Privacy Policy

  1. Introduction
    • This website is owned and operated by Sand Aire Limited for itself and its affiliates and subsidiaries, including Lord North Street Limited and Sand Aire (Singapore) (Pte.) Ltd.
    • Sand Aire (Singapore) (Pte.) Limited is incorporated in Singapore (Company Registration No.201134113G), with its registered office at 80 Robinson Road, #02-00, Singapore 068898 and its place of business at 77A Amoy Street, #02-00, Singapore 069896.
    • Sand Aire Limited is registered in England and Wales and has its registered office and place of business at 105 Wigmore Street, London, W1U 1QY (Company Number 3066958). Lord North Street Limited is registered in England and Wales and has its registered office and place of business at 105 Wigmore Street, London, W1U 1QY (Company Number 3664551).  “Sandaire” or “we” or “our” refers to Sand Aire Limited and Lord North Street Limited.
    • Sand Aire Limited’s Information Commissioner’s Office (ICO) registration number is Z6882334 and Lord North Street Limited’s ICO registration number is Z9045254.
    • Sandaire respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
    • This Privacy Policy aims to give you information on how Sandaire collects and processes your personal data through your use of this website, including any data you may provide through this website.
    • It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing Policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
    • Our Cookie Policy is designed to help you understand the information collection practices on our website. Sandaire will ask you to consent to our use of cookies in accordance with the terms of this Policy when you first visit our website.
    • This Policy is dated 8 July 2019. We reserve the right to amend this Privacy Policy at any time without notice, by updating this posting, in which case the date of this Policy will be revised.  The current version of this Policy can be accessed from the link on the homepage or at the bottom of our website page.  By accessing our website following amendments, you are accepting the amended Policy.
    • We are registered as a data controller with the UK ICO and are responsible for your personal data.
    • We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager by emailing or by telephone on 020 7290 5200.
  2. Collecting personal information

2.1      We may collect, store and use the following kinds of personal information:

(a)      information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);

(b)      information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);

(c)      information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);

(d)      any other personal information that you choose to send to us.

2.2      We do not collect any Special Categories of Personal Data about you via our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

2.3      Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this Policy.

  1. Using personal information

3.1      Personal information submitted to us through our website will be used for the purposes specified in this Policy or on the relevant pages of the website.  The types of personal data that may be collected include your name, address, email address and telephone number.  In addition, if you are accessing parts of this website that are password protected, then once you submit your password and enter, this website will recognise who you are and collect all information that you submit, including all electronic information (including all transaction information).

3.2      We may use your personal information to:

(a)      administer our website and business;

(b)      personalise our website for you;

(c)      enable your use of the services available on our website;

(d)      send you non-marketing commercial communications;

(e)      send you email notifications that you have specifically requested;

(f)       send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);

(g)      send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);

(h)      provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);

(i)       deal with enquiries and complaints made by or about you relating to our website;

(j)       keep our website secure and prevent fraud;

(k)      verify compliance with the terms and conditions governing the use of our website.

3.3      If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

3.4      Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.

3.5      We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

  1. Disclosing personal information

4.1      We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.

4.2      We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this Policy.

4.3      We may disclose your personal information:

(a)      to the extent that we are required to do so by law;

(b)      in connection with any ongoing or prospective legal proceedings;

(c)      in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d)      to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

(e)      to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4.4      Except as provided in this Policy, we will not provide your personal information to third parties.

  1. International data transfers

5.1      Where relevant for your services, your personal data may be transferred to and processed outside of the European Economic Area (“EEA”) in countries or territories that do not provide the same level of protection for personal data as the EEA does.  Where this happens, we will put appropriate measures in place to ensure the adequate protection of your personal data when it is transferred outside of the EEA.

In these circumstances, your personal data will only be transferred on one of the following grounds:

  • the country or territory to which the transfer is made ensures an adequate level of protection for personal data;
  • Sandaire and the recipient of the personal data outside the EEA have signed a form of model data protection clauses (standard contractual clauses) approved by the European Commission; or
  • there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent to make the transfer).

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard contractual clauses which Sandaire has entered into with recipients of your personal data, including Sand Aire (Singapore) (PTE) Ltd) by contacting us using the details set out below.

5.3      Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world.  We cannot prevent the use or misuse of such information by others.

5.4      You expressly agree to the transfers of personal information described in this Section 5.

  1. Retaining personal information

6.1      This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

6.2      Personal information that we process for any purpose or purposes shall not be kept for longer than is reasonably necessary for that purpose or those purposes.

6.3      Without prejudice to Section 6.2, data will not be kept for longer than is necessary for the purposes for which it was collected or as required by law.

6.4      Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:

(a)      to the extent that we are required to do so by law;

(b)      if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c)      in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

  1. Security of personal information

7.1      We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

7.2      We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

7.3      All electronic financial transactions entered into through our website will be protected by encryption technology.

7.4      You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.5      You are responsible for keeping any password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

  1. Amendments

8.1      We may update this Policy from time to time by publishing a new version on our website.

8.2      You should check this page occasionally to ensure you are happy with any changes to this Policy.

8.3      We may notify you of changes to this Policy by email.

  1. Your rights

9.1      You may contact us to:-

(a)      request that we amend, rectify, delete or update the personal data we hold about you;

(b)      where possible (e.g. in relation to marketing) amend or update your choices around processing;

(c)      subject to the supply of appropriate evidence of your identity request a copy of your personal data held by us.

9.2      We may withhold personal information that you request to the extent permitted by law.

9.3      In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  1. Third party websites

10.1    Our website includes hyperlinks to, and details of, third party websites.

10.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Business Transfers

11.1    If the business of Sandaire or any part thereof is acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide our services to you.  You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.