MILEWAY B.V., a limited liability company (besloten vennootschap met beperkte aansprakelijkheid), incorporated under the laws of the Netherlands, with its registered office at Parnassusweg 723, (1077 DG) Amsterdam, the Netherlands, registered with the Dutch trade register under number 71555730, together with various other companies within its corporate family, which are the owners and landlords of properties.
In light of the close relationship and cooperation between the owner(s) (listed in Schedule 1 to this Third Party Privacy Notice), Mileway B.V. (as asset manager) and other entities involved in the operation of our business activities such as the property manager and financial/administration services provider in respect of the properties Mileway B.V. is managing, this privacy notice has been drawn up on behalf of both Mileway B.V., the owner(s) and the other parties involved in order to keep this document as concise and clear as possible for you. In the remainder of this privacy notice, these parties are therefore collectively referred to as “Mileway”, “us”, “our” or “we”. Should you want to be informed of the exact identity of all parties that may process your personal information – you can send your request to: [email protected] at any time and we will provide you with this information free of charge.
If you are a tenant of one of our properties, you will (in principal) only have contact with the asset and property managers of the leased premises. If you are unclear of the exact identity of the owner of the leased premises (and/or of the identity of the other parties that may process your personal information in the context of the lease agreement), you can send your request to: [email protected] and we will provide you with this information free of charge. Also, you can find the identity of the owner of your leased premises in the notification of change of landlord (inbeheerbrief).
We own and manage properties across Europe, which offer industrial units for let that can serve different business needs including commercial use, warehouse provision and commercial storage. If you visit our website: www.mileway.com, are a current tenant or enquire about our letting services, visit one of our units, or interact with us in some other way, we may collect and process some of your personal information (also known as ‘personal data’).
This privacy notice explains how we collect, use and share personal data in the course of our business activities, including:
- When do we collect your personal data?
- What personal data do we collect and process about you?
- How and why do we use your personal data?
- What lawful basis do we rely on to process your personal data?
- When do we share your personal data and with whom?
- How you can manage your marketing preferences?
- How we protect and store personal data?
- What are your legal rights?
- Can this privacy notice change?
- How to contact us?
In accordance with the applicable data protection and privacy legislation (including the GDPR), we qualify as the controller of your personal data. This means we decide how your personal data is processed and protected. As a controller, we are responsible for keeping your personal data safe.
Links to other websites:
Our website and online services may, from time to time, contain links to external websites, plug-ins and applications including (but not limited to) social media platforms. This policy does not apply to these third-party services, and we are not responsible for the privacy policies or practices or the content of any third party. Please review third-party privacy policies and, where applicable, your privacy settings of such third parties.
1. When do we collect your personal data?
We collect information about you if you:
- purchase one of our products or services;
- lease one of our properties;
- contact us (including through our website) to enquire about our products, services or properties, or for any other reason;
- work for a company that purchases one of our products or services or leases one of our properties;
- work for a company that we lease from or purchase products, property or services from.
We may collect the information about you via the former owner or manager of the products, property or services that you use or that the company you work for uses.
2. What personal data do we collect and process about you?
Below we outline the categories of personal data we may collect and process about you. Whether we collect this information will depend on how you interact with us. Please see the How and why do we use your personal data? section of this privacy notice to understand more.
- Name and contact information: first name, last name, phone number (including work and personal phone numbers), postal address (including residential and business address) and email address.
- Tenancy information: including address and any other personal data about you in the lease and related documents. If you are viewing properties let by us, we will also ask for information about your property requirements and preferences.
- Financial information: bank account details, payment card details, billing address, details about payments made to and from you, and financial statements.
- Technical information: internet protocol (IP) address used to connect your device to the Internet, 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.
- Usage information: interaction information about your use of our services including the full Uniform Resource Locators (URL), clickstream, content you viewed or searched for, content response times, download errors, length of visits to certain content, interaction information (such as scrolling, clicks, and hover-overs), and methods used to browse away from content.
- Location information: We may derive your approximate regional location from your IP address.
- Social media platform information: If you interact with us through third party sites, such as, LinkedIn, we may collect personal data from you. For example, if you tag us in a social media post or otherwise interact with our social media adverts and accounts.
- Audio and video recordings: We may make voice and video records of any meetings you attend. We operate closed circuit television systems (“CCTV”) which may record you for security and safety purposes if you visit our premises or a property we let. We are responsible for the operation of our CCTV system and work with specialist providers who act as data processors to operate the system. Cameras may be placed both externally and internally in public and common areas. Signage on site will indicate the presence of cameras.Our customers may have their own CCTV or similar security systems in operation in their dedicated spaces. We are not responsible for the operation of these systems and any questions about them should always be directed to the relevant occupier or police, as applicable.
- Access information: If you are a customer or visiting a customer at one of our spaces, your name and organisation, job role, together with the time and date of your visit may be recorded. You may be issued with a security pass, these passes may, if scanned, enable us and our security partners to identify your location, arrival and exit times on our premises.Our customers may also make additional security arrangements which involve the collection of your personal data. You should ask to see their privacy notices for more information.
- Compliance information: We sometimes collect information from you and third-party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes. For example, we may need to collect identification information such as your date of birth, identity card and passport.
We may also receive your personal data from third party providers and partners which we work with, including our advertising partners and networks. For more information, please see How we use Cookies?
3. How and why do we use your personal data?
We use your personal data to manage our relationship with you, including to:
- take steps to enter into a tenancy or related agreement with you (including to register you as a new or prospective tenant and run background and credit checks where required);
- send you information about properties that we think you might be interested in and showing these properties to you;
- administer our tenancy services to you, including managing payment transactions with you, liaising with you on matters
- related to your tenancy, and notifying you of changes to this privacy notice; and contact you and to respond to any correspondence we receive from you.
We use your personal data for our website and services we make accessible from it, including to:
- deliver our website and services to you as requested, including the display of our website and to ensure content is presented in the most effective manner for you and your device;
- manage internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- keep our website and services safe and secure;
- analyse your use of our website and services; and
- understand where you are accessing our services from to deliver location specific content to you.
We use your personal data for advertising and marketing purposes, including to:
- send you direct marketing in the form of emails, text, SMS/MMS (as applicable) and to understand its effectiveness – you may receive marketing communication from us if you have requested information from us, have consented to marketing or have used our services and you have not opted out of receiving marketing or where we are otherwise legally permitted to send you marketing. (For further information on direct marketing, please see the How you can manage your marketing preferences? section of this privacy notice below);
- analyse your interaction with social media platforms and our content; and
- enable cookies and other similar technologies (together with third parties).
We use your personal data for other purposes, including to:
- work with third parties (which will include sharing your Personal Data) – please see the When we share your personal data and with whom? section of this privacy notice for more information;
- to protect our business from fraud, money-laundering, breach of confidence, theft and other financial or business crimes;
- for quality assurance and training purposes;
- to comply with our legal and regulatory obligations and bring and defend legal claims; and
- to protect the security of our premises and ensure you are able to safely access and move around our premises.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please see the How to contact us? section of this privacy notice for more information.
If we use your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so.
4. What lawful bases we rely on to process your personal data?
We must have a legal basis for each use of your personal data. We use the following personal data for each purpose listed below and set out the lawful basis we rely on.
| Purpose | Categories of personal data | Lawful basis |
|---|---|---|
| To manage our relationship with you | ||
| To take steps to enter into a tenancy or related agreement with you. |
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| To send you information about properties that we think you might be interested in and showing these properties to you. |
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| To administer our tenancy related services to you. |
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| To contact you and respond to any correspondence we receive from you. |
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| For our website and services we make accessible from it | ||
| To deliver relevant website services / content to you in the most effective manner for you and your device. |
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| To manage internal operations, including troubleshooting, data analysis, testing, research and statistical purposes. |
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| To keep our website and services safe and secure. |
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| To analyse your use of our website and services. |
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| To understand where you are accessing our services from to deliver location specific content to you. |
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| For advertising and marketing purposes. | ||
| To send you direct marketing and to understand its effectiveness. |
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| To analyse your interaction with social media platforms and our content. |
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| To enable cookies and other similar technologies to work. |
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| Other | ||
| For quality assurance and training purposes. |
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| To protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes. |
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| To protect the security of our premises. |
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| To comply with our legal and regulatory obligations and bring and defend legal claims. |
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Where we rely on our legitimate interest to process your personal data, we will only do so if we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes, and we will only process your personal data as necessary for the purposes described above.
5. When do we share your personal data and with whom?
We may share your personal data, where reasonably necessary for the purposes set out above, with the following categories of recipients:
- with other companies within our group, our owners and affiliates including Blackstone, where this helps us to better operate our business;
- an entity who takes over our business and assets, or relevant parts of them;
- with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted services to us. These include property managers, professional advisers, marketing and advertising companies, CCTV service providers and IT service providers who help manage our IT and back office systems;
- analytics and search engine providers that assist us in the improvement and optimisation of our website or services and advertising;
- with government organisations and agencies, law enforcement, regulators, which may include data protection supervisory authorities such as the Dutch Data Protection Authority and the UK Information Commissioner’s Office, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
- with banks and payment providers to authorize and complete payments; and
- with credit reference agencies and organisations working to prevent fraud.
Processing your personal data outside the EEA and the UK
We are based in the European Economic Area (“EEA”) and the UK. However, in processing your personal data in accordance with this privacy notice we may sometimes transfer your personal data outside of the EEA and the UK. Where we do this, we ensure a similar degree of protection is afforded to your personal data by ensuring that at least one of the following safeguards is implemented:
- We transfer your personal data to countries that have been deemed to provide an adequate level of protection by the supervisory authority (i.e. the European Commission and/or the UK Secretary of State) that is responsible for an adequacy assessment.
- We implement certain standard contractual clauses with the recipients of your personal data to safeguard transfers to countries outside of the UK / EEA, which do not benefit from a finding of adequacy.
Please contact us if you would like further information about the specific mechanism used by us when transferring your personal data out of the EEA and/or the UK.
6. How you can manage your marketing preferences?
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you; and
- you can ask us to stop direct marketing at any time and you can ask us to stop sending email marketing, by emailing [email protected].
We recommend you routinely review the privacy notice and preference settings that are available to you on any social media and other third-party platforms as well as your preferences within your account with us.
7. How we protect and store personal data?
Security
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.
Measures we take include:
- placing confidentiality requirements on our staff members and service providers;
- limiting access to your personal data to those employees, contractors and other third parties who have a business need to know;
- destroying or permanently anonymising personal data if it is no longer needed for the purposes for which it was collected; and
- following strict security procedures in the storage and disclosure of your personal data to. prevent unauthorised access to it.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information.
Storing your personal data
We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy notice. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner.
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.
In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements, or if we need an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
8. What are your legal rights?
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data:
- to access your personal data;
- to rectify / erase your personal data;
- to restrict the processing of your personal data;
- to transfer your personal data;
- to object to the processing of your personal data;
- to object to how we use your personal data for direct marketing purposes;
- to obtain a copy of personal data safeguards used for transfers outside your jurisdiction; and
- to lodge a complaint with your local supervisory authority.
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal data to you we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by emailing [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access your personal data
You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data may be transferred.
Right to rectify or erase your personal data
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
You can also request that we erase your personal data in limited circumstances where:
- it is no longer needed for the purposes for which it was collected;
- you have withdrawn your consent (where the data processing was based on consent);
- following a successful right to object (see right to object below);
- it has been processed unlawfully; or
- to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal data
You can ask us to restrict the processing of your personal data, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where:
- we have your consent;
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal data
You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the EEA and/or the UK.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement), which in the UK is the Information Commissioner’s Office and in the Netherlands is the Data Protection Authority (Autoriteit Persoonsgegevens) if you have concerns about how we are processing your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
9. Can this privacy notice change?
This privacy notice was last updated on the date mentioned at the top of it. We reserve the right to change this privacy notice from time to time. If we decide to change this privacy policy, we will post the changes on our website, so our visitors and customers are aware of what information we collect, how we use it, and under what circumstances, if any, we share it. Please check back frequently to see any changes.
10. How to contact us?
The primary point of contact for all issues arising from this privacy notice is our Data Protection Officer, who can be contacted in the following ways:
E-mail: [email protected]
Post: Mileway B.V.
Attn. Legal Team
Parnassusweg 723
1077 DG, Amsterdam The Netherlands
If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.