PRIVACY POLICY
Our privacy
commitments
The kushwaha
property ("we") respect the privacy of every person who visits,
registers with or subscribes to our websites and online publications
("you"), and are committed to ensuring a safe online experience.
This privacy
notice outlines the information we may collect about you in relation to your
use of our websites and related publications and services and how we may use
that personal data (as defined by the EU’s General Data Protection Regulation
(“GDPR”)). It also outlines the methods by which we and our service providers
may (subject to necessary consents) monitor your online behaviour in order to
deliver customised advertisements and marketing materials and other tailored
services. This privacy notice also tells you how you can verify the accuracy of
your personal data and how you can request that we delete or update it.
This privacy
notice applies to all websites operated by us (as indicated on the relevant
website) ("Sites"). For the purpose of this privacy notice
"company" shall mean any company which forms part of the kushwaha
property. By accessing and using the Sites you are agreeing to the terms of
this privacy notice.
Information
about us
Our principal
business activities:
- Provide
client solutions through a range of products and structures within commercial
asset management globally.
- Provide
market-leading research for strategic insights across the investment process.
- Co-invest
across all commercial sectors and manage funds with sector specialisms
- Digital
marketing including websites, newsletters, electronic information and data
- Organisers
and attendees of Seminars, Conferences, and Exhibitions for the asset
management sector.
Name of the
Data Controller
Kushwaha
Property
Office No-10
A-36 Gali No-2 Madhu Vihar I P Extension Patparganj
Contact
No-9899226354 9868958468
Email Id
sanatkumar47@gmail.com
https://www.kushwahaproperty.com
1. Collection
of personal data
Our primary
goal in collecting personal data from you is to give you an enjoyable
customised experience whilst allowing us to provide services and features that
most likely meet your needs.
Please note
that we do not intend to collect any personal data from children under thirteen
years of age and no child under thirteen should submit any personal data to any
of the Sites. Should we discover that any such personal data has been delivered
to any of the Sites, we will remove that information as soon as possible.
2. Types of
personal data held and its use
2.1 Customer
services and administration
We collect
certain personal data from you such as your name, job title, work and/or home
address, company, company size, job function and/or seniority, industry,
qualification levels, and telephone number and email address, in order to
register you for access to certain content and subscriptions. This information
may be supplemented with demographic information from your use of our Sites
such as your location, age, gender, purchasing preferences and interests.
This
information is used to administer and deliver to you the products and/or
services you have requested, to operate our Sites efficiently and improve our
service to you, and to retain records of our business transactions and
communications. By using the Sites and submitting personal information through
the registration process you are agreeing and have given us consent that we may
collect, hold, process and use your information (including personal information)
for the purpose of providing you with the Site services and developing our
business, which shall include (without limitation) the purposes described below
in and in accordance with the GDPR. We will endeavour to keep your information
accurate and up to date, and not keep it for longer than is necessary. We are
required to retain information in accordance with the law, such as information
needed for income tax and audit purposes. How long certain kinds of personal
data should be kept may also be governed by specific business-sector
requirements and agreed practices. Personal data may be held in addition to
these periods depending on individual business needs.
2.2 Monitoring
use of our Sites
If, as part of
our Site services, we enable you to post information or materials on our Site,
we may access and monitor any information which you upload or input, including
in any password-protected sections. Subject to any necessary consents, we also
monitor and/or record the different Sites you visit and actions taken on those
Sites, e.g. content viewed or searched for.
If you are a
registered user (e.g. a subscriber or taking a trial), when you log on, this
places a cookie on your machine. This enables your access to content and
services that are not publicly available. Once you are logged on, the actions
you take - for example, viewing an article - will be recorded (subject to any
necessary consents). We may use technology or a service provider to do this for
us. This information may be used for one or more of the following purposes:
to
fulfil our obligations to you;
- to improve
the efficiency, quality and design of our Sites and services;
- to see which
articles, features and services are most read and used
- to track
compliance with our terms and conditions of use;
- for
marketing purposes (subject to your rights to opt-in and opt-out of receiving
certain marketing communications) - see paragraph 5 below;
- for
advertising purposes, although the information used for these purposes does not
identify you personally;
- to protect
or comply with our legal rights and obligations; and
- to enable
our employees to contact and interact with you online in connection with any
content you may have viewed in our Sites.
Please see
paragraph 3 below for more information on cookies and similar technologies and
a link to a page where you can turn them on or off.
2.3 Marketing
Some of your
personal data collected, in accordance with the privacy notice, may be used by
us and/or our other group companies and third party service providers to
contact you by email, fax, telephone and/or post for sending information or
promotional material on our products and/or services and/or those of our other
group companies.
We give you the
opportunity to opt-out of receiving marketing communications and will in
certain circumstances need to obtain your consent before sending such
communications to you. Further detail can be found on the applicable Site and
in each marketing communication sent by us, our group companies or service
providers. See also "Consents and opt-outs" section below.
3. Cookies and
email tracking
We use cookies
on our Sites. This is to provide you with a better user experience when you
browse our Sites. It also enables us to improve our Sites. This section
explains how we do that.
What is a
cookie?
A cookie is a
small file of letters and numbers that we store on your browser or the hard
drive of your desktop, tablet or smartphone when you first visit our Sites. The
cookie will help our Sites, or another website, recognise your desktop, tablet
or smartphone the next time you visit. A cookie can contain Personal
Information. We detail what cookies we use, and what information they contain,
below.
What types of
cookies do we use?
We use the
following cookies:
• Strictly
necessary cookies: These are the cookies required to operate our Sites (for
example, to enable you to move around our Sites and use some of their features).
• Analytics
cookies: These allow us to recognise and count the number of visitors and to
see how visitors move around our Sites. This helps us improve the design of our
Sites.
•
Functionality cookies: These are used to recognise you when you return to our
Sites. This enables us to personalise our content for you and remember your
preferences.
• Targeting
cookies: These cookies record your visit to our Sites, the pages you visited
and the links you followed. We use this information to provide you with
targeted advertising and content we think you will be interested in.
In some cases
we may use information from third party cookies (be they analytics,
functionality or targeting cookies) to help us with market research or
improving the design of our Sites (for example, where traffic to our Sites
comes from).
How can I
block cookies?
You can block
cookies by activating the setting on your browser that allows you to refuse
all, or some, cookies. If you block all cookies (including essential cookies)
you may find that parts of our Sites do not work properly, or you may not be
able to access our Sites at all.
When do
cookies stop?
Our cookies
expire after up to two years.
Email tracking:
So that we can better understand our users' needs, we track responses to our
emails - for example, to see which links are the most popular in newsletters,
and to log and follow up responses to our marketing messages. To do this, we
use small image files that are placed within the body of our email messages.
They enable us to tell if a message has been opened and to track click-throughs
on links within the message.
Any other
purposes for which we wish to use your personal data will be notified to you
and your personal data will not be used for any such purpose without obtaining
your prior consent.
4. Third
Parties
We may pass
your personal data on to third-party service providers contracted to us in the
course of dealing with you. Any third parties that we may share your data with
are obliged to keep your details securely, and to use them only to fulfil the
service that they provide you on our behalf. When they no longer need your data
to fulfil this service, they will dispose of the details in line with our
procedures. If we wish to pass your sensitive personal data onto a third party
we will only do so once we have obtained your consent, unless we are legally
required to do otherwise.
5. Consents
and opt-outs
By consenting
to this privacy notice you are giving us permission to process your personal
data specifically for the purposes identified. Consent is required for us to
process both types of personal data, but it must be explicitly given. Where we
are asking you for sensitive personal data we will always tell you why and how
the information will be used.
You may
withdraw consent at any time by emailing sanatkumar47@gmail.com
For turning
cookies off, see the information in paragraph 3 above.
6. Disclosures
Information
collected may be shared between with any of our group companies for the
purposes listed above and as part of the processing activities.
We may also
disclose your personal data to other third parties, including, without
limitation, professional advisers, or governmental or State institutions or
regulatory authorities, where necessary in order to exercise or defend legal
rights or where required by law.
We may
transfer, sell or assign any of the information described in this policy to
third parties as a result of a sale, merger, consolidation, change of control,
transfer of assets or reorganisation of our business.
7. Public
forums, message boards, social media and blogs
Some of our
Sites make message boards, blogs or other facilities for user generated content
available and users can participate in these facilities. Any information that
is disclosed in these areas becomes public information and you should always be
careful when deciding to disclose your personal information.
8. Transfers
outside the EEA
Services on
the Internet are accessible globally so collection and transmission of personal
data is not always limited to one country. We may transfer your personal data,
for the purposes listed above, to other group companies, service providers or
other third parties which may be located in countries outside the European
Economic Area, whose laws may not give the level of protection to personal data
as within the UK. This will include transfers to Nuveen companies in the US
(who may collect some data directly from you, in relation to the sites which it
operates) and to third parties who provide us with email and marketing
services. Where we conduct any transfers we will take all steps reasonably
necessary to ensure that your data is treated securely and in accordance with
this
9.
Confidentiality and security of your personal data
We are
committed to keeping the data you provide us secure and will take reasonable
precautions to protect your personal data from loss, misuse or alteration.
The
transmission of information via the internet is not completely secure. Although
we will do our best to protect your personal data, we cannot guarantee the
security of your data transmitted to our Site; any transmission is at your own
risk. Once we have received your information, we will use strict procedures and
security features to try to prevent unauthorised access.
We have
implemented information security policies, rules and technical measures to
protect the personal data that we have under our control from:
- unauthorised
access
- improper use
or disclosure
- unauthorised
modification
- unlawful
destruction or accidental loss
All our
employees, contractors and data processors (i.e. those who process your
personal data on our behalf, for the purposes listed above), who have access
to, and are associated with the processing of your personal data, are obliged
to keep the information confidential and not use it for any other purpose than
to carry out the services they are performing for us.
10. How to
access, update and erase your personal information
At your
request, we can confirm what information we hold about you and how it is
processed. If we do hold personal data about you, you can request the following
information:
- Identity and
the contact details of the person or organisation that has determined how and
why to process your data. In some cases, this will be a representative in the
EU or UK.
- Contact
details of the data protection officer, where applicable.
- The purpose
of the processing as well as the legal basis for processing.
- If the
processing is based on the legitimate interests of us or a third party,
information about those interests.
- The
categories of personal data collected, stored and processed.
- Recipient(s)
or categories of recipients that the data is/will be disclosed to.
- If we intend
to transfer the personal data to a third country or international organisation,
information about how we ensure this is done securely. The EU has approved
sending personal data to some countries because they meet a minimum standard of
data protection. In other cases, we will ensure there are specific measures in
place to secure your information.
How long
the data will be stored.
- Details of
your rights to correct, erase, restrict or object to such processing.
- Information
about your right to withdraw consent at any time.
- How to lodge
a complaint with the supervisory authority.
- Whether the
provision of personal data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract, as well as whether you are
obliged to provide the personal data and the possible consequences of failing
to provide such data.
- The source
of personal data if it wasn’t collected directly from you.
- Any details
and information of automated decision making, such as profiling, and any
meaningful information about the logic involved, as well as the significance
and expected consequences of such processing.
Upon request,
we will provide you with a readable copy of the personal data which we keep
about you. We may require proof of your identity.
We will allow
you to challenge the data that we hold about you and, where appropriate in
accordance with applicable laws, you may have your personal information:
- Erased;
- rectified or
amended; and/or
- completed
Changes to
this privacy notice
We will
occasionally update this privacy notice to reflect new legislation or industry
practice, group company changes and customer feedback. We encourage you to
review this privacy notice periodically to be informed of how we are protecting
your personal data.
issue 8
October 2018