Areli respects your privacy and is committed to protecting personal data. This privacy policy will
inform you as to how we look after your personal data when you visit our website www.areligroup.co.uk
(regardless of where you visit it from), when you become a client, purchase our services, when you
visit our premises or when you otherwise contact us. It will also tell you about your privacy rights
and how the law protects you.
References to “you” or “your” include to you as an individual using our services where you are an
employee, representative, agent or contractor representing a business or organisation that is our
client.
1 Important Information
It is important that this privacy policy is read together with any other privacy policy or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data, so
that you are fully aware of how and why we are using your data. This privacy policy supplements
other notices and is not intended to override them.
This version was last updated on 1 May 2023 and last reviewed on 1 May 2023.
It is important that the personal data we hold about you is accurate and current. You should keep us
informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When
leaving our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
2 Who We Are
We are Areli Developments Limited (ADL), with a company number of 13064630. Our registered
office is Winchester House, Deane Gate Avenue, Taunton, Somerset, England, TA1 2UH. ADL is the
controller and responsible for your personal data (referred to as “Areli”, “ADL”, “the firm”, “we”,
“us” or “our” in this privacy policy.)
ADL provides real estate consultancy and development and project management services to a wide
range of businesses, other organisations and individuals. We are bound by applicable data
protection laws in respect of the handling and collection of your personal data. ADL is registered as a
data controller in England and Wales, with the Information Commissioner’s Office (ICO) under the
ICO number ZB354890.
If you have any questions about this privacy policy, including any requests to exercise legal rights,
please contact us using the contact details in section 13.
3 Basis for Processing Personal Data
3.1 Paragraphs 3.2 – 3.10 below explain how and why we process your personal data, as well as the
legal basis on which we carry out this processing.
3.2 To enter into and perform contracts with you: Where you ask us to provide services, we will
process your personal data so that we can deliver these services to you. We may also use your
information to notify you about important changes or developments to our services and to contact
you for your views on our services. The legal basis on which we process your personal data in this
way is the necessity to be able to enter into and perform the contract for the supply of services you
have requested from us. If you do not wish to provide us with your personal data in this way, you
will be unable to use our services.
3.3 To check your identity: In accordance with money laundering regulations and in order to carry
out credit reference checks, we may be required to undertake checks on your identity. To do so, we
will process your personal data. The legal basis on which we process your personal data in this way is
the necessity for us to comply with legal obligations.
3.4 To provide services to others: Where you have provided personal data about another person (for
example, where you request services on behalf of someone else, we need to process such personal
data in order to provide these services to the other person or people. We need to process their
personal data in this way to be able to provide them with the services you have requested for them
from us. The legal basis on which we process their personal data in these circumstances is our
legitimate interest to provide the person you have identified with the services you have requested.
3.5 To make our website better: We also use various cookies to help us improve our website (more
details are set out in section 6), and may share aggregate data on the usage of our site with third
parties (including third party analytics and search engine providers that assist us in the improvement
and optimisation of our website), but this will not include data that can be used to identify you.
We will also process your personal data for the purposes of making our website more secure, and to
administer our website and for internal operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes.
The legal basis on which we process your personal data in these circumstances is our legitimate
interest to provide you with the best client experience we can, and to ensure that our website is
kept secure.
The use of any non-essential cookies is subject to your consent. You can also prevent us from using
your personal data in this way by contacting us (please see section 13) or using the ‘do not track’
functionality in your internet browser. If you enable such ‘do not track’ functionality, our website
may be less tailored to your needs and preferences.
3.6 To provide client services to you: We may process your personal data in order to provide various
supporting client services to you (such as where you contact us with a question in connection with a
service and/or request certain information from us). The legal basis on which we process your
personal data in these circumstances is the legitimate interests of both us and our clients. If you do
not provide us with the personal data we request from you for client services purposes, we may not
be able to fully answer your queries.
3.7 For marketing purposes: Where you have expressly opted in to receive marketing
communications from us, we will process your personal data to provide you with direct marketing
communications in line with the preferences you have provided. The legal basis on which we process
your personal data is your consent.
We may also contact you when you have instructed us previously and where we believe there are
additional services that may be of interest to you. The legal basis on which we will use your personal
data is our legitimate interest in providing you access to a complete service.
You are not under any obligation to provide us with your personal data for marketing purposes, and
you can withdraw your consent to your personal data being processed in this way or opt out from
receiving marketing at any time by contacting us (please see section 13) or, where relevant, by
following the unsubscribe link in every marketing communication you receive from us. If you do
choose to withdraw your consent or opt out, this will not mean that our processing of your personal
data before you withdrew your consent was unlawful.
3.8 For prospecting: In a business-to-business context we may make contact with individuals to
provide or seek information in connection with our services. The legal basis we rely on for making
contact with individuals and processing their personal data is our shared legitimate interests in doing
business together. When we make contact with individuals, they can exercise their right to object to
such contact from us (for more information about individuals’ rights, see section 11).
3.9 If our business is sold: We will transfer your personal data to a third party:
3.9.1 in the event that we sell or buy any business or assets, in which case we will disclose your
personal data to the prospective seller or buyer of such business or assets (at all times in accordance
with all applicable data protection laws); or
3.9.2 if ADL or substantially all of its assets are acquired by a third party, in which case personal data
held by ADL bout its clients (including those individuals who work for an on behalf of our clients) will
be one of the assets transferred to the purchaser, in each case, the legal basis on which we process
your data in these circumstances is our legitimate interest to ensure our business can be continued
by a purchaser. If you object to our use of personal data in this way, the relevant seller or buyer of
our business may not be able to provide services to you.
3.10 In certain circumstances we may also need to share your personal data if we are under a duty
to disclose or share personal data in order to comply with any legal obligation.
4 Categories of Information we collect from you
4.1 We will collect and process the following personal data about you:
4.2 Information you give us: This is information about you that you give us by filling in forms on our
website, registering for an event or seminar or by corresponding with us by phone, email, letter or
otherwise. It includes information you provide when you register on our website, participate in our
social media, post messages on our website and report a problem with our website. The information
you give us may include names, addresses, email addresses and phone numbers.
4.3 Information we collect about you: With regard to each of your visits to our website we will
automatically collect the following information:
4.3.1 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, screen resolution, operating system and platform; and
4.3.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to,
through and from our website (including date and time), 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.
4.4 Information we receive from other sources: We may receive information about you:
4.4.1 when you use our site. We are also working closely with third parties (such as business
partners, sub-contractors, advertising networks, analytics providers, hosting providers and search
information providers) from whom we may also receive information about you;
4.4.2 from third parties as part of any potential or actual purchase of a property, including sales
agents;
4.4.3 from our identity, anti-money laundering and / or credit checking providers.
4.5 We may process special categories of personal data, meaning personal data revealing:
4.5.1 racial or ethnic origin;
4.5.2 political opinions;
4.5.3 religious or philosophical beliefs or trade union membership;
4.5.4 genetic or biometric data that uniquely identifies you;
4.5.5 data concerning your health, sex life or sexual orientation; or
We will only do so (1) with your explicit consent; (2) where the processing is required by law; or (3)
where the processing is necessary for the establishment, exercise or defence of legal claims.
4.6 We do not collect data relating to criminal convictions or offences or related security measures
unless legally obliged to do so.
5 Categories of Recipients of Personal Data
5.1 The details in our privacy policy relating to third parties other than ADL are for your information
only. We are not responsible for the privacy policies or practices of third party recipients of your
personal data. Where third parties are recipients of your personal data from us, please ensure that
you read any information those third parties provide you about how, why and the legal basis for,
their processing of your personal data and make your own enquiries in respect of them.
5.2 Your personal data may be shared by us with external third parties for the purposes set out in
section 3. Section 5.3 below details our main third party recipients of personal data.
5.3 Your personal data may be shared by us with external third parties who provide support integral
to the provision of our services and enable us to operate our business. These include:
Service providers or consultants acting as processors based in the UK who provide IT, marketing,
software and system administration services, who onboard clients digitally or who otherwise protect
the security or integrity of our business.
Various cloud service providers.
Suppliers who provide email marketing, our CRM system, meeting booking software in the event you
are scheduled to attend a meeting at our offices, out of hours and overflow client assistance or
external IT support.
Payment processors.
Professional advisers acting as processors or joint controllers including lawyers, barristers,
mediators, arbitrators, bankers, auditors, insurers and employment and recruitment agencies based
in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance,
accounting and recruitment services.
Companies providing identity, anti-money laundering and / or credit checks.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
based in the UK (or other relevant jurisdictions) who require reporting of processing activities in
certain circumstances.
Third parties who provide staff screening and identification services in relation to prospective ADL
employees, officers and contractors.
Other third party companies where we have an agreement in place and only where you have agreed
that we may share their personal data with them.
6 Cookies
6.1 Our website uses cookies to distinguish you from other users of our website. This helps us to
provide you with a good experience when you browse our website and also allows us to improve our
website. By continuing to browse the website, users are agreeing to our use of cookies.
6.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of
your computer. We only use (and store) non-essential cookies on your computer’s browser or hard
drive if you provide your consent.
6.3 Please note that third parties (including, for example, advertising networks and providers of
external services like web traffic analysis services) may also use cookies, over which we have no
control. These cookies are likely to be analytical/performance cookies or targeting cookies.
6.4 You can block cookies by activating the setting on your browser that allows you to refuse the
setting of all or some cookies. However, if you use your browser settings to block all cookies
(including essential cookies) they may not be able to access all or parts of our website.
7 Uses made of the Information
7.1 We will combine the information you provide to us with information we collect about you. We
will use this information and the combined information for the purposes set out above (depending
on the types of information we receive).
7.2 The transmission of information via the internet is not completely secure. Although we will do
our best to protect your personal data, we cannot guarantee the security of your data transmitted to
our website; any transmission is at your own risk. Once we have received your information, we will
use strict procedures and security features to try to prevent unauthorised access.
8 Where we store Personal Data
8.1 Our clients or individuals who access our website may be based outside the United Kingdom so
the processing of their personal data will involve the transfer and storage of data outside the United
Kingdom. Some of our suppliers are based outside the United Kingdom. For example, in the
European Economic Area (EEA) so their processing of your personal data will involve a transfer of
data outside the United Kingdom.
8.2 Whenever we transfer personal data out of the United Kingdom, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is implemented:
8.2.1 We will only transfer personal data to countries covered by UK adequacy regulations. This is
currently countries in the EEA, Gibraltar, countries that are deemed to provide an adequate level of
protection for personal data by the European Commission and EU or EEA institutions, bodies, offices
or agencies.
8.2.2 Where we use certain service providers outside the United Kingdom, we may use specific
contracts approved for use in the United Kingdom which give personal data the same protection it
has in the United Kingdom.
8.3 If further information on the specific mechanism used by us when transferring your personal
data out of the combined area of the United Kingdom and EEA is required please contact us directly
(please see section 13).
8.4 All information you provide to us is stored on secure servers. Where we have given you (or
where you have chosen) a password which enables you to access certain parts of our website, you
are responsible for keeping this password confidential. You must not share your password with
anyone.
9 Data Security
9.1 We have put in place appropriate security measures to prevent personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Any personal data
we store (including payment transactions) will be stored encrypted at rest and via SSL technology
during transfer. In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only process
personal data on our instructions and they are subject to a duty of confidentiality.
10 Data Retention
10.1 Where you use our services, we will retain your data for a period of up to twelve (12) years,
after the services are performed, depending on the type, to ensure that we are able to assist you
should you have any questions or feedback in relation to our services, or to protect, or defend our
legal rights. Where our services consist of property related work, we will retain your data for a
period of twelve (12) years.
10.2 Where we have processed your personal data to provide you with marketing communications
with your consent, we may contact to ensure you are happy to continue receiving such
communications. If you tell us that you no longer wish to receive such communications, your
personal data will be removed from our lists.
10.3 Where we have processed your data for any other reason (such as where you have contacted
us with a question in connection with our services), subject to section 10.1, we may generally retain
your data for up to twelve (12) years and for certain departments a longer retention period may be
necessary.
10.4 In some circumstances you can ask us to delete your data: see section 11.1.3 below for further
information.
10.5 In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
11 Your Legal Rights
11.1 Under certain circumstances, you have rights under data protection laws in relation to your
personal data. You may have the right to:
11.1.1 Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.
11.1.2 Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.
11.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have the right
to ask us to delete or remove your personal data where you have successfully exercised your right to
object to processing (see below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local law. Note, however, that we
may not always be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
11.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want
to object to processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
11.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use it.
11.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you,
or a third party you have chosen, your personal data in a structured, commonly used, machine-
readable format. Note that this right only applies to automated information which you initially
provided consent for us to use or where we used the information to perform a contract with you.
11.1.7 Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you withdrew
your consent. If you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly.
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data
protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with
concerns before you approach the ICO so please contact us in the first instance.
11.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access personal data (or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no right to receive it. We may
also contact you to ask for further information in relation to your request to speed up our response.
11.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
12 Changes to Our Privacy Policy
Any changes we make to our privacy policy in the future will be posted on this webpage and, where
appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
13 Contact
Questions, comments and requests regarding this privacy policy are welcomed to either info@areligroup.co.uk or to ADL, 73 New Bond Street, London W1S 1RS or on 0333 242 0876