Privacy Policy
We understand that your privacy and the security of your personal information is extremely important. This privacy policy explains what personal information Darwin Alternatives collects about you, and how and why we use that information.
Across the Darwin Alternatives websites, we also collect a number of cookies. Cookies are small unique text files that are collected by your browser from websites you visit which can be stored on your device. The cookies we use on the Darwin Alternatives website don’t collect or store your personal data (such as your name or address) so this information can’t be used to identify who you are.
About Us
We are the Darwin Alternative Investment Management Limited, a company registered in England and Wales (Reg. No. 08100415). Darwin Alternative Investment Management Limited is authorised and regulated in the UK by the Financial Conduct Authority (Ref. No. 745129)
Contact Us
If you have any questions about this privacy policy or to exercise your rights in relation to your personal data, please contact our Data Protection Officer:
The Data Protection Officer
Darwin Alternative Investment Management Limited
email@darwinalternatives.comUsing personal data allows us to develop a better understanding of, and engage with, our stakeholders and in turn provide you with relevant and timely information about the work that we do.
The purpose of this policy is to explain why we process your personal data and your rights in relation to your data. We are committed to respecting and protecting your personal data and being transparent about what we do with it, in accordance with your reasonable expectations and applicable laws and regulations.
This privacy policy was updated on 6 February 2023. We will update this privacy policy from time to time with regard to our activities and in accordance with applicable laws and regulations and will post any changes on our website. When you use our services, the latest privacy policy posted will apply so please check back regularly to ensure that you have seen our most up to date notice.We appreciate your support and the trust you give us when you provide us with your personal data.
We will only use your personal data if we have a legal basis to do so. This means that we will only use personal data where we have your explicit consent, where it is necessary in order to perform a contract with you, to comply with a legal duty or right, to protect your vital interests, or where the processing of your personal information is in our legitimate interest and not overridden by your legal rights.There are generally three legal bases under which we may process your data:
Consent: When consent is required we will always ask for your explicit consent to processing your personal data.
.Legitimate interests: In some situations we collect and process your personal data for purposes that are in our legitimate organisational interests. In doing so we consider that there is no overriding prejudice to you and that you would reasonably expect us to use your data in this way.
Key Terms
Cookies: means small text files which our website places on your computer's hard drive to store information such as activity on our website. When you visit the website again, the cookie allows that site to recognise your browser. Cookies may store your preferences and other information.
Malware and viruses: means malicious software (such as viruses) which can gain access to your computer or device and be used for criminal activity.
Personal data: means any information that identifies you or that could identify you either alone or when combined with other information.
Processing: means anything that is done to, or with, personal data (including simply collecting, storing or deleting those data).
Third Party Marketing: means marketing or other communications about products and services that are sent by or on behalf of a third party (and not the Darwin Alternatives. This will always be an affiliate company - we would never sell or pass on your data to a third party).
We/us: means Darwin Alternative Investment Management Limited, a company registered in England and Wales (Reg. No. 08100415). Darwin Alternative Investment Management Limited is authorised and regulated in the UK by the Financial Conduct Authority (Ref. No. 745129)
Website: means the website located at: www.darwinalternatives.com and any other websites operated Darwin Alternatives including www.transcendencegarden.com .
We use your personal data to contact you and provide information about our products and services and those of our affiliate businesses if you have requested this. We may also rely on our legitimate interest to communicate our work with you. We aim to send communications that you would reasonably expect to receive as someone who has requested information from us with minimal impact on your privacy. By clicking on links within our website and submitting your contact information to us, you have given us your explicit consent to receive them. As a visitor to our website we may collect the following information about you: Name, Address and postcode, Email address, Telephone numbers. We may also create information about you that becomes your personal data such as products you have expressed an interest in.
Photos, videos, audio from which persons are identifiable
We protect these as personal data. We collect these, and also permit some of our service providers to do so, in the following circumstances:
At properties owned by our affiliate companies, and at exhibit spaces
Filming and photography by or on behalf of Darwin Alternatives may take place at properties owned by our affiliate companies and at exhibition or event spaces. Your actual or simulated likeness may be captured and recorded if you attend one of our events. or visit one of our properties. The photos and videos are used for promotional purposes, including publication on our website, social media, printed media and may be shared with the press and trusted third parties for this purpose. Darwin Alternatives rely on our legitimate interest where we are photographing or filming at our properties and and events. This is because the large number of visitors makes it impractical and disproportionate to obtain signed consent from each individual person attending. By entering our exhibit or event spaces or properties you acknowledge that you have been informed about the photography and filming and to the use of your actual or simulated likeness for Darwin Alternatives promotional purposes as stated above without compensation. When we are filming we will let those in the vicinity know so that the area can be avoided if you do not want your likeness to be captured or recorded. When we take video recordings or photos of you for commercial advertising such as for TV or billboard advertising, we will ask for your signed consent. Drone use Occasionally we use remote controlled drones with cameras. When drones are in use, we will let those in the vicinity know with signs and you will be able to see the marked drone operator to allow you to avoid the area if you do not want to be inadvertently filmed. Time Lapse filming and images We are making lots of improvements at our development sites and when creating event spaces and are filming in and around these sites to capture the developments through time lapse photography and video. While it will likely not be possible to identify individuals in the finished time-lapse clips, individuals may be identifiable in the original footage and images. We will keep the original footage secure. We use CCTV at some of our properties and event sites to prevent and detect crime and for health and safety reasons. CCTV relies on strategic placement of cameras. We periodically monitor the camera's footage and recorded footage for specific purposes and limited period. You will be able to see our cameras and we have CCTV signs displayed in the areas in which we use them.
Social media
We collect information from social media sites if you have given us permission to do so or if you interact with us on one of our social media pages (for example, by liking or sharing Our Facebook page or posting a comment).
Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health). However, there are some situations where we will need to do so (e.g. if you have an accident at one of our properties or events or if you tell us about a disability). If we record your sensitive personal data we will take extra care and follow additional procedures to ensure your privacy rights are protected.
Our legal basis for collecting sensitive personal data will usually be so that we can fulfil legal or regulatory requirements and in other cases it will be your explicit consent.
Job applicants, Employees and Interns
If you are applying for a role at Darwin Alternatives , then we collect and use this personal information primarily for recruitment purposes – in particular, we may process your name, address, email, phone number, gender, date of birth, immigration/visa status, previous employment history and job title/position, academic/professional qualifications, education, CV, criminal records data (only ‘unspent’ current convictions for vetting purposes, where permissible and in accordance with applicable law). If you are not successful, we may still keep your application for a period of six months after interview to allow us to consider you for other suitable openings within Darwin Alternatives. We rely on our legal obligation under the various legislation governing the recruitment and selection process including anti-discrimination and equality legislation for collecting and processing your personal data.
Once you become Darwin Alternatives employee, we collect and use this personal information for the purpose of managing our employment or working relationship with you. Our lawful basis for processing your personal data is a ‘contract’ and legal obligation under various employment related legislation and the Equality Act 2010 – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary/pension details (so we can pay you).
We also collect and process equality and diversity information such as: ethnicity, gender, religious belief, sexuality, disability, physical or mental health etc. in order to meet our legal obligations as an employer under the relevant employment legislation, anti-discrimination legislation and the Equality Act 2010 that requires us to process this type of data. However, we will always seek your explicit consent where we need to collect equality and diversity information that fall outside of our legal obligation. Where we collect or process equality and diversity information for monitoring and statistical purposes, it will only be collected and processed anonymously and in an aggregated manner, so that individuals are not identifiable. It will never be used to identify individuals or to make decisions about any individual.
How We Use Your Information
We will only ever use your details to help you make the most of what we have to offer. We use contact frequency rules to ensure we do not send you too many communications. Your details are only used by us, or those who work with us (such as our suppliers and contractors), and will not be sold to anyone else. Where suppliers and contractors process personal data on our behalf, we control this in order to safeguard your personal data rights, through reviewing their data security arrangements and enforcement of specific personal data obligations in our contracts with themWe do not make personal data available to third parties to use for their own marketing purposes
Other ways we may use personal data
Analysis and grouping
We analyse data about our contacts to understand common characteristics and preferences. We may analyse various types of information including activity and demographic information (e.g. age or location). By analysing data and grouping people together by common characteristics, we can provide more relevant communications, offers, and information, improve our activities and services, and operate more efficiently.
Research and profiling
We also use personal data to build profiles of categories of contacts. This enables us to understand our stakeholders, improve our relationships, and provide a better customer experience. Darwin Alternatives does not carry out profiling that has any significant legal effect on you. If we think that any profiling activities that we carry out may have a significant legal effect, then we will ask for your consent to ensure you are informed and have control. We will not use profiling on children or special categories of data like genetic or biometric information. You have the right to object to this profiling. If you would like to do so, please let us know by contacting us using the details at the bottom of this policy.
Anonymised data
We may aggregate and anonymise personal data. We use anonymised or de-identified information for a variety of purposes, such as identifying trends or patterns within our contact base, to improve our activities and services.
Where and how we store your personal data
We maintain and apply appropriate safeguards, organisational and technological security measures in order to keep your personal data secure and also require that third parties we choose to process your personal data do the same. We have up-to-date security measures, a comprehensive privacy programme and carry out security audits. We actively manage our use of your personal data and store it securely in the UK.
How long we keep your information
We keep your personal data safely for as short a time as we need it or legally have to keep it. In doing so, we:review the length of time we keep your personal data; consider the purposes for which we holds the personal data in deciding whether (and for how long) to retain it; securely delete personal data that is no longer needed for those purposes; and update, archive or securely delete personal data if it goes out of date. The time periods for which we retain your personal data depend on the purposes for which we use it.We have set destruction limits taking into account legal rules, your rights and our needs and have a continuous programme that securely destroys your personal data when we have reached the relevant time limit.
Sharing your personal dataWe will never sell your personal data. We may share data, including personal data, with affiliates and subsidiaries, who may need to have access to your personal data for the purpose of providing services to us.
We may also share your personal data with third parties if we are required to do so by law or contract, to respond to legal process, to protect our customers or staff, to protect lives, with your consent, to complete a transaction, or to protect the rights or property of Darwin Alternatives.
We may also share your personal data if it is necessary to comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies. For example, on occasion we may disclose CCTV footage to the police.
Change your preferences and opt in
You are in control of what we do with your personal data. If you would like to change your choices, or how we communicate with, just let us know by emailing
email@darwinalternatives.com or call us on 020 7680 10540 and speak with our Marketing Team.
Your rightsYou have several legal rights in relation to your personal data. These data subject rights are the right to request: Right to be informed about the collection and use of your personal data; Access to your personal data (see below); Rectification of your personal data; Erasure of your personal data (this right is also referred to as the
'right to be forgotten'); Restriction of our processing of your personal data; Portability of your personal data (where we process your data by automated means and under the legal basis of consent you have the right to receive this data in a structured, commonly used and machine readable way and to transmit this to another controller); Processing of your personal data ceases (the right to object); and Not to be subject to automated decision making
To exercise your rights or ask any questions please contact the Data Protection Officer.
The Data Protection Officer
Darwin Alternative Investment Management Limited
Empire House
175 Piccadilly
London
W1J 9EN
email@darwinalternatives.comWe will always try to respond to your satisfaction, but there may be situations where we are unable to do so.More information can be found at the website of the
Information Commissioner's Office You can find out if we hold your personal data and ask for a copy of it by making a ‘subject access request’.If we do hold personal data about you, we will:let you know what personal data is being held or used and why let you know who can see your personal data give you a copy of the personal data you request in electronic form provide any other relevant information including how long we will hold your personal data for and how to correct inaccurate information that is held by us. Please get in touch with us if you have any questions about any aspect of this privacy policy, or wish to exercise your legal rights. To make a request or to exercise your legal rights, please email or send a letter (headed ‘Subject Access Request’) to:
The Data Protection Officer
Darwin Alternative Investment Management Limited
Empire House
175 Piccadilly
London
W1J 9EN
email@darwinalternatives.comWe will respond as soon as possible (and within one month of the date of receipt of your request and the information we need to respond).Access to information.
Security and privacyWe use up to date physical and technical measures to keep your information safe, prevent unauthorised access to it and to prevent misuse or unauthorised disclosure of it.We control who has access to our secure electronic databases and provide staff and volunteers training on our data protection policies and procedures. We also check these are being followed.