PRIVACY POLICY

This privacy policy sets out how Parabola collects and processes personal information about you, how we use and protect this information, and your rights in relation to this information when you use or interact with us via our websites (www.Parabola.com, www.myedinburghpark.com together being (the “Websites”)) or otherwise, including when you use our mobile application, when you apply to work for us or when you visit our properties or attend our events.

1. Who are we?

Parabola comprises Parabola Management Limited (Company Number 14601706), NW1A Limited (Company Number 11587074), Parabola Edinburgh Limited (Company Number 10638794), Parabola Arts Limited (Company Number 05272724) and related companies in the Parabola group (together “Parabola Entities”, “Parabola”, “we” or “us”).

This policy applies to any and all of these organisations. Any of the Parabola Entities may from time to time publish additional dedicated privacy policies to cover particular activities.

2. How we collect your information

We may collect personal data about you in a number of ways, including when you:

• Interact with Parabola via the Websites or our mobile application (the MyEdinburghPark App or the desktop version found at https://myedinburghpark.app/);
• Visit our properties or attend any events hosted or run by Parabola;
• Sign up to receive marketing communications, online magazines or newsletters;
• Enter any prize draw or competition;
• Provide feedback to us or make a complaint or otherwise make contact with us; and
• Apply to work for Parabola.

We also collect certain non-personal data when you visit and use our Websites, mobile application or access wi-fi at our properties. For example, we may collect information including but not limited to traffic data, location data and usage data while you are on any of our Websites or when you are using our applications or wi-fi. We will only collect such information in aggregate form (so no individual user is identified).

3. Legal basis for processing your personal data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for collecting and using your personal data. In almost every case the legal basis will be one of the following:

• Legitimate Interests: this is where the processing is necessary for our legitimate interests. Our legitimate interests for processing your data are for (i) maintaining and developing our business and the products and services we provide; (ii) marketing, promoting and advertising our products and services; and (iii) providing a better experience for you and others who interact with us and improving our customer service and business operations. Where we use a legitimate interests basis to process personal data, we have assessed that this is reasonable and that your interests, rights and freedoms do not outweigh our legitimate interests.
• Consent: you have given us your consent to process your personal data for a specific purpose. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link included in any marketing communications we send you or otherwise by contacting us to withdraw your consent.
• ‍Contractual: the processing is necessary for the performance of a contract or transaction with you or to enter into a contract or transaction with you, so that we can provide you with information you have requested or carry out the obligations contained in a contract between you and us.
• Legal Obligation: the processing is necessary to comply with our legal obligations, for example to keep financial records (this does not include contractual obligations).

4. What personal data we collect and how do we use it?

This sections sets out:

• the types of personal data which we collect;
• how we use this information;
• the legal basis on which we process the information; and
• how long we retain the information.

a. If you sign up to receive marketing communications

If you sign up or register via the Websites, through our mobile application or otherwise to receive magazines, newsletters or other marketing communications we collect personal information which may include your name, address, email address and phone number. We send such marketing communications with your consent, which we obtain at the point which you sign up or subscribe for the communication. The use of this information is necessary for our legitimate interests of: (i) maintaining and developing our business and the products and services we provide; and (ii) marketing, promoting and advertising our products and services.

We make use of this information:

• To provide you with the information, products and services that you request from us;
• To provide you with marketing relating to our properties and services; and
• To notify you about changes to our properties or services.

We will keep your information until you tell us that you wish to unsubscribe or otherwise contact us to withdraw your consent to our processing of your data for the purpose of providing such communications. Where you unsubscribe or withdraw your consent, we will retain your details on a suppression list to ensure that we do not send further marketing communications to you.

b. If you contact us with enquiries, feedback or complaints

If you contact us with enquiries, complaints, feedback or otherwise through our Websites, mobile application or by any other means of communication we collect personal information which may include your name, address, email address and phone number. The use of this information is necessary for our legitimate interests in providing a better experience for you and others interacting with Parabola.

We will use your information to process your enquiry, follow up on your feedback or resolve your complaint.

We will keep your information for a period of twelve months after the date of our last correspondence with you on the matter in question. This is to allow us to be able to respond to any follow up queries or any subsequent correspondence from you on your enquiry, feedback or complaint.

c. Tenants, occupiers or suppliers

If you are a tenant, occupier or supplier at one of our properties, or a potential tenant, occupier or supplier, we collect personal information which may include your financial and business information, name, address, email address, phone number and bank account details. The use of this information is necessary for our legitimate interests, for the performance of a contract or transaction and to enable us to comply with our legal obligations.

We make use of this information:

• To provide services to you or with a view to providing services to you, such as in connection with contracts or lease agreements;
• To notify you about changes to our properties or services;
• To be able to advise you of future vacancies and opportunities at our properties; and
• To comply with any relevant legislation or regulatory requirements which may include validating your identity to enable us to contract with or provide services to you.

If we do not enter into a contract or lease with you, we will keep your information for one year after our negotiations have concluded. If we do enter into a contract or lease with you, we will keep your information for seven years after the end of the financial year in which the contract or lease ends.

d. Photography

We may take promotional photos and videos (including live video streaming) of members of the public at our properties and events: if so, we will display appropriate signage advising members of the public that this is happening. The use of such imagery is necessary for our legitimate interests of maintaining and developing our business and the products and services we provide by marketing, promoting and advertising our business.

We make use of this information:

• on our Websites, social media channels or mobile application; and
• In our brochure publications, newsletters, magazines or other marketing communications.

We will keep this information until it is replaced with new content.

e. Your interactions with Parabola

When you visit our Websites or mobile application we may automatically collect non-personal information including the following:

• technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; your interactions (e.g. comments, RSVPs or bookings), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We will only collect such information in aggregate form such that no individual user is identified. The use of this information is necessary for our legitimate interests of: (i) maintaining and developing our business and the products and services we provide; and (ii) understanding our clients and users of our services, Websites or mobile application to improve our services and performance including the functionality of our Websites and user experience.

How we make use of this information:

• To maintain our Websites and mobile application and analyse its use;
• To ensure that content on our Websites, mobile application and social media channels is presented in the most effective manner for you and for your device;
• To administer and improve our Websites, mobile application and social media channels and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• As part of our efforts to keep our website safe and secure; and
• To measure or analyse the effectiveness of advertising.

We will keep this information for as long as reasonably required for the purposes for which we collected it, including for our business analysis purposes.

f. If you apply to work for us

We collect personal information from you if you apply to work with us, this information may include:

• your contact details;
• copies of right to work documentation;
• any information included in a CV or cover letter or as part of an application process;
• any information you have included as part of a speculative application to work with us;
• information from references that you have provided;
• information about criminal convictions (but only if this is appropriate given the nature of the role and where we are legally able to do so).

We use your personal information collected during the application process on the following legal bases: (i) where it is necessary to process your application or to comply with a legal or regulatory obligation; or (ii) where it is necessary for our legitimate interests including demonstrating compliance with legal, regulatory and corporate governance obligations or use as part of investigations by regulatory bodies, or in connection with legal proceedings and requests; (iii) where it is necessary for the establishment, exercise or defence of legal claims.

We use your personal information collected as part of a speculative application to work with us on the basis of your consent. You can withdraw your consent at any time by contacting us. We will not be able to consider you for any vacancies or positions if you withdraw your consent.

How we make use of this information:

• We will only use the personal information you supply to us, or that we collect as part of the recruitment process to: (i) process your application; (ii) to make a decision about your recruitment or appointment; and (iii) to monitor recruitment statistics. This may include checking you are legally entitled to work in the UK.
• Where we want to disclose information to other third parties, for example where we want to take up a reference or undertake criminal records checks (where appropriate), we will not do so without informing you beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for one year from the decision not to progress the application, following which we will delete it. The information will be retained to allow us to advise unsuccessful candidates of future vacancies which we may invite them to apply for.

Where we carry out criminal records checks as part of the application process, we delete the information obtained from these disclosures and checks within one month of an appointment being made (in the case of unsuccessful candidates).

We will retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that information.

Once a person has taken up employment with us, we will record, process, keep, and securely hold personal information in accordance with our Employee Privacy Notice (a copy of which will be provided to you when you start with us).

Parabola Management Limited is the data controller in respect of any data collected in terms of this paragraph (f).

g. If you visit our properties

We collect personal information from you if you visit our properties or sites, including your name, contact details and car registration number. We use this information where necessary to: (i) comply with our legal obligations; (ii) establish, bring or defend legal claims; and (iii) for our legitimate interests including preventing crime at our properties; ensuring your health and safety whilst in our properties, ensuring a safe working environment for our employees and to manage complaints or legal claims.

How we make use of this information:

• to register you as a visitor to our properties or sites;
• to enable you to use our car parking facilities;
• to ensure your health and safety when you are in one of our properties or on one of our sites;
• to prevent crime and to ensure the safety of our employees;
• to ensure a safe working environment for our employees; and
• to establish bring or defend legal claims.

We will keep this information for as long as it is reasonably required for the purposes for we collected it, after which it will be deleted. In particular, we ordinarily retain visitor records for a period of three months, after which they are deleted.

h. Our mobile application

We collect personal information from you when you register or use our mobile application which may include your full name, name of the company you work for, email address, your image and any associated metadata uploaded with that image (if you choose to upload a profile picture) and mobile telephone number. We may also collect your payment details if you make purchases via the mobile application. The use of such information is necessary for our legitimate interests including for maintaining and developing our business and the products and services we provide and for processing any transactions via the mobile application.

How we may make use of this information:

• To allow you to register and use the mobile application;
• To provide you with the appropriate level of access to the mobile application (depending on whether you work at our properties or are just visiting our properties);
• If you work at one of our properties, to provide you with an access pass;
• If you make a purchase, to process your purchase.

We will keep this information for as long as it is reasonably required for the purposes for we collected it, after which it will be deleted.

i. Prize draws, competitions or awards

We may from time to time advertise for prize draws, competitions or competitive awards (a “Competition”). We will collect personal information from you when you enter a Competition which may include your full name, location, email address, address, education information and telephone number. We use this information with your consent which you have given us when you enter the Competition.

How we make use of this information:

• To administer the Competition;
• To communicate with you regarding your entry;
• To fulfil prizes.

You may withdraw your consent at any time by contacting us. If you withdraw your consent we will not be able to process your entry to the Competition.

We will retain your information for as long as required for the purposes of administering the Competition.

j. Personal data obtained from third parties

We work with third parties (including, for example, business partners, contractors in technical services, advertising networks, analytics providers and search information providers) and may receive information about you from them. We may also receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.

k. Other

We may in other circumstances ask for your consent to collect and use other personal information. If we do so, you may withdraw your consent at any time by contacting us.

In accordance with good risk management practice, our IT systems are backed up on a daily basis. Because of the technical nature of how these back-ups are made and stored, it is not feasible for individual pieces of personal information to be deleted from them. Back-up data cannot be searched, it is stored securely and access is limited to IT administrators who would only access it in the event of the back-up being required to restore our systems. At this point, personal information which had already been deleted from the live system would remain deleted. Back-ups are permanently deleted after seven years.

5. How long we keep your personal information for

Section 4 above contains details of how long we retain your personal data in each case it is collected. To determine the appropriate retention periods for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6. Who controls your information?

Unless specifically noted elsewhere in this Policy, Parabola Management Limited (Company Number 14601706), NW1A Limited (Company Number 11587074), Parabola Edinburgh Limited (Company Number 10638794) and Parabola Arts Limited (Company Number 05272724) are joint data controllers in relation to the personal information we collect or process about you.

7. Who we share your information with

We may share your personal information with third parties as follows:

• other Parabola group companies and corporate entities related to the Parabola group;
• with our suppliers and service providers (for example website or database hosting companies or companies sending out our newsletters);
• with companies providing professional services to us, for example property management agents or accountants;
• with law enforcement agencies, courts, regulators, government authorities or similar bodies where required to comply with our legal and regulatory obligations;
• with our insurers or prospective insurers where required to obtain insurance for our properties.

We will share your personal information with third parties above for the purposes set out in this privacy policy only. We require those third parties to respect the security of your information and to process it in accordance with all applicable data protection legislation.

8. Overseas transfers

Your personal information may be transferred to, and stored in, countries outside of the UK and the European Economic Area for the above purposes. Where your personal information is transferred to countries outside of the UK and the European Economic Area, we will take appropriate steps to ensure that your personal information is adequately protected. Please contact us if you would like more details on the safeguards used by us to protect personal information for these transfers.

9. Your rights

You have the following rights over your personal information:

• The right to access the information in certain circumstances;
• The right to request for the information to be rectified or erased in certain circumstances;
• The right to restrict the ways in which we can use the information;
• The right to request that we port or transfer the information to you or a third party;
• The right to object to the processing of the information in certain circumstances; and
• The right to lodge a complaint with your data protection regulator, the Information Commissioner's Office.

10. Contact us

If you wish to contact us about this Privacy Policy or to exercise any of your rights, you can contact us by:

• emailing us at info@parabola.com; or
• or in writing to us at Parabola Management Limited, Pure Offices, 4  5 Lochside Way, Edinburgh Park, EH12 9DT.

This privacy policy was last updated in April 2024. This privacy policy may vary from time to time so please check it regularly.