Privacy Policy

When you interact with any websites owned and maintained by Poune Asset Management we process your personal data. The below table sets out the purposes for processing, the personal data used and the lawful basis.

a) What are Cookies

Cookies are small text files that are stored on your device when you visit our website. They allow the website to function properly, personalise some functions and analyse how people use our website.

b) Necessary cookies

These cookies are crucial to the functioning of our website and cannot be turned off in our cookie settings. We do not ask for consent for these cookies and rely on the legitimate interest lawful basis to install them. You can block these cookies using your browser settings but the website may not function as intended and some parts of the website may not work.

c) Analytic and Advertisement cookies

These cookies allow us to track the behaviour of users when using the website and optimise the performance of the website. We rely on the lawful basis of consent to install these cookies. Consent is switched off by default, and you have the opportunity to opt-in to these cookies by using the banner at the bottom of the page.

We process personal data in order to fulfil our contractual obligations with our clients. We may carry out various services to our clients which involve processing the personal data of leaseholders and residents depending on the service being provided. This may include any of the purposes set out below.

We may process the personal data of individuals of the general public while carrying out our business functions. This may include any of the purposes set out below.

We may process the personal data of individuals who are our clients while carrying out our business functions or to uphold our contract with you. This may include any of the purposes set out below.

We may process the personal data of individuals who are our suppliers while carrying out our business functions or to uphold our contract with you. This may include any of the purposes set out below.

We may obtain information from you in order to undertake Anti-Money Laundering (AML) and sanctions screening checks against sanctions lists and Politically Exposed Persons (PEP) lists.

We undertake such checks to verify your identity, meet the requirements of our banking partners to help prevent fraud, money laundering and other financial crime. We may use a third-party provider to carry out sanctions, fraud, and other compliance screening checks.

As part of this process, the provider may share your personal data with Credit Reference Agencies (CRAs). These agencies may retain a record of the search and may share that information with other organisations for purposes such as credit risk assessment, fraud prevention, anti-money laundering, and tracing individuals with outstanding debts. These searches may leave a footprint on your credit file; however, they are not credit checks and do not affect your credit score.

You can learn more about how CRAs use personal data by reading the Credit Reference Agency Information Notice (CRAIN), which is available at CRAIN v1.2.

Only in relation to Anti-Money Laundering (AML) and Sanctions Screening we may share your data with the following:

• Specialist third-party AML screening providers.
• Our banking partners.
• Group companies within our corporate structure, where such sharing supports our services or legal obligations.
• Regulatory authorities or law enforcement agencies if required by law.

We process personal data for the following legitimate interests:

• Satisfying contractual obligations with our clients.
• Satisfying our legal obligations as defined by statute.
• Sharing specific information of communal interest and/or statutory requirement.
• Recovering Service Charges or money owed to us.
• Ensuring the safety and security of individuals such as residents and staff members.
• Ensuring the safety and security of property owned or managed by Poune Asset Management or our clients.
• Effective internal administration.
• Improving our business by asking for opinions and feedback.
• Establishing, exercising or defending legal claims.
• Enforcing the terms of the lease on behalf of our clients.
• Communications with clients including the provision of industry and company information that may be of interest.
• For marketing purposes, where we believe that you may be interested in similar services to those you already receive.

Your personal data is accessed internally by the individuals and teams that need it to carry out the purposes set out above.

We use systems and products provided by third party companies to assist us in conducting our business. This includes using data processors such as Microsoft and Blocks Online to store and organise the personal data we collect.

We may share your data with the following categories of recipients:

• Freeholders of the building where you live or are a leaseholder.
• Landlords who have a contract with you.
• Public service providers such as the police or social services.
• Local authorities.
• Utility companies.
• IT service providers.
• Professional advisers, such as solicitors.
• Other leaseholders in specific circumstances.

We will only share your personal data when we are allowed to do so under data protection law.

If any personal data is transferred outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The country has been deemed to provide an adequate level of protection for personal data.
• We use specific approved contracts approved for use in the UK which give personal data the same protection as it has in the UK.

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for. Most of the personal data relating to leaseholders and residents will be retained for 2 years after the last contact with you. We may retain personal data for a longer period where we have a lawful basis or exemption, for example if there are arrears on the account or ongoing legal proceedings.

Specifically in relation to Anti-Money Laundering (AML) and Sanctions Screening we will retain personal data for as long as required under applicable anti-money laundering and financial crime prevention laws (typically 5 years from the end of the business relationship or transaction for AML purposes), or for as long as necessary for our or our banking partners’ legitimate interests in preventing fraud, money laundering, and other financial crimes, provided such interests are not overridden by your data protection rights.

You have the following rights under data protection law in relation to your personal data:

• The right to be informed — this privacy notice is our way of informing you how your data is used.
• The right of access — you can request a copy of all the information we hold about you to check that we are lawfully processing it.
• The right to rectification — you can request that we rectify information about you that is incorrect.
• The right to erasure — also known as the right to be forgotten. You can request that information about you is deleted.
• The right to restrict processing — you can request that we pause processing your data so we can verify the lawfulness of processing.
• The right to object — you can request that we stop processing your information if you feel that the processing is not lawful.
• The right to data portability — you can request that data is transferred to another party so it can be reused across services.

Where you have given consent for us to use your personal data for specific purposes, you have the right to withdraw this consent at any time.

If you would like to exercise any of those rights, please contact our Data Protection Officer by:

• Emailing us at contact@poune-am.com
• Writing to us at Poune AM Limited, 71-75 Shelton Street, London WC2H 9JQ
• Calling us on +44 (0)20 3984 5368

We will respond to any request within the statutory deadline of one calendar month. This deadline may be extended where applicable under data protection law. We will inform you if your request meets the extension criteria.

If you have any concerns about how we use your personal data, you have the right to make a data protection complaint to us. You can contact us using the details set out above.

We will:

• Acknowledge your complaint within 30 days;
• Investigate the matter;
• Keep you informed where appropriate; and
• Provide you with a response, including the outcome of our investigation, without undue delay.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can contact the ICO by:

• Visiting the ICO’s website
• Calling them on 0303 123 1113.