;
and count the number of visitors to our Website and see how they move around
the Website during use;
you when you return to our Website; and
your visit to our website, including any links you may follow.
following cookies are set to our Website for the listed purposes:
Enhances user experience by remembering session history.
Records users authentication session
Assists recognising user’s nationality and language
preferences, login, token, username recognition and
Part of a mechanism to protect against cross site scripting
Enhances user browsing experience – part of load balancing
Tracks presentation of the cookie information advice
Website additionally uses Google Analytics, a web analytics service provided by
Google, LLC (Google). Google Analytics uses analytical, performance or
targeting cookies to help analyse how you use the Website and compile reports
on your activity for us.
information generated by the cookie about your use of the Website (including
your IP address) will be transmitted to, and stored by, Google on servers in
the United States. Google will use this information for the purpose of
evaluating your use of the Website, compiling reports on your activity for us
and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do
so by law, or where such third parties process the information on Google's
behalf. Google will not associate your IP address with any other data held by
browser, however please note that if you do this your ability to use the
Website may be restricted. By using the Website, you consent to the processing
of data about you by Google in the manner and for the purposes set out above.
browser. However, if you do so, your ability to use the Website may be
for essential cookies, all cookies will expire after your session.
WHAT WE DO WITH YOUR DATA
data is primarily necessary to verify who you are when accessing your Account
and to ensure you meet our eligibility requirements in order to submit an
Application and make an Investment.
we or ShareIn will use all of your data you provide us to notify you about:
Projects or Properties listed on our Website that are similar to those you have
already Invested in, or otherwise viewed or enquired about; or
to our Website or our services.
or ShareIn use any data we collect about you (as a result of your visit to our
and improve our services (including the Website and its security);
with your inquiries and requests;
and monitor traffic and behaviours on our Website for analysis, testing,
research, statistical and survey purposes;
that any part of our Website (including any Content) is presented in the most
effective manner for you and your computer or device, and to make improvements
(where necessary); and
our Website safe and secure.
we change our services, or any applicable terms and conditions, we will contact
data we obtain about you from third parties are used for the purposes of
verifying your eligibility to submit an application and to make an investment
through our Website, and are acquired only to the extent we are unable to do so
as a result of the information you provide to us.
collected, we and/or ShareIn may retain your data for up to six years following
the date of your last Investment or the date you close your Account (whichever
is the later). This is to enable us to refer back to any transactions or
records you are involved in (should we be required to do so).
HOW AND WHY WE DISCLOSE YOUR DATA
Subject to the rest of part 8 of this policy, we
or ShareIn will only disclose your personal data to the following third parties
for the following purposes:
relevant Investee Company – in connection with your Investment, details of
which will be stated on your Application;
approved payment gateway – in order for you to make the payment(s) required
as part of your Investment;
approved transaction email provider, SendGrid, Inc - in order for us to be
able to send emails to you (NB only your email address is passed to SendGrid).
addition to the transfers contemplated by part 8.1, we or ShareIn may transfer or
disclose your personal data to:
prospective buyer of any part of the relevant business or assets in connection
with the sale (in which case, any personal data held by us or ShareIn about you
and our Account Holders will be one of the transferred assets);
with any legal obligation (such as where stated at clause 6.5 of the Investor
Terms and Conditions);
or apply any part of our Investor Terms and Conditions generally; or
our rights or our property, or those of our other Account Holders.
websites which are linked from the Website are outside of our control and not
covered by this policy. If you access those websites using the links provided,
the website operators may collect information from you which will be used by
them in accordance with their own privacy policies (if any). These policies may
differ from ours, and we cannot accept any responsibility or liability in
respect of these.
We have put in place appropriate technical and
organisational measures to help protect your personal information from
unauthorised access, use, disclosure, alteration or destruction consistent with
applicable Data Protection Laws.
Each member of staff has unique log-in details
and authentication software requires these to access the systems. Staff have
access to personal data only for the purposes of performing their roles.
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.
relation to all of your personal data, you have the following rights to ask us
or us or ShareIn (in addition to any rights you may have under the Act or the
to process your personal data for marketing purposes;
clarify what data we or ShareIn hold about you, how it was obtained, to whom it
has been disclosed and for how long it will be stored;
amend any inaccurate data we or ShareIn hold about you;
delete any of your data (where you no longer think we or ShareIn need to hold
it or you think we or ShareIn have obtained it or processed it without your
consent at any time); and
only process your personal data in limited circumstances or for limited
10.2 If you wish to exercise any of your rights at
any time, please contact us on the details contained at the beginning of this
policy in the first instance. We will require you to verify your identity to us
before we provide any personal data, and reserve the right to ask you to
specify the types of personal data to which your request relates.
you wish to exercise any of your rights, they may be subject to payment of a
nominal administration fee (to cover our costs incurred in processing your
request) and any clarification we may reasonably require in relation to your
request. Such fees may be charged where we consider (acting reasonably) that
your request is excessive, unfounded or repetitive.
data provided to you in accordance with your rights will be in a structured and