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Care REIT plc – Privacy & Cookies Policy

Care REIT plc (“we”, “us“, “our” or “Care REIT”), a public limited company incorporated in England and Wales with registered number 10464966 and whose registered office is located at the Scalpel, 18 Floor, 52 Lime Street, London EC3M 7AF, is committed to protecting the privacy of third parties (including its investors and all visitors to the website, www.carereit.co.uk (the “Website”)).

This Cookies and Privacy Policy (“Policy“) sets out how we will use and protect information from which you can be identified (“Personal Information”) that we collect about you when you visit our Website, together with other Personal Information that you provide to us or which we otherwise obtain in connection with our day-to-day business and which we hold in the capacity of a data controller.

We endeavour to ensure that your Personal Information is handled in accordance with “Data Protection Legislation”. References to “Data Protection Legislation” in this Policy mean any law applicable from time to time relating to the processing of personal data and/or privacy, as may be re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation the: (i) UK GDPR (being Regulation (EU) 2016/679 as incorporated into the law of the United Kingdom pursuant to the European Union (Withdrawal) Act 2018); (ii) Data Protection Act 2018; (iii) General Data Protection Regulation (EU) 2016/679 (as applicable); and (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, direction and orders issued from time to time under or in connection with any such law.

By visiting and/or contacting us through the Website (or otherwise engaging with us), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy.

For the purposes of Data Protection Legislation, Care REIT is the “data controller” in respect of any Personal Information that you provide to us or we otherwise obtain about you.

This Privacy and Cookie Policy covers:

1. Personal Information that we collect from you

  • When you engage with us (e.g. by visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number).
  • Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser).
  • When we acquire or invest in an asset (or are in a process of doing so) we may obtain some information about individuals who may be associated with a relevant asset.
  • If you (or an institutional investor or investment vehicle with which you are associated) consider investing with us, you may also provide us with your financial information and various other necessary Personal Information.
  • If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire your contact details and certain employment information.
  • We will only process your Personal Information where we have a legal basis for doing so. Our legal basis will be one of the following bases outlined below:
  • to fulfil a contract that we have in place with you;
  • to comply with our legal obligations;
  • to pursue our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests; or
  • where we have your express consent (in which case, you will be made aware and will be provided with the opportunity to withdraw your consent to the processing, should you wish to do so).

2. Personal information that we receive from other sources

We may receive information from third parties who collect Personal Information from you and pass it on to us. Where this is the case the third party is responsible for informing you that your Personal Information may be transferred to us.

3. What we do with your personal information

We will only use your Personal Information in order to:

  • supply the investment services or information you have requested and correspond with you;
  • provide support to you in respect of the services provided to you;
  • protect the security of our communications and other systems and to prevent and detect security threats, fraud or other criminal or malicious activities;
  • comply with our legal and regulatory obligations;
  • improve our Website and services; and
  • run our business affairs.

4. How we share your personal information

Where it is necessary to fulfil the purpose for which your Personal Information was collected, we may share your Personal Information with certain third parties such as our registrar, administrator, investment manager or investment adviser. By submitting your Personal Information to us, you acknowledge that to such third parties may receive and process your Personal Information. Care REIT asks all third parties to treat your data securely and in accordance with this Policy, and will take reasonable steps to enforce this.

In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal or regulatory obligation (such as AML obligations), enforce any agreement we have with you or protect the rights of Care REIT, Care REIT’s directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.

We may also process and transfer your Personal Information to auditors, advisers, law enforcement bodies or to other entities for the purpose of establishing or defending our legal rights, complying with the law or carrying out an internal investigation.

5. Our security and data retention measures, and any transfers we make outside of the EEA

We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.

We take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.

In processing your Personal Information, it may be necessary for us to transfer your Personal Information outside the United Kingdom (“UK“) and the European Economic Area (“EEA”). It may also be accessed by staff operating outside the UK and/or EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services to Care REIT or the Website. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the UK and/or EEA. This means that we will only transfer your Personal Information to third parties outside the UK and/or EEA if that third party: (a) is situated in a country that has been confirmed by the Information Commissioner’s Office and/or European Commission (as applicable) to provide adequate protection to Personal Information, or (b) has agreed (by way of written contract) to provide all protections to your Personal Information as required by Data Protection Legislation. Where any transfer takes place under a written contract, a copy of such contract will be available to you on written request (subject to certain redactions and/or an undertaking from you to respect the confidentiality of that contract).

6. Accessing and updating your personal information

You have certain rights in relation to your Personal Information, subject to certain exemptions, including to:

  • see the Personal Information that we hold about you (unless, for example, our duty of confidentiality to a third party takes precedence over this right), and withdraw any consent you may have given to us to hold and use that Personal Information;
  • make any changes to ensure that any Personal Information we hold about you is accurate and up to date;
  • erase or stop processing any Personal Information (or any part thereof) we hold about you, which we will comply with unless we have a lawful reason to retain your information (for example, to comply with our legal obligations); or
  • in some cases, ask us to transfer any information we hold about you to a specified third party.
    If you wish to exercise any of these rights, please contact us at on the details set out in section 10 of this Policy.

7. Complaints

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us using the details set out in section 10 of this Policy. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office or one of the competent European supervisory authorities regarding such issues.

Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, you will be leaving our Website and accessing that other website. As such, the operators of those websites are solely responsible for any Personal Information which they collect about you via their website, and such data will be collected in accordance with their own privacy policies. Please check these policies before you submit any Personal Information via these websites.

8. Our use of cookies

9. Changes to our Privacy and Cookies Policy

Care REIT may amend this Policy at any time without notice. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to this Policy will be posted on the Website. You should therefore check this page frequently to ensure that you are aware of any changes.

10. Our contact information

If you have any questions or concerns about the way in which we have handled your Personal Information, please feel free to contact us by email at: [email protected]

Alternatively, you may call our team on +44 (0) 203 146 7100, Monday to Friday: 9am to 5pm.