Website Privacy Notice

1. Introduction

Harrow Green is committed to protecting your personal information and being transparent about how we collect, use and store it. This Privacy Notice applies to personal information we collect and hold about individuals who:

• Visit our websites; and/or
• Choose to receive direct marketing communications, alerts or subscribed mailings from us.

Please read this Privacy Notice carefully, together with any other privacy notices we may provide on specific occasions when we collect or process personal data about you. This notice explains how and why we collect, store, use and share your personal information, your rights in relation to that information, and how to contact us or relevant supervisory authorities if you have a complaint.

When we refer to “Harrow Green”, “we”, “us” or “our”, we mean Harrow Green Ltd, the company responsible for processing your personal data in accordance with this Privacy Notice.

This Website Privacy Notice applies where personal data is collected via our websites, including but not limited to:

• https://www.harrowgreen.com/
• https://www.futureworkspaces.co.uk/

Where personal data is collected in other circumstances, an additional privacy notice may apply at the point of collection.

2. Scope

This Privacy Notice explains how Harrow Green collects and processes personal data gathered through our websites. It is intended for anyone who wishes to understand how we use the limited personal data collected online.

Our websites are not intended for children, and we do not knowingly collect personal data relating to children.

If you have any questions about this Privacy Notice or how your personal data is processed, please contact the Data Protection Officer using the details in Section 15.

3. Principles of Data Protection

When we refer to “personal data” or “personal information”, we mean information relating to an identifiable individual.

We process personal data in accordance with the following principles:

• Used lawfully, fairly and transparently
• Collected for specified, explicit and legitimate purposes
• Adequate, relevant and limited to what is necessary
• Accurate and kept up to date
• Retained only for as long as necessary
• Processed securely

We have policies, procedures and controls in place to ensure these principles are followed in practice.

Our websites may contain links to third-party websites. Harrow Green is not responsible for the privacy practices of third parties, and we encourage you to review their privacy notices separately.

4. Sources of Personal Data

We may collect personal data where:

• You provide it directly (e.g. completing forms, subscribing to updates, applying for roles)
• It is collected during our relationship with you
• You make data publicly available (e.g. via social media)
• It is received from business partners or service providers
• It is collected automatically when you use our websites
• It is created through interactions with us (e.g. correspondence, interviews, feedback).

5. Cookies

Our websites use cookies to collect limited technical data and analyse website usage. This helps us improve performance and user experience.

For more information, please refer to our Cookie Policy.

6. Personal Data Collected

The personal data we may collect includes:

• Personal details: name, title, address, email address, telephone number
• Consents and preferences: marketing preferences and subscriptions
• Website usage data: IP address, login credentials, access times
• Security-related information: where required for site access
• Correspondence: communications, enquiries, feedback or complaints.

7. Purpose and Use of Personal Data

We use personal data to:

• Operate, monitor and improve our websites
• Provide requested services or information
• Communicate with you, including responding to enquiries
• Deliver marketing communications (where permitted)
• Support recruitment activities
• Maintain security and prevent unauthorised access
• Comply with legal and regulatory obligations.

8. Legal Basis for Processing

We process personal data only where we have a lawful basis, including:

• Consent (e.g. marketing subscriptions)
• Performance of a contract or steps prior to entering into one
• Legal obligations
• Legitimate interests, such as:
  • Operating and improving our services
  • Preventing fraud and ensuring security
  • Managing relationships and communications
  • Establishing, exercising or defending legal claims.

Where legitimate interests apply, we balance these against your rights and freedoms.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. If you have any queries about our legal basis for using your personal information, please contact the DPO via the details set out in Section 15 below.

How do we justify our legitimate interests?

We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Exemptions

Harrow Green sometimes handles personal information relying on exemptions under the applicable data protection law. Any permitted handling of personal information under such exemptions will take priority over this Privacy Policy to the extent of any inconsistency.

9. Special Category & Criminal Offence Data

We do not collect special category or criminal offence data through our websites.

10. Direct Marketing

We may contact you with marketing communications where you have consented or where permitted by law. You can opt out at any time by:

• Using the unsubscribe link in emails
• Updating preferences via your account
• Emailing communications@harrowgreen.com or the DPO on dpo@harrowgreen.com

11. Sharing Personal Information

We may share personal data with:

• Group companies (where relevant)
• Service providers and professional advisers
• IT and infrastructure providers
• Regulatory or law enforcement bodies (where required).

All third parties are required to protect personal data and process it only in line with our instructions and applicable law.

Where personal data is transferred outside the UK, appropriate safeguards will be applied.

12. Security of Personal Data

We implement technical, administrative and physical measures to protect personal data, including:

• Access controls and passwords
• Encryption and firewalls
• Staff training and confidentiality obligations
• Secure deletion or anonymisation where data is no longer required.

13. Data Retention

We retain personal data only for as long as necessary for the purposes outlined in this notice or to meet legal requirements. When data is no longer required, it is securely deleted or anonymised.

14. Your Legal Rights

You have rights under data protection law, including the right to:

• Access your personal data
• Correct inaccurate data
• Object to processing
• Restrict processing
• Request data portability
• Withdraw consent
• Request erasure (in certain circumstances).

Requests should be submitted to the Data Protection Officer. We may ask you to verify your identity before responding.

15. Data Protection Contacts

Data Protection Officer

Harrow Green Ltd

Unit D Logistics City

Motherwell Way

Thurrock

Essex RM20 3AW

Email: dpo@harrowgreen.com

You also have the right to complain to the Information Commissioner’s Office (ICO).

16. Changes to This Privacy Notice

This Privacy Notice may be updated from time to time. Please check this page regularly for the latest version.