Privacy Policy

This policy covers the use of personal data collected and processed through the leaseholder portal operated by Nine Sutton Freehold Limited.

1. Data Controller

Company Name: Nine Sutton Freehold Limited
Registered Address: 1 Park Road, Hampton Wick, Kingston Upon Thames, Surrey, England, KT1 4AS

2. Categories of Personal Data Collected

• Usage and Technical Data: Login timestamps, IP addresses, device/browser metadata, activity logs

3. Purposes of Processing

• Security and Technical Monitoring: To protect the portal and monitor system integrity.

4. Data Processors and Third-Party Services

• Vercel: Hosting and delivery of the portal application and assets, processing minimal technical data (e.g., IP addresses, access logs).

5. International Data Transfers

Some of our service providers are based outside the UK or EEA or may store data in those locations. We ensure that any transfers are protected by Standard Contractual Clauses (SCCs) and maintain equivalent data protection standards.

6. Data Retention

We retain your personal data only as long as necessary to fulfil the purposes outlined or to comply with legal obligations. Usage logs are retained for security and auditing purposes. Data no longer needed is securely deleted or anonymised.

7. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, or data protection practices. Significant changes will be notified by email or via a notice on the portal. The "Last updated" date at the top of this policy will indicate when it was last revised.