PRIVACY POLICY

This privacy policy explains how The Fitzrovia Partnership, Business Improvement District Limited (08235892) of 11-13 Bayley Street, London, WC1B 3HD (“TFP, our, we, or us”) uses any personal information we collect about you. TFP has two brands; The Fitzrovia Partnership which provides services to businesses and their employees, and Enjoy Fitzrovia which provides services to individuals, consumers and the general public.

TFP may change this policy at any time in which case we shall notify you of any changes to this policy by noting this on this page of our website. The changes will apply to your use of our services after we have given notice. If you do not wish to accept the new policy you should inform us and not continue to use our services. If you continue to use our services after the date on which the change comes into effect, this indicates your agreement to be bound by the new policy.

This policy was last updated on 1 June 2024.

TFP is on the Commission Office (previously Information Commissioner’s Office, ICO)  Register of Data Controllers; Registration Number ZA013659.

What information do we collect about you?

We collect information about you when you either register with us through Enjoy Fitzrovia programmes or if your company becomes a member of The Fitzrovia Partnership. As part of this, we may collect information when you are representing your organisation in events, projects, meetings, or when you voluntarily complete surveys, provide feedback, participate in events and training. We do not collect information through the use of cookies on our website.

Why do we collect this information

Data Protection law says that TFP is allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:

• When it is in our legitimate interest
• When you consent to it
• When it is necessary to fulfil contractual obligations
• When it is necessary to comply with the law
• When it is necessary to protect someone’s life
• When it is necessary to perform a public task in the public interest or for our official functions and the function has a clear basis in law

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

Where we rely on our legitimate interest, we have detailed what it is below. For clarity, we have also detailed where consent is required.

1.  If you are a business or an individual acting in a business capacity, we rely on our legitimate interest to process your information in the following way:

2. If you are a consumer/member of the general public, we rely on legitimate interest and consent to process your information in the following way:

How will we use the information?

We collect information about you to provide membership services through The Fitzrovia Partnership and requested services through Enjoy Fitzrovia, and if you agree or we are otherwise permitted to do so by law, to email you about other products and services we may think of interest to you.

TFP will not share your information for marketing purposes with third party companies other than for transactional processing.

Using your information – your name and contact details

Your industry, sector, occupation and job information

Your membership activity information

Your loyalty activity information (if appropriate)

Your contact history with us

What you’ve said to us — for example, on phone calls, during meetings and briefings, at events

Attendance history

Marketing

Users of Enjoy Fitzrovia Consumer

We would like to send you information about our services, which include offers and rewards of third-party entities within our community, by email that may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please select the ‘Unsubscribe’ link on any enewsletter or email marketing@fitzroviapartnership.com.

Users of The Fitzrovia Partnership

We may send you information about our services, which include offers and rewards of third-party entities within our community, by email. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please select the ‘Unsubscribe’ link on any enewsletter or email marketing@fitzroviapartnership.com.

How long do we keep hold of your information  

We hold on to your information for as long as is needed to be able to provide the services to you, or for as long as is necessary to provide trend analysis or business continuity only.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or left your company or it is no longer needed to provide the services to you. In any event we will delete your personal data on the date within one month after the date on which you end your relationship with us.

Your rights

You have many rights concerning your personal information. Please quote your name and organisation (where applicable) together with your telephone number and/or email address on any requests. We would be grateful if could clearly indicate what you would like to know or what information you want a copy of (this helps us to more readily locate your data.) Your rights include:

• The right to be informed about whether, where and how your personal information is being used (like this notice)
• The right to access the personal information we hold about you
• The right to access with whom the data may be shared
• The right to request the period for which the data will be stored (or the criteria to determine that period)
• The right to request the correction of inaccurate personal information we hold about you
• The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
• The right to stop direct marketing messages, which you can also do through ‘unsubscribe’options, and to withdraw consent for other consent-based processing at any time
• The right to request that we transfer or port elements of your data either to you or another service provider
• The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office (ico.org.uk) – the Commission.

If you would like a copy of some or all of your personal information, please email lee.lyons@fitzroviapartnership.com or write to us at the following address:

Fitzrovia Partnership Business Improvement District Limited

1-13 Bayley Street

London

WC1B 3HD

As part of this request, we will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.

We will respond to all enquiries/subject access requests within 30 days. This may be extended to 90 days in exceptional circumstances for highly complex requests. You have the right to make as many access requests as you would like, however frequent and repeated requests may incur reasonable charges to cover the administrative time required. Should this arise, it will be discussed with you. You have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioners Office (ICO) and you can find out how to do this online here: https://ico.org.uk/concerns/

Information Security

TFP recognises that its customers are increasingly concerned about how companies protect personal information from misuse and abuse and about privacy in general. We are constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.

We use industry standard TLS certificates to provide encryption of data in transit, for example, all access to our website, internal systems and management portals is covered by HTTPS.

Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Third party service providers working on your behalf

We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. When we use third party service providers, we only disclose the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep the information secure and not for use it for their own direct marketing purposes.

Should we need to pass your information on to a third party, we will ensure that the information is transferred securely and that the third party is aware of their obligations under our privacy policy.

Third parties will be required to remove your information from their systems as soon as it is no longer needed for the purposes it was shared for (for example providing services for an event).

Data Storage and Security Systems

TFP stores all personal data securely on either CRM cloud storage systems or its own internal storage systems. All our cloud storage is kept in EU based or EU GDPR compliant data centres which are managed with sophisticated high-level security systems. These storage services have their own data protection policies which we can provide you with on request. We choose storage providers with excellent security policies and systems to ensure minimal risk of data breaches and unauthorised access.

Our internal storage and communications systems are protected by high level, managed security systems, which are updated regularly.

Our IT infrastructure is managed by experts and is regularly reviewed to ensure security is constantly up to date.

Other websites

Should our website contain links to other websites, this privacy policy only applies to our website so when you link to other websites you should read their own privacy policies.

How to contact us

You can contact us using the details below if you wish to exercise any of your rights listed above or if you have any questions about our privacy policy or information we hold about you generally:

Email: lee.lyons@fitzroviapartnership.com

Address:

Fitzrovia Partnership Business Improvement District Limited

11-13 Bayley Street

London

WC1B 3HD